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Old February 8th 04, 02:18 AM
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Default BPL - Comments on the original Inquiry document

FCC 03-100 Before the

Federal Communications Commission

Washington, D.C. 20554

Inquiry Regarding Carrier Current Systems, including Broadband over Power Line Systems

Docket No. 03-104

By the Commission: Chairman Powell and Commissioners: Abernathy, Martin, and Adelstein issuing

separate statements; Commissioner Copps approving in part, concurring in

part, and issuing a statement.

I. Introduction
1)The Commission is initiating this inquiry to obtain information on a variety of issues related to Broadband over Power Line (BPL) systems. BPL systems are new types of carrier current system that operate on an unlicensed basis under Part 15 of the Commission's rules. BPL systems use existing electrical power lines as a transmission medium to provide high-speed communications capabilities by coupling RF energy onto the power line. Because power lines reach virtually every community in the country, BPL could play an important role in providing additional competition in the offering of broadband infrastructure to the American home and consumers.

And because those power lines make fantastic antenna radiation arrays for all signal components above a few hundred kilohertz, only a mindless bureaucracy comprised of political appointments would ever consider using them for high-speed data transmissions -- also known as wide bandwidth radio transmissions. That is, unless all global medium and high frequency radio communications are considered no longer a valid within the North American continent. ak

2) In addition, BPL could bring Internet and high-speed broadband access to rural and underserved areas, which often are difficult to serve due to the high costs associated with upgrading existing infrastructure and interconnecting communication nodes with new technologies.

Existing and possibly additional satellite systems could also satisfy such needs, where they might exist. (Do they exist?) ak

Through this inquiry, we seek information and technical data so that we may evaluate the current state of BPL technology and determine whether changes to Part 15 of the Commission's rules are necessary to facilitate the deployment of this technology. While BPL may be deployed under our existing Part 15 rules, the rules do not specifically provide measurement procedures that apply to systems using the power line as a transmission medium. We therefore seek comment on what changes, if any, we should make to our Part 15 rules to promote and encourage the new BPL technology and to our measurement procedures for all types of carrier current systems. We further encourage present deployment of BPL that complies with our existing rules, noting that if, or when, our rules are modified, those rules will address prospective compliance.

There is no BPL technology that complies with existing Part 15 rules for interference to existing MF and HF radio transmission systems. ak

3) Snip power companies want some of the DSL and cable-modem internet business ak

4)The idea of using the alternating current (AC) power lines to carry information to a variety of devices is not new. A number of devices or systems already use carrier current techniques to couple radio frequency (RF) energy to the AC electrical wiring for purposes of communication. For example, AM radio systems on some school campuses employ carrier current technology; many devices intended for the home, such as intercom systems and remote controls for electrical appliances and lamps also utilize carrier current technology; and for many years, electric utilities have been using carrier current technology to monitor and control the electrical power grid. More recently, these systems have been used to convey information in digital form, providing communications at relatively slow transmission speeds on carrier frequencies below 2 MHz. All such devices are subject to our existing Part 15 rules for low-power, unlicensed equipment operating on a non-interference basis.

And none of the existing RF-on-power-lines systems are broadband. All operate on frequencies specifically allocated to them, or they share specific narrow-band frequencies where the propagation of low level signals can be guaranteed not to interfere with the primary services using those frequency allocations. ak

5)The Part 15 rules limit the amount of conducted RF energy that may be injected into a building's wiring by an RF device that receives power from the commercial power source, including carrier current systems that couple RF energy onto the AC wiring for communication purposes. This conducted energy can cause harmful interference to radio communications via two possible paths. First, the RF energy may be carried through the electrical wiring to other devices also connected to the electrical wiring. Second, at frequencies below 30 MHz, where wavelengths exceed 10 meters, long stretches of electrical wiring can act as an antenna, permitting the RF energy to be radiated over the airwaves. Due to the low propagation loss at these frequencies, such radiated energy can cause interference to other services at considerable distances.

Not "can act as an antenna," but WILL act as an antenna on, below and above the 10 meter wavelengths. ak

6) Discusses power line carrier systems, which are not subject to specific emission limits since they don't interfere with other communication allocations and do not propagate sufficiently to interfere with other such carrier systems.

7) snip non-sequitur info, ak New BPL devices operate on multiple carriers that are spread over a wide spectrum (e.g., from 4.5 MHz to 21 MHz), (Plus harmonics above those frequencies, ak) with adaptive algorithms to counter the noise in the line.

8) snip non-sequitur info, ak


9)The Commission has observed with great interest and anticipation developments in the area of high-speed communications over the power line.

By those special interests hoping to capitalize on marketing it at the expense of existing radio transmission services. ak

High speed transmission capabilities could enable BPL technology to provide an alternative platform for broadband deployment, which would bring valuable new services to consumers, stimulate economic activity, improve national productivity and advance economic opportunity for the American public, consistent with the Commission's objectives. BPL technology could play an important role in enabling Internet and high-speed broadband access to rural areas, because power lines reach virtually every home in the United States. BPL technology could also be used to assist the utilities by adding intelligent networking capabilities to the electric grid, thereby improving efficiency in activities such as energy management, power outage notification and automated meter reading. Furthermore, the electrical wiring in homes and office buildings establishes a physical connection between all electrical devices and power outlets that are located every few feet in most American homes. The high number of access points[1] can be used to provide networking applications within a building, eliminating the need for new or additional wiring to connect networking adaptors, thus allowing consumers to readily take advantage of the technology. In addition, homeland security would be enhanced by creating new facilities to provide redundancy in case of disruption of one or more existing channels of communications.

10)The Commission has a long history of facilitating the introduction of new technologies under Part 15 of its rules.

This is the first time the FCC Commissioners have introduced a new technology to wipe out 4.5 MHz to 21 MHz and higher frequency radio communications!

snip more meaningless techi-sounding discussion of "class A or Class B radiated emission limits."

The FCC desperately needs at least one commissioner who has some slight comprehension of technical issues and isn't corrupted by special interest groups that only care about what will make money for them.


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