Under the present
rules, they must be tested at 3 typical locations. "

What's the FCC definition of "typical locations"??

There is none.

15.209 is the problem, it's grossly outdated, did not foresee anything
like BPL and the limits needs to be revised downward which is one
piece of this brawl. Ref: Tailpipe emissions regs, same basic problem,
different pollution media.

A good tailpipe analogy would be to consider the present tailpipe emissions
limits. We can still breathe with the number of cars that emit. Now, the
equivalent to BPL emissions occurring on several MHz at a time would be to
stack 100 cars on top of each other and have them all running at the same time.
The equivalent to building the system as large as an entire community is to do
that for every square inch of roadway. Would the emissions limits that work for
an occasional car passing by your home still work under those circumstances, or
would we all choke to death in a matter of minutes?

73,
Ed Hare, W1RFI