[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
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Chris Imlay