Topband: How to File BPL Comments With the FCC

[k3ky at erols.com]

On Thu, 07 Aug 2003 09:59:22 -0400, Bill Tippett wrote:
>    Several suggested I summarize how to do this:
>1.  Go to http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi
>2.  Enter only 03-104 in Box 1 (Proceeding).
>3.    (snip)
>
>Your comments will likely not appear until the next
>business day since it takes them awhile to process everything.
>Please DO comment before the August 20 window closes!  
This
>could be the most important thing you will ever do to insure we
>do not allow the FCC fill our bands with interference.  Let's 
prevent
>another Pandora's Box like the FCC gave us with Citizens 
Band!
>
>                73,  Bill  W4ZV
>
>P.S.  Much more info is available at ARRL's webpage:
>http://www.arrl.org/tis/info/HTML/plc/ including how to file.

I got some time Friday night late and wrote my Reply
Comments to the UPLC Comments. Just as I was ready
to transmit them to FCC, I saw the following on the ECFS
website, around 2-3AM Saturday morning:

"The ECFS will be unavailable for (sic) scheduled maintenance
from Saturday Agugust (sic) 16th, 2003 until Monsday (sic)
August 18th, 2003."

Hmmm, what peculiar timing. I would think this might put a
chill on last minute submissions. In my case, it simply 
stiffened my resolve.

Note: As of 4 AM on Monday the 18th, the site is still
partially non-functional. It now 'accepts' my comments but
returns an error message when I click on the confirmation
bar on the next page. I will keep trying. I hope this site
is not still broken when the 20th rolls around!

I spent quite a while writing my comments, and tried to
make the point that UPLC only states they have not
received any interference *reports*! Well, of course not!
I pointed out that folks who receive interference might not
know how to identify this new modulation type and might
therefore be hesitant to report it, lacking specifics and
therefore feeling unlikely ro receive any remediation from
FCC.

I also pointed out the obvious (at some length)- that the
BPL system is not only a radiator, it is an HF jamming
transmitter, whether or not it is defined as an
"intentional" radiator. I also repeated the well-made
comments from a DL ham that many milliwatt transmitters
combine via ionospheric skip to provide effective jamming
even at locations nowhere near a local BPL source.
I also pointed out that skip signals only follow propagation
and do not respect national borders, and that, in addition
to the howls of protest to be expected in the US, it is
likely that foreign governments may be filing protests
with the US as well.     73, K3KY