I'd also mention that all too many of those comments seem to be along the
lines of
"BPL will make HF unusable, don't do it"
When the FCC has said that BPL is a done deal, and they're just looking for
advice on regulation/procedure for implementation.
Here's my list of talking points:
1) FCC must weigh the public good of wider variety of access against
degradation in service. Does BPL provide sufficient additional capability,
particularly in a non-trivial rollout (undergrounding of utilities makes
access BPL kind of useless)
2) Part 15 kinds of limits is aimed at single consumer boxes stemming from
EMI/EMC issues in the 70's. Are the style of the regulatory requirement
philosophy of Part 15 appropriate to BPL (particularly the part carried on
MV feeders).
2a) The part 15 philosophy is two pronged: EMI/EMC limits on mfred
equipment is half; the other half is the responsibility of the equipment
operator to mitigate interference.
3) There is a great diversity between the manufacturers, installers,
owners, and users of BPL equipment. Who is responsible for finding and
fixing interference? The ISP using the BPL channel? The company owning the
BPL box? The power company which rents the usage of the wires to the BPL
box owner? etc. There is a mix of regulated and unregulated entities here,
and there are economic incentives to point the finger "somewhere else".
4) This is not a point source of interference, and identifying the source
is difficult:
a) Line source
b) low frequency so DF doesn't work like it does at VHF/UHF
c) The emission is broad band and noise like, not a narrow tone (unlike the
"wireless modem hookup, which was narrow band in the 80m band), making it
difficult to detect (total power radiometers?)
d) large scale deployment makes it worse
5) unforeseen effects
a) skywave propagation (international treaty obligations, etc.)
b) intermodulation (among various BPL signal components) from weathered
equipment, e.g., could produce "out of band" or spurious signals that are
hard to localize
6) Has testing adequately assessed the impact of the aging physical plant
on the viability of BPL as a legitimate competitor (since the FCC's mandate
is to foster competition).
a) Corroded wire, semiconductive insulation reduces effectiveness of wires
as transmission line
b) Does the economic plan address the gradual undergrounding of utilities.
c) Are there more competitive alternatives available (i.e. the replacement
of cables with fiber optic cored cabling, as currently used on HV
transmission lines)
7) Safety aspects
a) You've got to couple across the galvanic barrier of the distribution
transformer.
At 05:44 AM 7/3/2003 -0700, Michael Tope wrote:
>Fellow Reflectorites:
>
>Just a quick reminder that the deadline for filing
>comments in response to the FCC's Notice of
>Inquiry on Broadband over Powerline (BPL) is
>this coming MONDAY JULY 7, 2003. If you haven't
>had a chance to make your voice heard on this
>matter, please try to do so before the deadline.
>The Japanese government said no to BPL largely
>because the Japanese Amateur Radio community
>spoke loudly in opposition to the technology, so
>don't think your voice doesn't count.
>
>If you are not sure what to say, I have posted
>links on my website to a sampling of both short
>and long comments from amateurs that have
>already been filed with the FCC:
>
>www.dellroy.com/bpl.htm
>
>Additionally, a good tutorial on the BPL Notice
>of Inquiry with suggestions for appropriate reply
>comments can be found on the ARRL website
>at the following link:
>
>http://www.arrl.org/news/features/2003/06/19/2/?nc=1
>
>
>If you haven't read the NOI, you can download
>a copy at the following link:
>
>http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-03-100A1.doc
>
>
>You can view all comments filed in response
>to this NOI at the following webpage:
>
>http://gullfoss2.fcc.gov/prod/ecfs/comsrch_v2.cgi
>
>If you type "03-104" in the "Proceeding" field
>and then hit the "Retrieve Document List" button
>at the bottom, you will bring up a list of all of the
>comments filed in response to the BPL NOI.
>
>
>You can electronically file your comments at the
>following link:
>
>http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi
>
>Just follow the instructions found on this webpage
>(remember the NOI number is "03-104").
>
>
>Unless you relish having a 24/7 S-9 noise floor,
>please consider taking a little time to comment. This
>technology poses a VERY SERIOUS RFI threat to
>the HF and lower VHF frequency bands!
>
>Thanks and 73,
>
>Mike, W4EF...................
>
>
>
>
>
>
>
>
>
>_______________________________________________
>
>See: http://www.mscomputer.com for "Self Supporting Towers", "Wireless
>Weather Stations", and lot's more. Call Toll Free, 1-800-333-9041 with
>any questions and ask for Sherman, W2FLA.
>
>_______________________________________________
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