[TowerTalk] [Fwd: BPL Comments]

[Tom Anderson <WW5L@gte.net>]

Lone Star DX Association prez. Bill, W5SJ found the following BPL 
comments and asked me to forward them to the reflector since he was 
having bounce problems with his ISP and the reflector.

Tom, WW5L



 Here's an interesting and worth reading BPL comment to FCC by a young ham.
Sent to me by Skip W5GAI...73, Bill, W5SJ
--------------------
Reply Comments by to the Notice of Proposed Rulemaking
by Benjamin S. Gelb, KF4KJQ, a graduating senior at Thomas Jefferson
High
 School for
 Science and Technology in Alexandria, Virginia.

Before the
> > Federal Communications Commission
> > Washington, D.C. 20554
> >
> > In the Matter of
> > Carrier Current Systems, including Broadband over
> > Power Line Systems
> > )ET Docket No. 03-104
> >
> > Amendment of Part 15 regarding new requirements and measurement
guidelines
> for Access
> > Broadband over Power Line Systems
> > ) ET Docket No. 04-37
> >
> > To: The Commission
> >
> > Reply Comments to Notice of Proposed Rule Making (04-37)
> > Reply Comments by to the Notice of Proposed Rulemaking
> > by Benjamin S. Gelb
> >
> >
> > I have been a licensed Amateur Radio operator for eight years, 
completed
> multiple physics
> > and electronics courses and have countless hours of hands-on experience
> experimenting with
> > radio and electronics equipment. I am a graduating senior at Thomas
> Jefferson High School
> > for
> > Science and Technology in Alexandria, Virginia and will be 
attending MIT
> in the fall.
> >
> > The following are reply comments to various comments on the NRPM 
(04-37)
> by Current
> > Technologies and Ambient Corporation.
> >
> > Current Technologies asserts that "Current Technologies implementation
of
> BPL is
> > noninterfering."  I dispute Current Technologies' assertion that
"Current
> Technologies
> > implementation of BPL is non-interfering." There seems to be a great
> division between
> > those who believe BPL will be a
> > source of harmful interference, and those who do not. I contend this
> division is not a
> > result of "misunderstandings about how BPL works" on the part of 
amateur
> radio operators
> > and many other individuals and organizations but rather a
misunderstanding
> of basic
> > physics on the part of
> > both the Commission and Current Technologies.
> >
> > Current Technologies states on page 14 that "Access BPL devices do not
use
> power lines as
> > antennas. They use power lines to conduct data signals, not radiate
them."
> > I'm sure that Current Technologies' goal is to conduct signals rather
than
> radiate them.
> > Unfortunately, Current Technologies, no matter how much they wish to
deny
> it, is bound by
> > the same laws of physics as every one else. When an RF current is
coupled
> into a
> > conductor, that conductor will radiate. Period. This is because of the
> electric and
> > magnetic fields created by the charge and current on the conductor.
> >
> > In coaxial cable the fields are contained by a shield at ground
potential.
> In balanced
> > line, equal and opposite fields from correctly spaced parallel
conductors
> mathematically
> > cancel. Power lines have RF characteristics that are irregular and
> variable, and do not
> > resemble either type of feed line. Therefore, BPL systems that 
couple RF
> to the power line
> > will cause the power line to
> > radiate. Period.
> >
> > This has been shown to be true in the real world. A video1 produced by
the
> American Radio
> > Relay League demonstrates actual received interference in four trial
> areas, one of which
> > is operated by Current Technologies.
> >
> > Because of the great disagreement between BPL promoters and those who
> stand to be impacted
> > by the implementations of BPL systems, it seems that the Commission
ought
> to be obligated
> > to, at the very least, conduct some sort of real world testing of its
own
> to determine the
> > radiation characteristics of power lines. To date, no effort to 
validate
> the claims of
> > either side has been made by the Commission.
> >
> > So far, the Commission's attitude seems to be to accept the word of BPL
> manufacturers as
> > fact, no questions asked, despite the fact that many statements made by
> BPL proponents and
> > subsequently parroted by the Commission are embarrassingly nonsensical
to
> someone with
> > even
> > the most rudimentary technical education (e.g. stating that the
> characteristics of a power
> > line are "somewhere between a waveguide and an antenna" in the NPRM).
> Meanwhile, the
> > Commission has dismissed actual testing and analysis conducted by many
> technically adept
> > individuals, as
> > well as organizations such as the ARRL, AMRAD, and the NTIA as
> "unsupported claims" that
> > cannot "stand in the way of such an innovation as BPL."2
> >
> > Current Technologies states that the debate has been "complicated
further
> by the existence
> > of several different technical approaches to BPL, each of which works
> differently."
> >
> > Current Technologies seems to say that while some implementations 
of BPL
> may cause power
> > line radiation, its own implementation does not. This cannot be for the
> reason addressed
> > previously - all BPL systems will cause power line radiation - but
> assuming for a moment
> > that
> > Current has found a way around the laws of physics, it is clear that
each
> of the
> > "different technical approaches" to BPL needs to be addressed
individually
> in the new
> > rules, because even if Current Technologies' implementation may not
cause
> interference,
> > other implementations will.
> > More curiously, no sufficient detail has been provided regarding the
> operations of ANY of
> > the "different technical approaches" or what technical property gives
> Current Technolgies'
> > system the ability to prevent power lines from radiating. It 
boggles the
> mind to think
> > that the Commission plans to implement effective new rules without
> evaluating such
> > technical details.
> >
> > 1 ARRL BPL Video. http://216.167.96.120/BPL_Trial-web.mpg
> >
> > 2 The statement of Commissioner Adelstein on the NPRM.
> > Current Technologies' assertion that "BPL bandwidth has no effect on
> interference" is
> > incorrect.
> >
> > This is not a matter of science, but one merely of common sense. A 
wider
> signal bandwidth
> > means that BPL signals will occupy a greater set of frequencies.
Therefore
> there are more
> > frequencies where interference may occur. An isolated interfering 
signal
> of narrow
> > bandwidth often does not constitute harmful interference because, while
> annoying, it can
> > be easily avoided by simply moving to another frequency. A broad band
BPL
> signal, on the
> > other hand, could quite easily consume an entire BAND of operating
> frequencies, which are
> > normally only a few hundred kHz wide in the HF range. There is a grave
> difference between
> > a single narrow band signal and a broad band one like BPL.
> >
> > In its comments, Ambient cites President George W. Bush's recent speech
on
> broadband
> > technology.  "So how is some guy in remote Wyoming going to get any
> broadband
> > technology? Regulatory policy has got to be wise and smart as we
encourage
> the spread of
> > this important technology. There needs to be technical standards to 
make
> possible new
> > broadband technologies, such as the use of high-speed communication
> directly over power
> > lines. Power lines were for electricity; power lines can be used for
> broadband technology.
> > So the technical standards need to be changed to encourage that.
> >
> > Ambient strongly supports the President's conclusion that ' ...
technical
> standards need
> > to be changed to encourage ...' the use of high-speed communication
> directly over power
> > lines."
> >
> > Ambient supports the conclusion that "technical standards need to be
> changed," but what
> > about that guy out in Wyoming? Ambient seems to have artfully 
chosen its
> words so it can
> > later deny promises of rural broadband. This is because, as I explained
in
> my original
> > comments to the
> > NPRM, Access BPL is no more viable in a rural area than cable or DSL
> service. For the
> > benefit of the Commission, I have reproduced those earlier comments 
here
> (paragraph
> > references refer to paragraphs in the NPRM).
> >
> > Access BPL will not provide service to rural areas for the same reasons
> that cable and DSL
> > are not available in rural areas. As is stated in paragraph 3, access
BPL
> is a means
> > of "'last mile' delivery." A BPL signal can only travel a few thousand
> feet down a power
> > line. Neighborhood distribution lines still must be connected to the
> Internet via fiber
> > optic
> > cable, as is outlined in paragraph 4. This is viable in an urban or
> suburban setting,
> > where the number of potential customers can justify the cost of the
fiber
> backhaul, but
> > will not float in a rural environment. The Commission seems to 
subscribe
> to a
> > misconception that the national power grid can be magically 
connected to
> BPL and turn
> > every outlet in America into an Internet connection. This is not the
case.
> A substantial
> > amount of new infrastructure must be constructed in the area of BPL
> service, and therefore
> > will not promote BPL in rural areas any more than other broadband
> technologies.
> >
> > As the promise of rural service is the sole pretense for the
Commission's
> blind rush to
> > deploy BPL at all costs, perhaps it might behoove the Commission to
> consider BPL for what
> > it really is and reconsider its motivation for promoting it so
> relentlessly.
> >
> > Ambient states that it "believes that such coexistence of BPL with 
other
> critical uses of
> > spectrum is a goal which can be achieved."
> >
> > The coexistence of Access BPL with other critical uses of spectrum is
not
> a goal to be
> > achieved; it is a BEDROCK REQUIREMENT for operation under the
> non-interferences conditions
> > of the Part 15 rules. Compliance to this condition must be demonstrated
> PRIOR to operation
> > of Access
> > BPL systems. To apply regulatory power in any other way would simply
turn
> Part 15 on its
> > head.
> >
> > To quote from the Part 15 label on the back of a small electronic 
device
> on my desk, "this
> > device may not cause harmful interference." This is a stark contrast
from
> the
> > interpretation of the rules regarding BPL, which goes something like,
"BPL
> systems may
> > cause interference, as long as some effort is made to correct said
> interference once it is
> > identified by a party receiving interference." This is simply backward.
> The responsibility
> > of identifying and initiating corrective action for interference must
not
> fall on the
> > licensed user of spectrum. Access BPL equipment
> > must be conclusively proven to be able to operate under 
non-interference
> conditions
> > through a thorough, documented technical analysis. To date, no such
> analysis exists.
> >
> > There is a growing body of evidence, however, that suggests that Access
> BPL systems cannot
> > be implemented without causing interference. Technical analyses by
AMRAD,
> the ARRL and the
> > NTIA point to a severe interference problem. An official interference
> complaint3 has been
> > filed
> > by E. Alan Croswell, a resident who lives in the area of Ambient's BPL
> trial in New York.
> >
> > In the interest of protecting licensed users of spectrum, the 
Commission
> must undertake
> > some effort to more thoroughly evaluate the interferences risks of BPL.
To
> date, no
> > thorough technical analysis exists that suggests BPL can be implemented
in
> a manner
> > consistent with the noninterference conditions of the Part 15 
rules, and
> many analyses, as
> > well as real world observation and simple physics, suggest the 
contrary.
> >
> > Respectfully submitted,
> > Ben Gelb
> > A.R.S. KF4KJQ
> > 104 Windover Avenue
> > Vienna, VA 22180
> > (703) 281-1371
> > ben@gelbnet.com
> >
> > 3 E. Alan Crosswell. "Harmful interference from experimental license
> WD2XEQ."
> > http://www.columbia.edu/~alan/bpl/complaint-fcc.pdf
> >
> > http://gullfoss2.fcc.gov/prod....6184039
> >
>




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