Fw: [TowerTalk] [Fwd: BPL Comments]
Robert Shohet
kq2m at earthlink.net
Fri Jul 2 12:27:11 EDT 2004
This is truly an ABSOLUTELY FABULOUS OBJECTIVE AND FACTUAL
summary and refutation of the shamelessly negligent FCC, Bush Administration
and BPL lobby statements and machinations.
Their collective agenda is clear and it has NEVER been about following the
regulations or paying attention to and dealing with LEGITIMATE FACTUAL
objections based on real-world real-time Science and Analysis as opposed to
hype, illusion and conflicts of interest.
How fortunate we are to have such a wonderful young mind in our hobby!
73
Bob KQ2M
> ----- Original Message -----
> From: "Tom Anderson" <WW5L at gte.net>
> To: <lsdxa at yahoogroups.com>
> Sent: Thursday, July 01, 2004 7:00 PM
> Subject: [TowerTalk] [Fwd: BPL Comments]
>
>
> >
> > Lone Star DX Association prez. Bill, W5SJ found the following BPL
> > comments and asked me to forward them to the reflector since he was
> > having bounce problems with his ISP and the reflector.
> >
> > Tom, WW5L
> >
> >
> >
> > Here's an interesting and worth reading BPL comment to FCC by a young
> ham.
> > Sent to me by Skip W5GAI...73, Bill, W5SJ
> > --------------------
> > Reply Comments by to the Notice of Proposed Rulemaking
> > by Benjamin S. Gelb, KF4KJQ, a graduating senior at Thomas Jefferson
> > High
> > School for
> > Science and Technology in Alexandria, Virginia.
> >
> > Before the
> > > > Federal Communications Commission
> > > > Washington, D.C. 20554
> > > >
> > > > In the Matter of
> > > > Carrier Current Systems, including Broadband over
> > > > Power Line Systems
> > > > )ET Docket No. 03-104
> > > >
> > > > Amendment of Part 15 regarding new requirements and measurement
> > guidelines
> > > for Access
> > > > Broadband over Power Line Systems
> > > > ) ET Docket No. 04-37
> > > >
> > > > To: The Commission
> > > >
> > > > Reply Comments to Notice of Proposed Rule Making (04-37)
> > > > Reply Comments by to the Notice of Proposed Rulemaking
> > > > by Benjamin S. Gelb
> > > >
> > > >
> > > > I have been a licensed Amateur Radio operator for eight years,
> > completed
> > > multiple physics
> > > > and electronics courses and have countless hours of hands-on
> experience
> > > experimenting with
> > > > radio and electronics equipment. I am a graduating senior at Thomas
> > > Jefferson High School
> > > > for
> > > > Science and Technology in Alexandria, Virginia and will be
> > attending MIT
> > > in the fall.
> > > >
> > > > The following are reply comments to various comments on the NRPM
> > (04-37)
> > > by Current
> > > > Technologies and Ambient Corporation.
> > > >
> > > > Current Technologies asserts that "Current Technologies
> implementation
> > of
> > > BPL is
> > > > noninterfering." I dispute Current Technologies' assertion that
> > "Current
> > > Technologies
> > > > implementation of BPL is non-interfering." There seems to be a
great
> > > division between
> > > > those who believe BPL will be a
> > > > source of harmful interference, and those who do not. I contend
this
> > > division is not a
> > > > result of "misunderstandings about how BPL works" on the part of
> > amateur
> > > radio operators
> > > > and many other individuals and organizations but rather a
> > misunderstanding
> > > of basic
> > > > physics on the part of
> > > > both the Commission and Current Technologies.
> > > >
> > > > Current Technologies states on page 14 that "Access BPL devices do
> not
> > use
> > > power lines as
> > > > antennas. They use power lines to conduct data signals, not radiate
> > them."
> > > > I'm sure that Current Technologies' goal is to conduct signals
rather
> > than
> > > radiate them.
> > > > Unfortunately, Current Technologies, no matter how much they wish
to
> > deny
> > > it, is bound by
> > > > the same laws of physics as every one else. When an RF current is
> > coupled
> > > into a
> > > > conductor, that conductor will radiate. Period. This is because of
> the
> > > electric and
> > > > magnetic fields created by the charge and current on the conductor.
> > > >
> > > > In coaxial cable the fields are contained by a shield at ground
> > potential.
> > > In balanced
> > > > line, equal and opposite fields from correctly spaced parallel
> > conductors
> > > mathematically
> > > > cancel. Power lines have RF characteristics that are irregular and
> > > variable, and do not
> > > > resemble either type of feed line. Therefore, BPL systems that
> > couple RF
> > > to the power line
> > > > will cause the power line to
> > > > radiate. Period.
> > > >
> > > > This has been shown to be true in the real world. A video1 produced
> by
> > the
> > > American Radio
> > > > Relay League demonstrates actual received interference in four
trial
> > > areas, one of which
> > > > is operated by Current Technologies.
> > > >
> > > > Because of the great disagreement between BPL promoters and those
who
> > > stand to be impacted
> > > > by the implementations of BPL systems, it seems that the Commission
> > ought
> > > to be obligated
> > > > to, at the very least, conduct some sort of real world testing of
its
> > own
> > > to determine the
> > > > radiation characteristics of power lines. To date, no effort to
> > validate
> > > the claims of
> > > > either side has been made by the Commission.
> > > >
> > > > So far, the Commission's attitude seems to be to accept the word of
> BPL
> > > manufacturers as
> > > > fact, no questions asked, despite the fact that many statements
made
> by
> > > BPL proponents and
> > > > subsequently parroted by the Commission are embarrassingly
> nonsensical
> > to
> > > someone with
> > > > even
> > > > the most rudimentary technical education (e.g. stating that the
> > > characteristics of a power
> > > > line are "somewhere between a waveguide and an antenna" in the
NPRM).
> > > Meanwhile, the
> > > > Commission has dismissed actual testing and analysis conducted by
> many
> > > technically adept
> > > > individuals, as
> > > > well as organizations such as the ARRL, AMRAD, and the NTIA as
> > > "unsupported claims" that
> > > > cannot "stand in the way of such an innovation as BPL."2
> > > >
> > > > Current Technologies states that the debate has been "complicated
> > further
> > > by the existence
> > > > of several different technical approaches to BPL, each of which
works
> > > differently."
> > > >
> > > > Current Technologies seems to say that while some implementations
> > of BPL
> > > may cause power
> > > > line radiation, its own implementation does not. This cannot be for
> the
> > > reason addressed
> > > > previously - all BPL systems will cause power line radiation - but
> > > assuming for a moment
> > > > that
> > > > Current has found a way around the laws of physics, it is clear
that
> > each
> > > of the
> > > > "different technical approaches" to BPL needs to be addressed
> > individually
> > > in the new
> > > > rules, because even if Current Technologies' implementation may not
> > cause
> > > interference,
> > > > other implementations will.
> > > > More curiously, no sufficient detail has been provided regarding
the
> > > operations of ANY of
> > > > the "different technical approaches" or what technical property
gives
> > > Current Technolgies'
> > > > system the ability to prevent power lines from radiating. It
> > boggles the
> > > mind to think
> > > > that the Commission plans to implement effective new rules without
> > > evaluating such
> > > > technical details.
> > > >
> > > > 1 ARRL BPL Video. http://216.167.96.120/BPL_Trial-web.mpg
> > > >
> > > > 2 The statement of Commissioner Adelstein on the NPRM.
> > > > Current Technologies' assertion that "BPL bandwidth has no effect
on
> > > interference" is
> > > > incorrect.
> > > >
> > > > This is not a matter of science, but one merely of common sense. A
> > wider
> > > signal bandwidth
> > > > means that BPL signals will occupy a greater set of frequencies.
> > Therefore
> > > there are more
> > > > frequencies where interference may occur. An isolated interfering
> > signal
> > > of narrow
> > > > bandwidth often does not constitute harmful interference because,
> while
> > > annoying, it can
> > > > be easily avoided by simply moving to another frequency. A broad
band
> > BPL
> > > signal, on the
> > > > other hand, could quite easily consume an entire BAND of operating
> > > frequencies, which are
> > > > normally only a few hundred kHz wide in the HF range. There is a
> grave
> > > difference between
> > > > a single narrow band signal and a broad band one like BPL.
> > > >
> > > > In its comments, Ambient cites President George W. Bush's recent
> speech
> > on
> > > broadband
> > > > technology. "So how is some guy in remote Wyoming going to get any
> > > broadband
> > > > technology? Regulatory policy has got to be wise and smart as we
> > encourage
> > > the spread of
> > > > this important technology. There needs to be technical standards to
> > make
> > > possible new
> > > > broadband technologies, such as the use of high-speed communication
> > > directly over power
> > > > lines. Power lines were for electricity; power lines can be used
for
> > > broadband technology.
> > > > So the technical standards need to be changed to encourage that.
> > > >
> > > > Ambient strongly supports the President's conclusion that ' ...
> > technical
> > > standards need
> > > > to be changed to encourage ...' the use of high-speed communication
> > > directly over power
> > > > lines."
> > > >
> > > > Ambient supports the conclusion that "technical standards need to
be
> > > changed," but what
> > > > about that guy out in Wyoming? Ambient seems to have artfully
> > chosen its
> > > words so it can
> > > > later deny promises of rural broadband. This is because, as I
> explained
> > in
> > > my original
> > > > comments to the
> > > > NPRM, Access BPL is no more viable in a rural area than cable or
DSL
> > > service. For the
> > > > benefit of the Commission, I have reproduced those earlier comments
> > here
> > > (paragraph
> > > > references refer to paragraphs in the NPRM).
> > > >
> > > > Access BPL will not provide service to rural areas for the same
> reasons
> > > that cable and DSL
> > > > are not available in rural areas. As is stated in paragraph 3,
access
> > BPL
> > > is a means
> > > > of "'last mile' delivery." A BPL signal can only travel a few
> thousand
> > > feet down a power
> > > > line. Neighborhood distribution lines still must be connected to
the
> > > Internet via fiber
> > > > optic
> > > > cable, as is outlined in paragraph 4. This is viable in an urban or
> > > suburban setting,
> > > > where the number of potential customers can justify the cost of the
> > fiber
> > > backhaul, but
> > > > will not float in a rural environment. The Commission seems to
> > subscribe
> > > to a
> > > > misconception that the national power grid can be magically
> > connected to
> > > BPL and turn
> > > > every outlet in America into an Internet connection. This is not
the
> > case.
> > > A substantial
> > > > amount of new infrastructure must be constructed in the area of BPL
> > > service, and therefore
> > > > will not promote BPL in rural areas any more than other broadband
> > > technologies.
> > > >
> > > > As the promise of rural service is the sole pretense for the
> > Commission's
> > > blind rush to
> > > > deploy BPL at all costs, perhaps it might behoove the Commission to
> > > consider BPL for what
> > > > it really is and reconsider its motivation for promoting it so
> > > relentlessly.
> > > >
> > > > Ambient states that it "believes that such coexistence of BPL with
> > other
> > > critical uses of
> > > > spectrum is a goal which can be achieved."
> > > >
> > > > The coexistence of Access BPL with other critical uses of spectrum
is
> > not
> > > a goal to be
> > > > achieved; it is a BEDROCK REQUIREMENT for operation under the
> > > non-interferences conditions
> > > > of the Part 15 rules. Compliance to this condition must be
> demonstrated
> > > PRIOR to operation
> > > > of Access
> > > > BPL systems. To apply regulatory power in any other way would
simply
> > turn
> > > Part 15 on its
> > > > head.
> > > >
> > > > To quote from the Part 15 label on the back of a small electronic
> > device
> > > on my desk, "this
> > > > device may not cause harmful interference." This is a stark
contrast
> > from
> > > the
> > > > interpretation of the rules regarding BPL, which goes something
like,
> > "BPL
> > > systems may
> > > > cause interference, as long as some effort is made to correct said
> > > interference once it is
> > > > identified by a party receiving interference." This is simply
> backward.
> > > The responsibility
> > > > of identifying and initiating corrective action for interference
must
> > not
> > > fall on the
> > > > licensed user of spectrum. Access BPL equipment
> > > > must be conclusively proven to be able to operate under
> > non-interference
> > > conditions
> > > > through a thorough, documented technical analysis. To date, no such
> > > analysis exists.
> > > >
> > > > There is a growing body of evidence, however, that suggests that
> Access
> > > BPL systems cannot
> > > > be implemented without causing interference. Technical analyses by
> > AMRAD,
> > > the ARRL and the
> > > > NTIA point to a severe interference problem. An official
interference
> > > complaint3 has been
> > > > filed
> > > > by E. Alan Croswell, a resident who lives in the area of Ambient's
> BPL
> > > trial in New York.
> > > >
> > > > In the interest of protecting licensed users of spectrum, the
> > Commission
> > > must undertake
> > > > some effort to more thoroughly evaluate the interferences risks of
> BPL.
> > To
> > > date, no
> > > > thorough technical analysis exists that suggests BPL can be
> implemented
> > in
> > > a manner
> > > > consistent with the noninterference conditions of the Part 15
> > rules, and
> > > many analyses, as
> > > > well as real world observation and simple physics, suggest the
> > contrary.
> > > >
> > > > Respectfully submitted,
> > > > Ben Gelb
> > > > A.R.S. KF4KJQ
> > > > 104 Windover Avenue
> > > > Vienna, VA 22180
> > > > (703) 281-1371
> > > > ben at gelbnet.com
> > > >
> > > > 3 E. Alan Crosswell. "Harmful interference from experimental
license
> > > WD2XEQ."
> > > > http://www.columbia.edu/~alan/bpl/complaint-fcc.pdf
> > > >
> > > > http://gullfoss2.fcc.gov/prod....6184039
> > > >
> > >
> >
> >
> >
> >
> > _______________________________________________
> >
> > See: http://www.mscomputer.com for "Self Supporting Towers", "Wireless
> Weather Stations", and lot's more. Call Toll Free, 1-800-333-9041 with
any
> questions and ask for Sherman, W2FLA.
> >
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