[TenTec] BPL

[K5XS at aol.com]

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 at fyi.net writes:

> A