Dave, Excellent letter! - Bill N3LLR -----Original Message----- From: "Sumner, Dave, K1ZZ" <dsumner@arrl.org> Subj: [arrl-odv:14889] Letter to FCC Chairman Martin Date: Wed Dec 6, 2006 10:48 am Size: 5K To: "arrl-odv" <arrl-odv@reflector.arrl.org> Letter to FCC Chairman Martin Last week in a presentation at Georgetown University, FCC Chairman Martin used a "BPL Deployment" map taken right off the United Power Line Council's Web site. It's the same map, incidentally, that was on display at the FCC's open meeting last August at which the BPL Memorandum Opinion and Order dispensing with the reconsideration petitions was adopted. This made me see red. After clearing it with Chris and Joel, this morning I sent the following letter to Chairman Martin. We will give it suitable publicity as well. Dave December 6, 2006 Kevin J. Martin, Chairman Federal Communications Commission 445 Twelfth Street, SW Washington, DC 20554 Via FAX - Page 1 of 3 pages Dear Chairman Martin: In your November 30 presentation to the Georgetown University McDonough School of Businesss Center for Business and Public Policy, you included a slide purporting to show Broadband Over Power Line Deployments. This slide is taken from a biased industry source and fails to note that a large percentage of the deployments shown on the map have been shut down and no longer exist. Here are but a few examples: PPL announced in October 2005, more than a year ago, that it was terminating its trial deployment because it had been found to be uneconomic. United Illuminating announced two trial deployments, but only ever installed one and shut that one down in December 2005 after a few months of operation. SMECO announced in March 2006 that it had ended its trial in December 2005 and noted that BPL signal speeds and bandwidth are not competitive with other technologies currently available. The Idaho Power deployment was by IDACOMM, which announced in January 2006 that it was abandoning the BPL business (and has done so). RPU has no BPL deployed. I confirmed this by telephone yesterday. They had an unsuccessful Main.net trial deployment in 2004. This list is by no means comprehensive. The fact is that BPL systems are being shut down faster than they are being deployed. The ARRL respectfully requests that the FCC cease using the United Power Line Council as a source for illustrating BPL deployments. We also request that in the spirit of a level playing-field that you say is a guiding regulatory principle, you consider a more evenhanded approach to the promotion of so-called nascent broadband technologies. For example, your prepared remarks cited wireless broadband, broadband over powerline, and Fiber-to-the-Home all as new technologies that are beginning to be deployed, yet neither wireless broadband nor Fiber-to-the-Home merited a PowerPoint slide - despite the fact that the FCC Report, High-Speed Services for Internet Access: Status as of December 31, 2005 showed 448,196 Fiber lines and 256,538 Fixed Wireless lines compared to just 5,859 for Power Line and Other. Your prepared remarks do not even mention satellite broadband, yet the same report shows 426,928 satellite lines. As you know, the ARRLs concern is with the still-unresolved radio interference issues that uniquely plague BPL and not with BPL as such. However, it is evident that the technology does not deserve the favored treatment the FCC continues to bestow upon it, especially when its inherent shortcoming, that it is a radio spectrum polluter, escapes mention. Sincerely, David Sumner Chief Executive Officer Attachment: Broadband Over Powerline Deployments slide cc: Commissioners