Ron,
Here is what I wrote Commisioner Abernathy following her remarks.
73,
Bernie K5XS
Dear Ms. Abernathy,
I just read a transcript of your "Reaching Broadband Nirvana" comments given at
the United PowerLine Council Annual Conference.
Your e-mail box is no doubt being flooded with those who would argue that
broadband over powerline (BPL) technology poses serious technical risks to
licensed users of radio frequency spectrum. I am inclined to agree with them.
I would offer, however, that I am intrigued by and strongly support your
"Nascent Services Doctrine." I think it's a refreshing approach to prevent new
technologies from being crushed by the burdens of archaic regulation. Bravo
for you! It's a great line of thought and I salute you for your ingenuity in
developing it.
I would ask, however, for you to consider fully the implications of each of the
nascent technologies as they are proposed and before they are allowed to
propagate. In the case of BPL, for example, I am convinced the risks of its
implementation are substantial. Test results I have seen suggest strongly
that implementation of BPL in its present form will generate sufficient noise
to saturate spectrum at near-, mid- and far-distances. This appears to be
particularly pronounced in the high frequency range (3 - 30 MHz), and all users
of that spectrum will be negatively impacted by implementation of current BPL
technologies.
I believe the Commission should consider carefully the technical risks and
merits of BPL versus the risks posed to licensed spectrum users. In the case
of the Amateur Radio Service, for example, the loss of access to HF spectrum
would render the service incapable of fulfilling its substantial role in
providing emergency communications support as it has done repeatedly and
reliably in any number of disasters. As the ARRL can show you, in the past
few years alone the Amateur Radio Service has proven invaluable as a source of
no-cost emergency communications to local, municipal, state and national
disaster relief operations. Without assured access to interference-free
spectrum, it would be incapable of performing those services.
Again, I commend you for your active role as a Commission leader in thought.
We truly need a Nascent Services Doctrine, and I am glad you have brought it
into being. I'd just ask that you consider carefully the impact of each of
those services before they are allowed to deploy in the marketplace, and that
you would not support implementation of those technologies in forms that deny
the use of spectrum to other valuable services.
Sincerely,
Bernie Skoch
Brigadier General, USAF (Ret)
In a message dated 9/26/2003 4:22:27 PM Eastern Daylight Time, wn3vaw@fyi.net
writes:
> A
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