2. “It’s the technology stupid.” (the FCC NOI and BPL) A presentation to NRECA/NRTC Cincinnati, Ohio July 29, 2003

3. Slide 2 Outline Part 15 Regulations and BPL –Unlicensed operation: non-interference directive –EMC limits FCC Notice of Inquiry –Performance issues –Interference issues –Measurement issues What can co-ops do? Conclusions

4. Slide 3 FCC Part 15: Overview FCC Part 15 pertains to unlicensed operations –The non-interference directive (not Star Trek). Accept interference from other licensed users Not cause interference to other licensed users –Limits on radiated/conducted emissions serve as primary means of preventing interference. Varies according to frequency, intentional v. unintentional radiators, Class A v. Class B digital devices. –Equipment must be authorized. Common examples: garage door openers, Wi-Fi

5. Slide 4 Part 15 Regulations and BPL BPL treated as carrier current systems (CCS), defined as –A system, or part of a system, that transmits radio frequency energy by conduction over the electric power lines. A carrier current system can be designed such that the signals are received by conduction directly from connection to the power lines (unintentional radiator) or the signals are received over the air due to radiation of the radio frequency signals from the electric power lines (intentional radiator). Common examples: AM campus radio stations

6. Slide 5 Part 15 Regulations and BPL BPL must comply with radiated emission limits for CCS ( 30 MHz)(§15.109(e)) RegulationDistance  V/mdB  V/m 3 3000 69.5 10 270 48.5 30 29.5 3 300 49.5 10 90 39 30 29.5 3 100 40 10 30 29.5 30 10 20 Carrier Current Devices 1-30 MHz FCC Class A Digital Devices 30-88 MHz FCC Class B Digital Devices 30-88 MHz

7. Slide 6 Part 15 Regulations and BPL BPL must also comply with conducted emission limits that apply to carrier current systems (§15.107): –CCS that operate between 535-1705 kHz: no emission limits –All others: 1000 uV between 535-1705 kHz FCC Report & Order defers changing limits until future proceeding. –Influenced by IEC CISPR I standards in development, and UTC and PLCA comments opposing proposals to tighten conducted limits for BPL.

8. Slide 7 FCC Notice of Inquiry Format of proceeding –NOI is preliminary proceeding: No rules proposed Stated objective –Promote BPL while protecting against interference Prospective application –Utilities may deploy BPL under current Part 15 rules Focused on technical rules –Deliberately avoids thorny policy issues

9. Slide 8 FCC Notice of Inquiry General Issue: Are rules for CCS appropriate for BPL? Specific Issues –Performance –Interference –Measurement methods –Equipment authorization –Other issues Bottom line: BPL question is both technical and political.

10. Slide 9 FCC Notice of Inquiry Comments filed July 7 –Utilities/Vendors: support BPL Explain BPL operations, suggest ways to improve rules –Licensed users: oppose BPL Raise interference concerns –Broadband competitors: further study/proceedings Compatibility issues, pole attachments Reply comments due August 6

11. Slide 10 What Can Coop’s Do? FILE COMMENTS IN SUPPORT OF BPL! BPL advances rural access for broadband –Cable/DSL duopoly –Investment drying up Coop’s are uniquely situated to serve rural customers –Many are already providing Internet to communities bypassed or beheld by incumbents BPL could create opportunities for co-ops –extends reach/makes effective use of fiber optic facilities –Improves electric service

12. Slide 11 Conclusions FCC wants to promote BPL through the NOI Input from co-ops important –NOI is as much policy as it is technical –Rural broadband deployment is the FCC’s #1 priority –FCC needs to know if utilities will compete with cable and DSL –FCC needs to know if BPL can/would remedy the “digital divide” –Anecdotal information is welcome! For more information, contact UTC or the UPLC!

13. Slide 12 Thank You! Brett Kilbourne United PowerLine Council 1901 Pennsylvania Avenue, NW Fifth Floor Washington, DC 20006 (202)833-6807 www.uplc.orgwww.uplc.org / www.utc.orgwww.utc.org