This is what my reply comments said: Note the reference to the recent power
outage as another reason to not allow another add on to present over taxed
power lines. 73,
Stuart, K5KVH
"In reply to the named docket 03-104 (BPL) I concur with the comments of
ARRL Inc., the national association for Amateur Radio; those of the IEEE,
Television Broadcasters, Shortwave Broadcasters, and similar presently
licensed users of the HF spectrum from 1 to 80 MHz.
In the comments and replies of the proponents of BPL, no evidence of
comprehensive RF interference test results of BPL RFI to other licensed
services has been performed or presented.
It would not be good engineering practice to authorize an increase in Part
15 device powers without extensive RFI testing to insure such devices do not
interfere with any licensed radio service. It is not sufficient in today's
market to try to enforce cessation of use by consumer/ owners after the
interference blocks licensed radio spectrum users reception or transmission.
The approval of BPL would not encourage other radio spectrum users to use
minimum power for transmission, because the minimum power required would be
raised to maximum allowable limits, due to overwhelming interference from
Test BPL sites already observed by not only ARRL but independent engineers
of RFI Inc., in travels across the USA.
BPL has not been shown to be compatible with existing users of the HF
spectrum, and would be a threat to the public, since it would block
emergency radio communications by FEMA emergency radio networks, the
American Red Cross, Salvation Army, and other emergency radio networks.
These networks support weather emergency communications on behalf of NOAA,
and the Homeland Security Dept. emergency communications in any type of
disaster or attack upon conventional communications.
The use of widely spaced power transmission conductors for an RF
transmission medium is flawed as the conductors are not suited to shielded
transmission of RF data. Radiation resulting in interference to other
licensed users and listeners of the HF spectrum would result.
The need for RF bypasses around transformers would further aggravate the
questionable reliability of the Power System. The recent multi state
blackout shows the transmission paths are unreliable and in a questionable
state for the transmission of AC power let alone piggy backed RF data of
BPL.
For the above stated reasons and other engineering considerations of
adequate service of Broadband data by non interfering means, BPL over Power
Lines should NOT be developed. It would only cause more problems for
present interference receiving, licensed users, of the HF spectrum. The
ambient RF noise level can be shown to have become higher over the last
several years, and BPL should not be added to that increase in spectrum
noise pollution."
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