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KP4IG  > SAT      09.05.04 06:05l 63 Lines 3023 Bytes #999 (0) @ AMSAT
BID : ANS-130.01
Read: GUEST
Subj: AMSAT Files Comments with FCC on BPL
Path: DB0FHN<DB0FOR<DB0SIF<DB0EA<DB0RES<ON0AR<WB0TAX<KP4IG
Sent: 040509/0502Z @:KP4IG.#JD.PR.USA.NA #:9775 WFBB7.00h $:ANS-130.01
From: KP4IG@KP4IG.#JD.PR.USA.NA
To  : SAT@AMSAT

 
AMSAT News Service Bulletin 130.01 From AMSAT HQ
SILVER SPRING, MD.  May 9, 2004
To All RADIO AMATEURS
BID: $ANS-130.01
 
Dr. Perry I. Klein, W3PK, AMSAT Vice President, Government Liaison, reports
that comments to the FCC's Notice of Proposed Rule Making on Access
Broadband over Power Line Systems (BPL) have been filed expressing AMSAT's
concern on the potential for interference that these systems represent to
the Amateur Satellite community.
 
While a lot of attention has been paid to the impact to HF operations, AMSAT
raises the concern that harmonics and intermodulation products could extend
the potential for interference well into VHF and UHF frequencies.  AMSAT
quoted existing Part 15 rules:
 
   "To determine compliance with the radiated emission limits, if the
     highest frequency generated or used in the device, or on which device
     operates or tunes is 10 MHz, the upper frequency to be examined is
     500 MHz."
 
AMSAT pointed out that 500 MHz is FIFTY TIMES 10 MHz and noted that the
Commission, in this instance, was clearly concerned with harmonics, and
possibly other out-of-band  emissions.  Nevertheless, AMSAT observed that
no such language appears in the new rules proposed for Broadband over Power
Lines in the Docket.
 
AMSAT also addressed a broader issue of the risk posed by the high voltage
involved in BPL systems.  AMSAT believes that a potential risk could be
present by the existence of "couplers" or similar devices installed across
transformers. If a short-circuit should occur in one of these devices,
dangerously high voltages could be conducted to homes and offices, with
potentially fatal results.
 
AMSAT urges the Commission NOT to allow Access BPL systems, even at current
Part 15 radiation limits, and certainly not at higher ones as many of its
proponents urge, until it has had a chance to review all of the National
Telecommunications and Information Administration's (NTIA) analyses,
including that to be contained in its planned Phase II report.
 
AMSAT also urges the Commission NOT to allow any further deployment of
Access BPL systems until these steps have been taken and until the
Commission has had an opportunity to assess ALL the aspects of Access BPL,
including the potential interference threat posed by harmonics and other
out-of-band radiation. This assessment should, of course, include a thorough
review of the NTIA Phase II report. Furthermore, existing Access BPL systems
should be shut down pending the outcome of this assessment.
 
The full text of AMSAT's comments can be found at
http://www.amsat.org/amsat/amsat-na/filings/et-04-37-comments.pdf
 
Perry noted that a lot of hard work and study went into getting these
comments filed with the FCC in a timely manner.  Ray Soifer, W2RS and Bill
Tynan, W5XO were instrumental in helping pull these comments together along
with contributions from other AMSAT Board Members and Officers.
 
[ANS thanks Perry, W3PK for the above information]
 


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