Nick Roscoe N3NR (ARRL member from Glen Mills, PA) sent the following message to the PR dweeb for the UPLC. He posted it on the reflector of a contest club I belong to. It's a good read. 73 - Kay N3KN -----Original Message----- Sent: Friday, June 25, 2004 11:01 PM To: mary.patterson@utc.org Subject: [FRC] Re: UPLC Sets the Record Straight on BPL Interference Dear Ms. Patterson, As a practicing RF design engineer with experience in the design of terrestrial military radio and RADAR systems, military space communication and navigation systems, and NASA space communication systems, as well as a licensed amateur radio operator, I would like to take exception to several statements in your organization's press release dated June 22, 2004 titled "UPLC Sets the Record Straight on BPL Interference". In paragraph three of the above referenced press release your organization made the following statement: "UPLC also commented on amateur radio opposition to the technology, urging the Commission to ignore "armchair amateurs that still use vacuum tube transmitters" and listen to the reputable companies and entrepreneurs who are the real experts on BPL and who have overcome enormous technical obstacles to make BPL a reality in the U.S." I would like to bring to your attention the fact that many currently fielded military radio and RADAR systems, as well as several military satellite systems, still employ various vacuum tube technologies. These include systems in the HF frequency range as well as the EHF and SHF frequency ranges. In fact, vacuum tube technology is still the most cost effective means to develop the required high radio frequency power levels that allows these systems to operate. Companies who have fielded vacuum technology in recent years include such names as Northrop Grumman, Lockheed Martin, L3 Communications, The Boeing Company, Rockwell Collins, Harris Corporation, ITT Industries, and Raytheon. While your organization may be of the opinion that there is little competent technical expertise in the amateur radio community I would suggest that the same statement cannot be made for the numerous highly competent engineers that have and currently are working for the aforementioned reputable companies. Your organization is mistaken if it is trying to equate vacuum tube technology with out-of-date technology. It is also a great mistake to underestimate the technical capability of the amateur radio community. Also in paragraph three of the above referenced press release your organization states "All the field trials over the years in various parts of the country have shown that the risk of interference from BPL is extraordinarily low, because it produces only minimal radio frequency energy at a few points in the system. Moreover, these systems will incorporate adaptive interference mitigation capabilities that will effectively remedy any interference that might result to fixed and mobile operations in the High Frequency (HF) band (1.7-80 MHz)." This is clearly an erroneous statement. I would refer you, as an example, to the current state of BPL system trials in the Cedar Rapids, Iowa area where amateur radio operators have documented high levels of interference from a system fielded by Alliant Energy. For over a month now Alliant Energy, in conjunction with the BPL equipment provider Amperion, has been trying to employ adaptive interference mitigation techniques without success. For further information I would refer you to the following web link: http://www.arrl.org/news/stories/2004/06/15/2/?nc=1 Additionally, while your organization claims that BPL systems only produce minimal radio frequency energy at a few points in the BPL system, I would note that it only takes a few RF sources to turn the whole system into a RF radiator. This phenomena has been noted in the NTIA's April 2004 Phase 1 Report on Potential Interference From BPL Systems to Federal Government Radiocommunications. Finally I would like to note that the amateur radio community in certainly not opposed to BPL technology per se. Our community is opposed to poorly designed systems that operate in the congested HF radio spectrum. BPL systems that operate in the middle microwave bands (such as S Band or C Band) that employ techniques that excite surface waves along power line media are a viable alternative to HF systems with regard to both technological considerations and economic considerations. Sincerely, Nicholas P. Roscoe, Jr. (amateur radio licensee N3NR) Senior RF Design Engineer Northrop Grumman Electronic Systems High Power RF/Power Generation Systems -- Incoming mail is certified Virus Free. Checked by AVG Anti-Virus (http://www.grisoft.com). Version: 7.0.253 / Virus Database: 263.3.6 - Release Date: 6/25/2004