BPL Reply Comment Period Open

Discussion in 'Ham Radio Discussions' started by WA3KYY, May 6, 2004.

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  1. WA3KYY

    WA3KYY Ham Member QRZ Page

    Now that the comment period on the BPL NPRM has closed, the Reply Comment period has begun. Remember, this is a fast track proposal so the Reply Comment period is short. We need to read the various comments by the BPL proponents and find the holes in their arguments and show them for what they are. Use facts from the NTIA report and other commentary filings to support your argument against the statements made by the proponents in their fillings.

    The time is now past for direct comment on aspects of the NPRM or the NOI. Limit your reply commentary to addressing what other commenters filed. Some suggestions are to state why a public database is required for BPL compared to other broadband suppliers, use the documented interfernce comments and the general lack of knowledge about who and what was causing the interference. Address wishy-washy mitigation techniques proposed by the BPL providers. Attack the concept of "accomodation" or letting anyone other than the injured protected service or the FCC determine what constitutes "harmful interfernce". Reply in support of specific means of determining harmful interference. (There was a very good comment filed addressing this).

    Many, many comments on the NPRM appear to have been denied. At least, a date appears in the Date Release/Denied field. A cursory look at those comapred to others throughout the 1167 comments filed seems to indicate those with a date in that field were not responding to the specifics of the NPRM but were emotional appeals to ban BPL. So, if you are going to file a Reply Comment, address specific points of filed comments. That is what the FCC is seeking at this point in time.

    Mike
     
  2. KA5S

    KA5S Ham Member QRZ Page

    It is not clear what the entry "Date Released/Denied" means with regard to a Comment. The on-line ECFS manual says, "This is the date a Commission originated document was released or the date a petition for rulemaking was denied. ..." In any event, I note that not one of the BPL proponents' Comments has a date in this space!

    Cortland
     
  3. WA3KYY

    WA3KYY Ham Member QRZ Page

    Well I did a somewhat cursory review of those with and without dates in this field, including my own comment filed a while back. (Very brief, addressing the gross lack of understanding of Part 15 by the general public, no date). It appears to me at least that those without a date were more reponsive to the specifics of the NPRM than those with a date. There are numerous comments very critical of various provisions of the NPRM that also do not have dates so it is not just the industry comments.
     
  4. WA3KYY

    WA3KYY Ham Member QRZ Page

    I just read the filing by Consolidated Edison

    Consolidated Edison BPL Filing

    They are requesting a relaxation or exemption of the shutdown rule for interfering Access BPL devices if they are being used for vital electric utility services.

    We need to strongly object to this comment and suggest the FCC ban the use of Access BPL for the provision of vital electric utiltity services as being dangerous and incomaptible with the rules governing a Part 15 device. Critical services need their own protection and it would not be in the public interest to have these services provisioned with Part 15 devices that themselves can be interfered with by numerous licensed serivices, not just amateur radio, and must be shut down if interference from them cannot be eliminated.

    Mike
     
  5. N0PU

    N0PU Guest

    </span><table border="0" align="center" width="95%" cellpadding="3" cellspacing="1"><tr><td>Quote (WA3KYY @ May 06 2004,08:09)</td></tr><tr><td id="QUOTE">I just read the filing by Consolidated Edison

    Consolidated Edison BPL Filing

    They are requesting a relaxation or exemption of the shutdown rule for interfering Access BPL devices if they are being used for vital electric utility services.

    We need to strongly object to this comment and suggest the FCC ban the use of Access BPL for the provision of vital electric utiltity services as being dangerous and incomaptible with the rules governing a Part 15 device.  Critical services need their own protection and it would not be in the public interest to have these services provisioned with Part 15 devices that themselves can be interfered with by numerous licensed serivices, not just amateur radio, and must be shut down if interference from them cannot be eliminated.

    Mike[/QUOTE]<span id='postcolor'>
    Whoa...slow down a bit...

    Con Ed among others have been using this technology to control parts of their electrical distribution systems for well over 50 years... At the present time I believe it is mostly used on a secondary basis, however it IS part of the command and control system for their major distribution points...

    Their use of this technology has caused interference for as long as they have used it...BUT, you didn't notice it because it was fast and infrequent... maybe you did notice it.. &quot;What was that I just heard?&quot; ... and then it was gone... not harmful interference!...

    It is the continuous use of BPL by many users all at the same time that is the problem... THAT is where the harmful interference is coming from...

    I keep saying this over and over... BPL is NOT new technology... it is the type of implementation that is new... BPL is already legal... The fight is over the levels of interference that will be allowed...

    ---- other thoughts-------

    If you write to the FCC about this technology PLEASE be sure you are well read and informed on what you are writing about... Uneducated, poorly written and technically inferior presentations will not help the cause... They only make the over all Ham community look like fools... Name calling and threats are NOT going to help... This is NOT a numbers game... it is a technology and engineering game aided by some lawyers that KNOW how to word things...

    PLEASE be careful what you say and how you say it... ONE false statement or instance of name calling will void all the work you put into your comment... This is NOT the place for emotional appeals... If one does not believe they are technically competent to make sensible, technically correct statements, I recommend staying out of this... Let the people who KNOW what they are talking about fight the battle...
     
  6. WA3KYY

    WA3KYY Ham Member QRZ Page

    I am well aware of the use of PLC currently in use to control power systems both in the VLF range and others. PEPCO (my electric provider) uses some form of PLC to turn my A/C off for 15 min and hour during peak use times. However, you will recall that the FCC denied a request for a low power amateur allocation in the 137KHz region because of power company concerns over interference TO their PLC signals and systems.

    My concern is that ConEd and others will want to use Access BPL as part of critical control systems as opposed to non-critical load shedding, and consumer end monitoring. Once established, they will want protection FROM interference as well as a no shutdown clause. They are not asking for that now, but we need to head that off. I have no objection to shutdown as a last resort but would comment object to the BPL provider being able to say what is good enough to avoid shutdown. Thus, I believe that critical control and montoring functions should not be allowed via a high duty cycle Part 15 device. Intermittent, periodic bursts of short duration would probably not be a problem unless there is an aggregate effect from hundreds of such devices on a given leg of the system. That is, each device gets its own tiny slice but the end result is a continuous or near continuous signal due to the numbers of devices operating in quick succession.

    Mike
     
  7. N0PU

    N0PU Guest

    </span><table border="0" align="center" width="95%" cellpadding="3" cellspacing="1"><tr><td>Quote (WA3KYY @ May 06 2004,09:14)</td></tr><tr><td id="QUOTE">I am well aware of the use of PLC currently in use to control power systems both in the VLF range and others. PEPCO (my electric provider) uses some form of PLC to turn my A/C off for 15 min and hour during peak use times.  However, you will recall that the FCC denied a request for a low power amateur allocation in the 137KHz region because of power company concerns over interference TO their PLC signals and systems.

    My concern is that ConEd and others will want to use Access BPL as part of critical control systems as opposed to non-critical load shedding, and consumer end monitoring.  Once established, they will want protection FROM interference as well as a no shutdown clause.  They are not asking for that now, but we need to head that off.  I have no objection to shutdown as a last resort but would comment object to the BPL provider being able to say what is good enough to avoid shutdown.  Thus, I believe that critical control and montoring functions should not be allowed via a high duty cycle Part 15 device.  Intermittent, periodic bursts of short duration would probably not be a problem unless there is an aggregate effect from hundreds of such devices on a given leg of the system.  That is, each device gets its own tiny slice but the end result is a continuous or near continuous signal due to the numbers of devices operating in quick succession.

    Mike[/QUOTE]<span id='postcolor'>
    Good thought... I didn't see that one coming... I got blind sided...

    Problem is there is nothing to prevent them from moving control functions into Access BPL frequency ranges and then claiming immunity... and do it legally if granted the no-shut-down rule...

    Sneaky buggers... Good catch...
     
  8. N4KIT

    N4KIT Ham Member QRZ Page

    Thanks for pointing out the release date. I never realized this would indicte if your comments would be considered.

    Mine were dismissed. It dealt with FCC's non-interference obligations under the ITU Radio Regulations. Not suprising that the point would be ignored by an admisitration that has repeatedly thumbed it's nose at international treaty obligations.

    73, Hope we can make this bearable,
    Chris, N4KIT
     
  9. Guest

    Guest Guest

    Do not forget to write your anti-BPL letters,
    encourage new amateur radio participation and generally be nice
    to one another. That is all.
     
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