Subject: [NEXTEL-1] NTIA On BPL

From: [email-masked]
Date: Wed, 20 Aug 2003 17:45:48 -0400

Document Date: 07/01/03
Date Received/Adopted: 07/17/03

UNITED STATES DEPARTMENT OF COMMERCE
National Telecommunications and
Information Administration
Washington 0 C. 20230
Chief, Office of Engineering and Technology
Federal Communications Commission
445 1 2 ‘ ~ Street. sw
Washington, D.C. 20554

Subject: Request for Waiver filed by Current Technology Broadband for
over Power Line (BPL), February 6,2003

“Inquiry Regarding Carrier Current Systems, including Broadband over
Power Line Systems,” Federal Communications Commission, ET Docket
No. 03-104, released April 28, 2003

Dear Mr. Thomas:

The National Telecommunications and Information Administration (NTIA),
Oflice of Spectrum Management reviewed the subject request for a permanent waiver
of
the field strength limit specified for Class B emissions in Part 15 of the
Commission’s
Rules. While noting that a number of limiting conditions are proposed, NTIA
believes
that a permanent waiver should not be granted at this time because of the present
lack of
measurements and analyses showing that any resulting interference to allocated
services
would be at acceptable levels. One concern is that the proposed pole-mounted
interface
devices and outdoor power lines used for BPL could be located close to public
safety
mobile and base station receivers operating in the 30-50 MHz fiequencyrange and
consequently many of the intervening signal paths would be unobstructed. The
unobstnicted and ubiquitous nature of this BPL application, and perhaps other
aspects of
BPL, differs considerably from the situations presently found in typical
unintentional
radiators authorized under the Commission’s Part 15 Rules. We also have concerns
regarding compliance measurement techniques for BPL systems and the
characterization
of emissions from a BPL system for use in compatibility studies.

We believe the continued operation of BPL systems on an experimental basis will
provide an excellent oppommity to examine many of the issues raised by the
Commission in the above-referenced Notice of Inquiry (NOI). NTLA has begun
technical
studies to address some of the interference-related issues raised in the NOI,
including
measurements and analyses, which will help deteimine the least constraining BPL
emission Iimits that would preclude unacceptable interference. Our Spectrum
Engineering and Analysis Division is conducting these studies and developing a
measurement plan with the Institute for Telecommunication Sciences (ITS).
Measurements at two BPL demonstration sites are tentatively scheduled to start
late in
July 2003.

We understand that the Commission also may be conducting BPL measurements.
In order to establish the best possible common technical basis for our respective
analyses,
I siiggest that our BPL measurement efforts be coordinated at a11 appropriate
technical
working level. We look forward to working with the Commission's staff in
developing
the appropriate regulatory franiework to permit BPL to evolve while protecting
Federal
and public safety systems.

Sincerely,

Fredrick MQ- R. Wentland
Associate Administrator
Office of Spectnim Management

http://svartifoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6514382058

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