Art, I share your skepticism about the effectiveness of notching at 50 MHz. That's one of the reasons for the need for non-interference-basis reaffirmation. If that were the outcome it would be incumbent on the BPL providers to make notching work, and I don't believe they can. Another point I was trying to make was that even if it COULD be notched we'd be leaving other coalition partners out in the cold. I'm not convinced it's wise for us to do so. Here's a message I received earlier today that provides some food for thought in that regard. Dave -----Original Message----- From: johnf [mailto:johnf@kc.rr.com] Sent: Friday, September 26, 2003 12:15 PM To: K1ZZ@ARRL.net Subject: BPL & Safety of Life Communication Frequencies Dave- Please forgive my likely error but there seems to be missing the FCC hot button: Safety of Life Communications. Over the past 40+ years of working with the FCC looking over my shoulder concerning Type Acceptances, CATV leakage, et al, the one term that perked up all ears was Interference to Safety of Life Communications. BPL promises to virtually wipe out VHF Low Band 30-50 MHz. Within this band are numerous State Patrols, Rural Fire Districts, Sheriff's Departments, and a multitude of others, all involving Safety of Life. H.F. Maritime also comes to mind. As well as H.F. SSB on aircraft in transoceanic flight. Satcom and GPS is great but where is the backup? A few milli-watts into an "antenna system" that is measured in square miles will result in strong signals at altitude. The CATV leakage of the Oberlin, Ohio system will bring the FAA bad memories. Has the FAA been made aware of the likely degradation of their Safety of Life Communication frequencies? How does Kathleen Abernathly propose to hold all the various Safety of Life Communication frequencies harmless from BPL interference? Thanks for all the hard work. John Fuhrman K0LFA PS My father was a fireman. I do not want anything to interfere with their radios. It's personal, Dave. -----Original Message----- From: Goddard, Art (Dir, SW) Sent: Friday, September 26, 2003 12:45 PM To: arrl-odv Subject: [ARRL-ODV:9515] Re: FCC's Commissioner Abernathy Praises BPL Dave, I wish I could share your apparent confidence that notching the 6M band will work. Do you have any technical data/rationale to share? 73, Art ----- Original Message ----- From: Sumner, Dave, <mailto:dsumner@arrl.org> K1ZZ To: arrl-odv <mailto:arrl-odv@reflector.arrl.org> Sent: Friday, September 26, 2003 7:14 AM Subject: [ARRL-ODV:9510] Re: FCC's Commissioner Abernathy Praises BPL I don't follow your Wright Brothers analogy, Chris. Be that as it may, let me just repeat for ODV what I have previously said to you about what would constitute a satisfactory outcome: I think a satisfactory outcome for us on the BPL NOI would be a finding by the FCC that BPL is not viable below 30 MHz and cannot be permitted there because of the high potential for interference, and that if it is to be permitted above 30 MHz the 50-54 MHz band has to be notched. This would have to be coupled with a reaffirmation that BPL operation is strictly on a non-interference basis, and that any instances of harmful interference to licensed radio services have to be immediately resolved by the BPL operator. However, this outcome would not satisfy the concerns of some of our coalition partners and potential partners -- the NAB and APCO, for instance. It also seems unlikely to me that it would satisfy the BPL interests, although of course I wouldn't shed any tears over that. If we're serious about a coalition I don't see how we can leave the interests of the coalition partners out of the equation. Also, until more work is done on the potential for out-of-band interference -- particularly harmonics, which could affect two meters among other bands -- we should stay aligned with NTIA's concerns on that score. At least some members who work there think there is a potential for creating a "negative buzz" about BPL on Wall Street such that potential investors would shy away from it. I see no reason to discourage that line of thinking. The utilities can do more with fiber-to-the-home than they can with BPL. Why not encourage them to foresake BPL and go directly to fiber? Do we have the horsepower to make either of these things happen? No. But we can plant some seeds. 73, Dave K1ZZ -----Original Message----- From: Imlay, Chris (ARRL Counsel) Sent: Thursday, September 25, 2003 5:31 PM To: arrl-odv Subject: [ARRL-ODV:9502] Re: FCC's Commissioner Abernathy Praises BPL In a message dated 9/25/2003 4:07:16 PM Eastern Standard Time, dsumner@arrl.org writes: But my favorite example is March 1988 QST: "TV Answer: What Was the Question?" A quote from that editorial: "Once in a while an idea comes along that is so preposterous, and the actions of its proponents so outrageous, that no amount of human charity can put a reasonable face on it -- or on the actions of those who would even take it seriously." Well, to continue the debate, Dave, telecom and utility people most certainly DO take BPL seriously, to the extent that a lot of money is going into advocating it. It is really easy to see that the FCC is going to want to push the concept to the extent of at least allowing the industry to try to make a competitive service play. I don't think it will; you don't and we on this reflector don't. But where is our ability to cause those advocating it to cease and desist? I don't think it exists. All this leads me to suggest that, if we can allow FCC to limit BPL to the bands 30-88 MHz, and to "notch" (an inappropriate term, apparently) 6 meters, we should be in a position to allow ourselves to declare victory. As Ed Thomas put it, the success or failiure of BPL is not the FCC's job; they think they have to facilitate the initiation of a competitive service. If they can do so in a way that is responsive to our very legitimate and urgent concerns, I think we ought to step back and let them fail at the attempt. It is like the Federal Government prohibiting both the Wright Brothers and Otto Lilienthal from aviation experimentation. Sure, they could have saved Otto's life in the process, but they would have prohibited the Wright Brothers too. That seems to be their thinking. Chris