[RFI] RE: [TowerTalk] BPL: Presidential Backing

[Eric Rosenberg]

At the request of the TT administrators, AA6YQ responded directly to my 
email.  Except where noted, I will not quote all of his 
comments.  Dave's email response to me is his to post where and how he 
likes and I respect that. My comments are copied to the RFI reflector, 
as I strongly believe that this discussion on BPL, what it means and 
how one approaches it is a vital and vigorous one that should and must 
continue... on the RFI list!

That we may (and often do) disagree is a good thing.  That we respect 
each other's opinions and agree to disagree is even better.

That having been said,  I understand Dave's perspective. His career  as 
a "hardware engineer, a software engineer, an entrepreneur, an 
executive, and a ham" is quite distinguished and very, very 
successful.  He has given freely to the amateur radio community as 
author of the excellent -- and free -- DXLab  software suite.

In his original comments, Dave stated that  "If we're going to overcome 
BPL, it will be with better technology in the marketplace, not by 
plying lobbyists, politicians, and regulatory agencies with emotional 
arguments that appeal to no one but us",  to which I replied that this 
" is dead wrong.  The reality of this world is that policy is driven by 
politics and economics."

I inadvertently kept the words "appeal to no one but us", which left 
Dave to understandably assert that I was the naive one.  Having said 
that, it should be noted that politics is defined as the process by 
which one gets their way by plying lobbyists, politicians and 
regulatory agencies with emotional arguments:  "my <stuff> works, and I 
can prove it if you help me!"; "If I can get the <rules added, deleted, 
changed, modified> and sell my wares, I'll set up the factory in your 
district"; .. and the list of emotional arguments goes on.  Watch any 
legislative appropriations committee from the federal government 
through your town council. While the issue is not likely to be radio 
spectrum, it will often relate to 'infrastructure', 'progress' and the 
never defined 'leading edge' (is bulldozing un/under/less developed 
land to build more roads and parking lots to accommodate a "super 
store" that could likely kill off the older, established, but smaller, 
specialized shops in town necessarily a good thing for the community at 
large?).  The proliferation of  megastores and megamalls 
[WalMarts/KMarts, etc.] has been slowed down, modified, and even 
stopped due to emotional arguments by those who are directly impacted 
by their potential presence, even when all of the environmental impact 
and other unemotional reports may say otherwise.  I'm not saying that 
this is good or bad, only that politics do play a role in the 
determining the ultimate decision.

I said that " The other reality is that BPL in some form is here to 
stay until/unless the market kills it."  Dave replied (and I quote) 
"This was the primary point of my message, and yet you label me as 
naïve for taking this position."

My comment was not to disagree -- I, too, believe (hope?) that BPL will 
not survive in the market place.  My point was to suggest that in this 
instance, the market will not and cannot exist if the regulatory 
environment doesn't allow for it.  Which is where we are in the time 
line.

Dave said (and I quote again) " Of course, I'm being a somewhat more 
pro-active, in that I'm inciting the ham radio community to hasten 
BPL's death by providing a demonstrably better alternative." and asks 
if that is what I find naive.

While I am not in the least suggesting that the amateur radio community 
stop being creative and entrepreneurial towards the development of new 
technology, I do believe assuming any single approach is the one and 
only path to take is extremely naive.  The amateur radio community has 
a rich history of developing new, better, and less expensive 
technologies, don't ever forget that in the end, policy makers are 
pressured by time (elections and referendums) and money (unbalanced 
budgets and ever-changing tax bases), demands from constituents 
(residents, workforce and employers/industry).  In my experience 
working in the regulatory world, the single most asked question by a 
regulator when I applied for a license or asked for a policy decision 
was "what happens to me if and when I grant you this license or issue a 
decree."  Never forget that all politics are local... and once elected, 
a politician's most important job is to stay in office.

Dave rightly commented that the issue at hand -- at the present moment 
-- is deploying BPL in the United States, not deploying BPL around the 
world.  What he might not understand is that the world, rightly or 
wrongly, looks at United States and more often than not follows our 
lead.  While it is true that we have made what some consider to have 
been mistakes that have hurt us since (the Teledesic spectrum 
allocation rammed through the WRC in the early 1990's is often 
cited),  in all too many cases, other countries have followed our lead 
in the radiocommunications regulatory world.  What happens in the USA 
is very often -- and soon thereafter -- reflected elsewhere.  I have 
been personally involved in licensing and policy situations where a 
foreign country that had been opposed to my employer's entering and 
operating in their country welcomed us once the US ruled in our favor.

The question has come up as to who are large users of HF in the 
USA.  The Departments of Defense, Homeland Security and Transportation 
immediately come to mind. While I believe it can be safely said that 
their systems were in a state of decline until September 11, this 
appears to no longer be the case.  They all are looking for new 
technology, recognizing that HF is an asset that is already in place, 
costs virtually nothing to operate (no airtime or other fees) and is a 
technology they all are familiar with.  That these agencies don't speak 
up is, from what I am told, cultural and political. Here's our chance 
to change things!

Dave asked (quoting) "What, precisely, is "the reality of our 
predicament"? And exactly what has  he ARRL achieved in its defense of 
"our position"?"

The predicament? A technology (BPL) has been "approved" that threatens 
incumbent users (government, maritime, aeronautical, amateur) of the 
newly allocated shared spectrum.  BPL remains here, the regulations 
governing it appear to be broad, the enforcement mechanism untested.

What has the ARRL achieved in defense of "our" position?  Using what 
limited resources it has (the ARRL does not have the war chest that the 
Nextels, Microsofts and other commercial entities have), the ARRL 
brought the issue to the above named incumbents, who likely would not 
have paid much attention to it (not sexy enough for them), brought the 
subject to the international level, slowed down approval in the USA 
(this issue has been going on for some time now) and elsewhere.  If not 
for their efforts, the impact could have been far, far worse.

As this debate continues, I'll be curious to see the extent of the BPL 
and power industry's lobbying efforts, how much money they spend, and 
where their money comes from.  As I think we all agree, there is the 
potential of a lot of money to be made by the power companies, whose 
ultimate goal is to take a piece of the broadband delivery pie.  To 
that end, I wonder where the satellite (EchoStar, DirecTV, etc.) and 
wireline broadband delivery companies (the ROCKS) sit on this issue.

In conclusion, I respect but disagree with Dave's comments quoted 
above.  This is not a personal fight.  To each their own, and may we 
agree to disagree.  Likewise, this is not a competition to see whose 
approach is the better one.   Our goal, I believe, is to limit the 
damage the deployment of BPL systems can cause to incumbent, viable, 
and working (HF) communications systems in the US and ultimately 
worldwide.

With that, let's respect the request of the TowerTalk administrators 
and move this to the RFI reflector.

Eric W3DQ
Washington, DC