Topband: NTIA Letter to FCC re: BPL

[Donald Chester]

Just as NTIA threw a spoke in the wheel with the amateur 60m. band, they 
apparently have serious misgivings regarding BPL, although their concern 
seems to be focused primarily on the 30-50 mHz range. The following  letter 
appears on the FCC's website  displaying filed comments.


Mr. Edmond J. Thomas Ju 12003
UNITED STATES DEPARTMENT OF COMMERCE
National Telecommunications and
Information Administration
Washington 0 C. 20230

Chief, Office of Engineering and Technology
Federal Communications Commission RECEIVED
445 1 2 ‘ ~ Street. sw
Washington, D.C. 20554

Subject:
JuL 1 7 2003
Fede~l Cornmurnms hmw
Request for Waiver filed by Current Tec~o?8&?%?@for IC f Broadband
over Power Line (BPL), February 6,2003

“Inquiry Regarding Carrier Current Systems, including Broadband over
Power Line Systems,” Federal Communications Commission, ET Docket
No. 03-104, released April 28,2003

Refeience:

Dear Mr. Thomas:
The National Telecommunications and Information Administration (NTIA),
Oflice of Spectrum Management reviewed the subject request for a permanent 
waiver of the field strength limit specified for Class B emissions in Part 
15 of the Commission’s Rules. While noting that a number of limiting 
conditions are proposed, NTIA believes that a permanent waiver should not be 
granted at this time because of the present lack of measurements and 
analyses showing that any resulting interference to allocated services would 
be at acceptable levels. One concern is that the proposed pole-mounted 
interface devices and outdoor power lines used for BPL could be located 
close to public safety mobile and base station receivers operating in the 
30-50 MHz fiequencyrange and consequently many of the intervening signal 
paths would be unobstructed. The unobstnicted and ubiquitous nature of this 
BPL application, and perhaps other aspects of
BPL, differs considerably from the situations presently found in typical 
unintentional radiators authorized under the Commission’s Part 15 Rules. We 
also have concerns regarding compliance measurement techniques for BPL 
systems and the characterization of emissions from a BPL system for use in 
compatibility studies. We believe the continued operation of BPL systems on 
an experimental basis will provide an excellent oppommity to examine many of 
the issues raised by the Commission in the above-referenced Notice of 
Inquiry (NOI). NTLA has begun technical studies to address some of the 
interference-related issues raised in the NOI, including measurements and 
analyses, which will help deteimine the least constraining BPL emission 
Iimits that would preclude unacceptable interference. Our Spectrum 
Engineering and Analysis Division is conducting these studies and developing 
a measurement plan with the Institute for Telecommunication Sciences (ITS). 
Measurements at two BPL demonstration sites are tentatively scheduled to 
start late in July 2003.

We understand that the Commission also may be conducting BPL measurements.
In order to establish the best possible common technical basis for our 
respective analyses, I siiggest that our BPL measurement efforts be 
coordinated at a11 appropriate technical working level. We look forward to 
working with the Commission's staff in developing the appropriate regulatory 
franiework to permit BPL to evolve while protecting Federal and public 
safety systems.

Sincerely,
Fredrick MQ- R. Wentland
Associate Administrator
Office of Spectnim Management

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