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[RFI] Correspondance with UTC

To: "RFI Reflector " <rfi@contesting.com>
Subject: [RFI] Correspondance with UTC
From: "EDWARDS, EDDIE J" <eedwards@oppd.com>
Date: Mon, 12 Apr 2004 10:03:55 -0500
List-post: <mailto:rfi@contesting.com>
Thought I'd share this exchange I had with the UTC (United Telecom
Council).  It can be read top to bottom.  I just can't believe he does
not see all the similarities.  

I find it interesting that when there's any chance of interference to
utility communications systems, the UTC will go all out to fight it.
But when they want their members to roll out equipment that will cause
interference, it's no big deal.  I've removed the names of the UTC
personnel since my company belongs to UTC and I just wanted to share the
info, not stir up trouble for the writer who gave me his honest answer
even if I disagree with it.

Am I being overly sensitive here to the statement below?: "By
comparison, the BPL NPRM provides specific rules for real equipment
(unintentional radiating RF only a few feet from the line) to provide
real services that are being thoroughly tested ahead of time by
utilities that have a great track record when it comes to interference
and that ultimately bear the responsibility of fixing any interference
they cause."

It seems to imply that HF radio services don't "provide real services".
I keep hearing this theme in many pro-BPL articles.  I guess Tornado and
Storm spotting isn't a "real service" anymore, so I won't be going out
anymore this year and risking my life providing such a fake service
(with much sarcasm!).  And I know we don't use HF for SKYWARN, but
without HF, I won't be active in Ham Radio to do anymore of these fake
services along with a lot of others.

And where the hell did he hear that utilities have a "great track record
when it comes to interference"?  Talk about the Land of OZ.

73, de ed -K0iL

-----Original Message-----
From: UTC Alert 
Sent: Tuesday, April 06, 2004 3:44 PM
To: Alert
Subject: UTC Alert - April 6, 2004

Technical Division Chair Needs Your Help 
in Interference Temperature Proceeding 

The Chairman of UTC's Technical Division has asked for
additional member support in responding to a Federal Communications
Commission initiative that could threaten the reliability and integrity
of our wireless systems. While meant to promote spectrum efficiency, the
FCC's Interference Temperature Notice of Inquiry/Notice of Proposed
Rulemaking (ET Docket No. 03-237) could subject microwave systems in the
6 GHz and 12/13 GHz bands -- and eventually, all bands -- to harmful and
destructive interference. Without these dependable communications links,
the utility industry would be unable to operate and control the nation's
energy systems in a safe, timely and economical manner. 

Interference is presently minimized through coordination of the
frequency, radiated power and location of individual transmitters. Under
the interference temperature model, a maximum noise level would be set
for an entire band and new systems could be placed in service if it is
anticipated that the interference temperature limit would not be
exceeded. Several methods are proposed for monitoring interference
temperature, but there is no guarantee that any of these theoretical
systems will work or that licensed systems will not receive harmful
interference. Because new users would be unlicensed, locating each
offender and resolving interference would be an impossible task. 

While many user communities are deeply concerned about this proceeding,
few have the resources to answer this threat on a technical basis. UTC
needs your support more than ever. Interference to critical
telecommunications systems could place the entire energy system in
jeopardy. The FCC must be made aware of our concerns and be fully
informed of the dangers inherent in the interference temperature
proposal. Please contact >>>snip<<< for information on how you can
help to safeguard our telecommunications systems. 

-----Original Message-----
Sent: Thursday, April 08, 2004 11:40 AM
Subject: Re: Technical Division Chair Needs Your Help (UTC Alert)

I'm more than a little curious.  How can UTC be concerned over the
"Interference Temperature" issue and yet, through UPLC, support BPL
technology which appears to cause harmful interference to licensed users
on a band of frequencies with very unique and rare propagation
characteristics not found elsewhere in the RF spectrum?  Doesn't the
right hand know what the left hand is doing within UTC?  

If harmful interference is found to be acceptable in one band, that
standard will most likely be applied by the FCC in other bands as well
including utility frequencies.

 Eddie Edwards

-----Original Message-----
From: UTC
Subject: RE: Technical Division Chair Needs Your Help (UTC Alert)

Dear Mr. Edwards:

Thank you for your inquiry concerning the Interference Temperature
proceeding at the FCC.  

While there are some superficial similarities between that proceeding
and the BPL NPRM, they end there.  The interference temperature metric
is a concept that has no equipment and has not been tested anywhere in
the lab or in the field.  The Commission is simultaneously inquiring
whether this concept could/should be used in all spectrum bands (not
just the HF bands), and it is specifically proposing to test the idea
out in the 6 GHz/12 GHz band without any details as to how this would
work.  As UTC pointed out in its comments on the record, the 6 GHz band
is home to critical infrastructure microwave systems that help to
support the reliability/security/safety of electric transmission and
other utility distribution systems.  How the Commission came up with the
idea and to test it in the 6 GHz band is puzzling.  But, we have told
the FCC that it needs to study this more before testing it in any band,
let alone the 6 GHz band.  We have also told the FCC they need to
protect the CI communications in the 6 GHz band if they proceed with the
proposal to test there.  

The prospect of intentional radiators that by design emit RF for miles
(e.g. 802.16) operating in close proximity on the same frequencies with
CI systems that throw circuit breakers and close gas valves is truly
frightening.  By comparison, the BPL NPRM provides specific rules for
real equipment (unintentional radiating RF only a few feet from the
line) to provide real services that are being thoroughly tested ahead of
time by utilities that have a great track record when it comes to
interference and that ultimately bear the responsibility of fixing any
interference they cause.  

UTC's position in the BPL NPRM is entirely consistent with its position
in the 6 GHz band.  We are mindful of interference to our systems in the
6 GHz band and from our BPL operations in the HF bands.  We believe that
regulatory certainty about interference is necessary for the
interference temperature concept to work and for BPL to be deployed.  We
keep an open mind on improving spectrum management by permitting
unlicensed operations in existing bands, provided that it does not
compromise licensed communications.  Finally, we are committed to
improving the quality of life for the communities we serve, by both
enabling our infrastructure to provide commercial broadband services via
BPL to rural and underserved customers, and by ensuring that the
essential services that we provide to the public continue to be
delivered safely, efficiently and reliably, thanks to private internal
communications systems that have adequate spectrum and are free from

Once again, thanks for your feedback.  I look forward to our continued

Best regards,

United Telecom Council

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