[SCCC] California Public Utilities Commission to set rules on BPLtesting Today 4/13/06

[Marty Woll]

Here's my comment letter to the CPUC, FWIW

Marty N6VI

Date: April 13, 2006



To: Commissioners, California Public Utilities Commission



From: Martin A. Woll



Re: Public Comment on CPUC April 13, 206 Agenda Item No. 55, R05-09-006 - 
Order Instituting Rulemaking concerning broadband over power line deployment 
by electric utilities in California



Honorable Commissioners:



Although my location in the Los Angeles aea prevents me from appearing in 
person today, I wish to submit my comments on the above-indicated item on 
today's agenda.



I am very concerned that any testing or approval of broadband-over-power 
line ("BPL") installations in our state be accompanied by adequate 
protection of radio services from the potentially devastating interference 
that can be caused by the unintentional radio-frequency emissions that 
characterize such systems.



I am a licensed Amateur Radio Operator engaged in providing communication 
support to the Los Angeles Fire Department under the Auxiliary Communication 
Service (ACS) and in public-service communications under the Amateur Radio 
Emergency Service (ARES).  The frequencies we use to provide our public 
service are subject to harmful interference by unintended radiators such as 
BPL installations, whose mode of transmission turns power lines into giant 
antennas that can carry radio noise and interference throughout the 
communities where we live, work and provide our services.  Some of the 
communication systems used by public safety and other public agencies are 
similarly subject to disruption from such interference, as are members of 
the public who engage in short-wave broadcast listening and other 
radio-related activities.



Although the Federal Communications Commission is ultimately responsible for 
the regulation of radio-frequency transmissions, intended and unintended 
alike, prior BPL tests around the country have resulted in well-documented 
cases of harmful and illegal interference that have been inadequately 
enforced.  Nowhere in the Report and Order before you today do I find any 
provisions for monitoring for or prompt elimination of interference caused 
by BPL installations.  We have a right to protection from "spectrum 
pollution" caused by systems that don't rely on radio frequencies but 
generate and propagate harmful radio signals as a side effect of their 
operation.



You rely on us, as licensed, trained volunteer Amateur Radio operators, to 
be there in disasters to support public safety.  We, in turn, rely on you to 
insure that appropriate monitoring, enforcement and controls are made an 
integral part of any BPL activities in California.



Very truly yours,



Martin A. Woll N6VI

LAFDACS, ARES, ARECC III

Chatsworth, California