I just want to add that Chris has every right to be proud of this. He and Ed crafted a magnum opus. What the FCC will do with it remains to be seen, but it gives them the perfect opportunity (if they wish to seize it) to show that the new Chairman’s claim that future FCC decisions will be fact-based and scientific is more than just hot air.

Dave K1ZZ

From: Chris Imlay [mailto:w3kd@aol.com]
Sent: Wednesday, September 23, 2009 2:14 PM
To: arrl-odv
Cc: Hare, Ed W1RFI
Subject: [arrl-odv:18116] BPL Further Notice of Proposed Rule Making, Docket 04-37; Comments filed

Greetings. Today, the due date, we filed the attached comments in response to the FCC's "Request for Further Comment and Further Notice of Proposed Rule Making" in the BPL docket following Executive Committee review and approval with editorial privilege.

Frankly, I am quite proud of these comments, not due to any great writing on my part (two members of the Executive Committee could not get through an earlier draft of this without, as they each separately and independently put it, "their eyes glazing over") but because Ed Hare did a magnificent job in supporting our arguments, most especially with respect to the 40, 30 or 20 dB/decade extrapolation factor. I think these comments are bold and frank, and they are most importantly technically accurate. Ed and I worked closely together on these, and as I told the EC, ARRL is very lucky to have such an expert on the subject on our staff.

I am sending each of the four exhibits that were filed with these comments separately. It is likely that Exhibit A may not make it through ARRL's server. If not, I will get you a URL so that you can read them. They are several of Dave Sumner's slides of the redacted and unredacted FCC laboratory findings; I think you have seen them all before. Exhibit A is a subset of those.

Thanks for helpful edits to these from President Harrison, First Vice President Craigie,EC member Tom Frenaye; Dave Sumner; and Brennan Price. 

Now, let's see what the rest of the comments look like. The reply comments are due very soon. By the way, lest you think that BPL is dead as a broadband delivery mechanism, think again. Ed and I just had a "coming to Jesus" meeting with the FCC and a BPL company in San  Diego that received an experimental STA to operate BPL tests in San Diego at 3-30 MHz using "1 Watt ERP" of radiated power !!! That was fixed, and the company uses notching and will not exceed the FCC Part 15 radiated emission limits during the tests, but the company, using adaptive technology, is planning some new BPL hardware rollout. So, it isn't dead yet. Not by quite a ways.

73, Chris W3KD  

Christopher D. Imlay
Booth, Freret, Imlay & Tepper. P.C.
14356 Cape May Road
Silver Spring, Maryland 20904-6011
(301) 384-5525 telephone
(301) 384-6384 facsimile
W3KD@ARRL.ORG