SMSE-005-05 – Consultation Paper on Broadband Over Power Line Communications System Created in Microsoft WORD 2000 XP Home Edition

Attached are my comments to:

Notice No. SMSE-005-05 – Consultation Paper on Broadband over Power Line Communications System Created in Microsoft WORD 2000 XP home edition

I am a licensed amateur radio operator – VE7BWC, and am very concerned about the proposal to allow the BPL system, as anyone near power lines will experience harmful interference to incoming signals. There will be interference over a huge area and it will not only affect Amateurs.

An example: ships at sea use HF (High Frequency) for any distance communications, as VHF is only useful for vessels in close proximity to one another. Long distance distress signals intended to be received at a shore-based station will be totally unreadable for any station near a power line. This will be true for any number of civil and commercial services.

The amateur radio service has proven itself to be extremely useful in recent emergencies, being almost the only working communication after the disasters have struck. Almost all receiving stations worldwide are near power lines.

In most disaster scenarios the amateur operators are using battery power so the signals coming out are not strong but with good conditions can be read over thousands of miles away. These signals would be unreadable unless and until there is major refinement of the proposed system.

With today’s state-of-the-art technology in many disciplines it seems preposterous that such a system as BPL should be allowed. As it stands now it should be scrapped or put on hold, as it will be a massive assault on a huge area of the radio spectrum. If in the future a way is found to refine the system it might be considered again at that time.

Robert Allison, 1179 Cloverley St, North Vancouver, BC, V7L 1N7 [email protected] NSARC NEWSLETTER – 20 NOVEMBER 2005 – NUMBER 548 THE NSARC CALENDAR 22 November: 2 metre net: 1900 hours, 147.26 MHz, Net Control: Erik VE7ZQ 23 November: RAC Forum on the air, 1900 hours on 147.18 MHz. (details below) 24 November: HF Group meeting (see details below) 29 November: 2 metre net: 1900 hours, 147.26 MHz. Net Control: Bob VE7RPX 1 December: General meeting. There has been a program change. See details below. 6 December: 2 metre net: 1900 hours, 147.26 MHz. Net Control: Bill VA7BIL 8 December: Christmas Dinner. See details below. THIS WEEK'S HIGHLIGHTS:

1. The Dec. 1 Program: Dirk VE7DRK's presentation on "The Gerry Brewer Building" has been put off till February. The amateur radio hobby, as well as this Club, attracts people from all walks of life. Occasionally the Club persuades those members with unique or different vocations to share some information about their work. On December 1, Leif VA7CAE will talk about his vocation. To use a ham-originated expression, "come and have an eyeball with Leif" and find out what he does for a living.

2. The Christmas Dinner will be held on December eighth at the North Shore Winter Club. Tickets for members and their guests are $30 each, available for the last time at the December first meeting, or you can contact Alan Jones VA7ALJ for tickets.

3. The HF Group meets this Thursday. Nick VA7NRM will unravel the mysteries of Smith Charts as well as discuss tuners.

4. The RAC Forum On The Air, Wednesday Nov. 23: Radio Amateurs of Canada Director Ed Frazer VE7EF will conduct RAC Forum On The Air, hosted by the Oceanside Radio Communications Association (ORCA) of Parksville/Qualicum on Repeater VE7RBB 147.180 (+) The VE7RBB repeater covers the Vancouver area. Lower Mainland hams are invited to check in and participate. Check-in at 1900 hours for the ORCA Net. The RAC Forum follows at 1930 hours and runs until 2000 hours. Topics will include,

- RAC and amateur radio update.

- Report on meeting with the Canadian Amateur Radio Advisory Board (CARAB) in Ottawa on Nov. 3. (CARAB meets twice annually with RAC and Industry Canada).

- No-code HF operation, and the new rules.

- - Update on Broadband Over Power Line and response to IC Gazette Notice SMSE-005-05 (Responses to IC are due Nov. 28).

5. November 28 is the deadline for Industry Canada to receive your views on the implementation of Broadband over Power lines. Please do your share to advise Industry Canada that you are concerned about interference to HF signals. Sample Response to Gazette SMSE-005-05, Broadband over Power Line To download a sample response: - Go to the Radio Amateurs of Canada Home Page at www.rac.ca . - Right Click on "Sample Response to Gazette SMSE-005-05, Broadband over Power Line" - Select "Save Target as..." - Select a Directory on your computer in which to download the MS- Word file "2005_11_BPLResponse". Read the suggestions in the first page, and then delete it from the document being sent to Industry Canada, as well as removing all of the RED comments. To view or download the Industry Canada Gazette Notice SMSE-005- 05, go to: http://strategis.ic.gc.ca/epic/internet/insmt- gst.nsf/en/sf08432e.html Then click on the title: "Consultation Paper on Broadband over Power Line (BPL) Communication Systems" to download the Paper. 6. Today's link: Your are hearing a lot about RAC and Amateur Radio Clubs working on preserving our radio spectrum. This sounds like a lot of work and the need for a lot of resources. But if you really want to see what our American friends are doing about this very same subject, take a look at http://www.arrl.org/news/stories/2005/11/15/2/?nc=1 North Shore Amateur Radio Club http://www.nsarc.ca Feedback? [email protected]

147 East 14th Street North Vancouver, BC V7L 2N4

Frank Andersen 8805 East Saanich Road Sidney BC Canada V8L 1H3 250-655-1301

November 10, 2005

Director General, Spectrum Engineering Branch Industry Canada, 300 Slater Street, Ottawa, ON K1A 0C8

Subject: Response to Canada Gazette Notice SMSE-005-05 dated July 19, 2005 Consultation Paper on Broadband over Power Line (BPL) Communications Systems

Dear Sir:

GENERAL

I have been a licensed amateur radio operator for 20 years. I am involved in radio communications for personal enjoyment, as well as for the benefit of our community, and in particular to provide communications during local, national and international emergencies where other communications means have failed.

RESPONSE

The following sections follow the numbering in Canada Gazette notice SMSE-005-05:

2 3. General Description of BPL Systems

No Comment

6.0 Discussion and Proposals

The Department also seeks comment on any other specific issue or concern relating to the Department’s role in the deployment and regulation of BPL systems in general.

The amateur radio service is a significant resource to the local, national and international community, particularly in times of emergency. During major disasters such as the Katrina storm, the Asian Tsunami, and Okanagan fires, amateur radio via MF, HF and VHF networks was often the only communication available during and days after each disaster. BPL systems, in their present form, have the capability of interfering with or totally preventing radio operations. The Department has a substantial obligation to preserve the ability of radio systems to continue operation.

6.1 Equipment Standard and Approval Process

We agree that a technical standard is required for the equipment and the operating system. However, because the power-line is not designed for efficient transfer of Broad-Band signals, it is essential that the installed system be made compliant with a system standard that does not create harmful interference to other licensed or authorized users of the spectrum.

6.2 Prospective Technical Requirements

6.2 (a) Emission Limits

Access BPL systems operating below 30 MHz will be subject to following limits:

Frequency (MHz) Field strength Measurement (microvolts/metre) Distance (metres) 1.705-30.0 30 30

Access BPL systems operating above 30 MHz will be subject to the following limits:

Frequency (MHz) Field strength Measurement (microvolts/metre) Distance (metres) 30-80 90 10

The Department seeks comment on the above limits and their suitability for Access BPL systems in Canada. Please provide technical rationale.

Most Amateur Radio stations are located within 30 m of a LV or MV power line. A dipole 3 antenna located near a BPL power line (often less than 30 m) will intercept an interfering BPL signal that is substantially greater than the typical weak-signal from a distant station. An emission level of 30 uv/m would block all reception except for the very strong signals, which are not typical.

6.2 (b) Interference Mitigation Requirements for Access BPL Systems

In addition to establishing appropriate emission limits, the Department is proposing that Access BPL equipment/systems incorporate adaptive interference mitigation techniques to minimize the potential for interference to radiocommunication users. These include:

• remote controllable shut-down features; • remote power reduction; and, • notch filtering and/or frequency avoidance.

The Department seeks comment on whether: (1) Access BPL equipment should incorporate adaptive interference mitigation techniques as described above; and,

(2) additional or alternative interference mitigation techniques, if any, should be used to minimize the potential

for interference to authorized services.

Please provide rationale

All three techniques should be employed, particularly the avoidance of the amateur radio bands, for the reasons given in section 6.2 (a) above.

The Department seeks comment on any additional technical requirements for access BPL system. Please provide supporting technical rationale.

No comment

6.3 Operational Requirements

6.3 (a) Prohibited Frequency Bands

In times of national or local emergencies and national disaster, amateur radio is a community resource, and should be protected. There are parts of the MF/HF/low VHF spectrum, such as 30 to 50 MHz, where BPL would least affect users. It is recommended that the Department judiciously choose frequency bands to be excluded, and promote BPL in those segments least likely to be affected.

4 6.3 (b) Geographical Frequency Restrictions and Coordination Requirements

6.3 (c) Interference Resolution

The Department seeks comments on: (1) its proposal that individuals and organizations refer problems to BPL operators to investigate and resolve matters on a timely basis; and (2) what other approaches could be taken to ensure the resolution of interference complaints? Please provide rationale.

(1) If the BPL operator is to be the first point of contact, the Department’s regulations and protocols should include time-frames for both the response to a notification of interference and for the action to resolve the interference. (2) If the BPL operator does not resolve an interference problem in a timely manner, the Department should then intervene, and require the operator to comply.

Conclusion Radio amateurs are not against BPL per se and recognize that BPL may benefit some Canadians. However, given the interference problems that have been experienced by radio amateurs in various countries to-date from BPL system radiation, radio amateurs strongly believe that it is incumbent upon the Department to regulate BPL equipment and systems to minimize interference to all HF radio services from these unconventional, non-radio data and telecommunications systems.

Submitted by: Frank Andersen VE7GCO/VA7FA

Joseph Alfred Louis Beaubien VE7CGE, 4813 fairlawn Drive, Burnaby, B.C. V5C3R7

Telephone (604) 291-1569 e-mail [email protected]

November 19, 2005

Director General, Spectrum Engineering Branch Industry Canada, 300 Slater Street, Ottawa, ON K1A 0C8

Subject: Response to Canada Gazette Notice SMSE-005-05 dated July 19, 2005 Consultation Paper on Broadband over Power Line (BPL) Communications Systems

Dear Sir:

GENERAL I wish to comment on the document referred to above. Industry Canada's decisions on the matter of BPL can have a severe impact on the ability of licensed and authorized radio users to receive and communicate on MF, HF and VHF spectrum, and in particular, on the future of the Amateur Radio Service.

I have been a licensed amateur radio operator for 40 years in the community of British Columbia. I am involved in radio communications for personal enjoyment, as well as for the benefit of our community, and in particular to provide communications during local, national and international emergencies where other communications means have failed. I have served on the local ESS committee for several years and I have been involved in installing repeaters and other vital Amateur Radio Communications, Currently, I am supporting in Win Link which allows for high speed emergency message handling. This is a very high priority right now in our community. We are on the leading edge in Canada.

RESPONSE

The following sections follow the numbering in Canada Gazette notice SMSE-005-05:

2 3. General Description of BPL Systems

: No Comment

6.0 Discussion and Proposals

The Department also seeks comment on any other specific issue or concern relating to the Department’s role in the deployment and regulation of BPL systems in general.

: The amateur radio service is a significant resource to the local, national and international community, particularly in times of emergency. During major disasters such as the Katrina storm, the Asian Tsunami, and Okanagan fires, amateur radio via MF, HF and VHF networks was often the only communication available during and days after each disaster. BPL systems, in their present form, have the capability of interfering with or totally preventing radio operations. The Department has a substantial obligation to preserve the ability of radio systems to continue operation. Because this service operates over power lines, it comes in close contact with my Amateur Radio Station. This concerns me as I understand that radio frequencies cause less interference if they can be channeled further away to antennas located on proper antenna support structures. I have spent quite a lot of money to achieve this.

6.1 Equipment Standard and Approval Process

6.2 Prospective Technical Requirements

6.2 (a) Emission Limits

Access BPL systems operating below 30 MHz will be subject to following limits:

Frequency (MHz) Field strength Measurement (microvolts/metre) Distance (metres) 1.705-30.0 30 30

Access BPL systems operating above 30 MHz will be subject to the following limits:

Frequency (MHz) Field strength Measurement (microvolts/metre) Distance (metres) 30-80 90 10

The Department seeks comment on the above limits and their suitability for Access BPL systems in Canada. Please provide technical rationale.

: The proposed emission limits for BPL systems will create harmful interference to typical MF/HF/VHF signals that are being received by radio operators adjacent to BPL-carrying power lines. Ideally, the emission limits should be 40 dB less, or 0.3 uV/meter at 30 meters.

6.2 (b) Interference Mitigation Requirements for Access BPL Systems

• remote controllable shut-down features; • remote power reduction; and, • notch filtering and/or frequency avoidance.

The Department seeks comment on whether: (1) Access BPL equipment should incorporate adaptive interference mitigation techniques as described above; and,

(2) additional or alternative interference mitigation techniques, if any, should be used to minimize the potential

for interference to authorized services.

Please provide rationale

All three techniques should be employed, particularly the avoidance of the amateur radio bands, for the reasons given in section 6.2 (a) above.

The Department seeks comment on any additional technical requirements for access BPL system. Please provide supporting technical rationale.

: No comment

6.3 Operational Requirements

6.3 (a) Prohibited Frequency Bands

4 6.3 (b) Geographical Frequency Restrictions and Coordination Requirements

The Department seeks comment on: (1) What specific geographic locations, if any, should Access BPL systems be prohibited from operating? (2) As opposed to total ban, should Access BPL systems be able to operate in these locations if specific frequencies were avoided? (3) What procedure, if any, should be used to facilitate coordination between BPL operators and specific authorized users? Please provide rationale. : (1) No comment. (2) Operation of BPL would be acceptable if the amateur radio bands were avoided. (3) The Department must prepare regulations and protocols that require BPL operators to communicate with, and respond to, spectrum users filing interference complaints.

6.3 (c) Interference Resolution

: (1) If the BPL operator is to be the first point of contact, the Department’s regulations and protocols should include time-frames for both the response to a notification of interference and for the action to resolve the interference. (2) If the BPL operator does not resolve an interference problem in a timely manner, the Department should then intervene, and require the operator to comply. There should be severe penalties to the operator if compliance is not swift. Good engineering is paramount if BPL interference I to be eliminated in the first place.

: The USA experience as reported by ARRL is that the web sites maintained by BPL operators are not readily available to affected parties, and usage is restricted. Therefore, the website should be maintained by the Department.

Submitted by Joseph A.”Lou” Beaubien VE7CGE (

19 Nov 2005 My File 2800-5

Director General, Spectrum Engineering Branch Industry Canada, 300 Slater Street, Ottawa, ON K1A 0C8

Subject: Response to Canada Gazette Notice SMSE-005-05 dated July 19, 2005 Consultation Paper on Broadband over Power Line (BPL) Communications Systems

Dear Sir:

Below are my comments to

Notice No SMSE -005-05-Consultation Paper on Broadband Over Power Lines Prepared with MS Word 2003 XP home edition

GENERAL

I wish to comment on the document referred to above. Industry Canada's decisions on the matter of BPL can have a severe impact on the ability of licensed and authorized radio users to receive and communicate on MF, HF and VHF spectrum, and in particular, on the future of the Amateur Radio Service. I have been a licensed amateur radio operator for 22 years in various communities involving communications for personal enjoyment, as well as for the benefit of our community, and in particular to provide communications during local, national and international emergencies where other communications means have failed.

Having reviewed your Paper and other available literature on the subject, I believe that the introduction of BPL with the proposed emission limits, will create harmful interference to authorized and legitimate uses of the radio spectrum. In its current state of development, wide-area BPL could have a devastating effect on radio users in the range 2 – 80 MHz and beyond, and deprive them of a legitimate use of this spectrum. It is my firm opinion that BPL has the potential of bearing devastating effects on Amateur Radio. The possible benefits of provision of this service to a few, is far outweighed by the potential harm to communities in times of emergencies if our Amateur service is compromised in any way by interference. Our ability to transmit and hear weak signals must not be impaired if we are to be effective. In order to ensure this all amateur bands, frequencies and their related harmonics must be kept free of BPL use entirely.

RESPONSE

The following sections follow the numbering in Canada Gazette notice SMSE-005-05:

3. General Description of BPL Systems

No Comment

6.0 Discussion and Proposals

The Department also seeks comment on any other specificissue or concern relating to the Department’s role in the deployment andregulation of BPL systems ingeneral.

The amateur radio service is a significant resource to the local, national and international community, particularly in times of emergency. During major disasters such as the Katrina storm, the Asian Tsunami, and Okanogan fires, amateur radio via MF, HF and VHF networks was often the only communication available during and days after each disaster. BPL systems, in their present form, have the capability of interfering with or totally preventing radio operations. The Department has a substantial obligation to preserve the ability of radio systems to continue operation.

6.1 Equipment Standard and Approval Process

I agree that a technical standard is required for the equipment and the operating system. However, because the power-line is not designed for efficient transfer of Broad-Band signals, it is essential that the installed system be made compliant with a system standard that does not create harmful interference to other licensed or authorized users of the spectrum.

6.2 Prospective Technical Requirements

6.2 (a) Emission Limits

Access BPL systems operating below 30 MHz will be subject to following limits:

Frequency (MHz) Field strength Measurement (microvolts/metre) Distance (metres) 1.705-30.0 30 30

Access BPL systems operating above 30 MHz will be subject to the following limits:

Frequency (MHz) Field strength Measurement (microvolts/metre) Distance (metres) 30-80 90 10

The Department seeks comment on the above limits and their suitability for Access BPL systems in Canada. Please provide technical rationale.

6.2 (b) Interference Mitigation Requirements for Access BPL Systems

• remote controllable shut-down features; • remote power reduction; and, • notch filtering and/or frequency avoidance.

The Department seeks comment on whether: (1) Access BPL equipment should incorporate adaptive interference mitigation techniques as described above; and, (2) additional or alternative interference mitigation techniques, if any, should be used to minimize the potential for interference to authorized services. Please provide rationale

All three techniques should be employed, particularly the avoidance of the amateur radio bands, for the reasons given in section 6.2 (a) above.

The Department seeks comment on any additional technical requirements for access BPL system. Please provide supporting technical rationale.

No comment

6.3 Operational Requirements

6.3 (a) Prohibited Frequency Bands

6.3 (b) Geographical Frequency Restrictions and Coordination Requirements

(1) No comment. (2) Operation of BPL would be acceptable if the amateur radio bands were avoided completely. (3) The Department must prepare regulations and protocols that require BPL operators to communicate with, and respond to, spectrum users filing interference complaints.

6.3 (c) Interference Resolution

Conclusion Radio amateurs are not against BPL per se and recognize that BPL may benefit some Canadians. However, given the interference problems that have been experienced by radio amateurs in various countries to-date from BPL system radiation, radio amateurs strongly believe that it is incumbent upon the Department to regulate BPL equipment and systems to eliminateinterference to all HF radio services from these unconventional, non- radio data and telecommunications systems.

Submitted by Neil Blackburn VE7EDO 920 Woodhall Dr Victoria BC V8X 3L8

Rob Boux – VE4RRB 667 Munroe Avenue Winnipeg, MB, R2K-1H9 October 23, 2005

Dr. Robert McCaughern Director General Spectrum Engineering Industry Canada, 300 Slater Street, Ottawa, ON K1A 0C8

Subject: Rob Boux, VE4RRB - Response to Canada Gazette Notice SMSE-005-05 dated 2005-07-30 Consultation Paper of Broadband over Power Line (BPL) Communications Systems

Dear Dr. McCaughern:

GENERAL

I fell that I must voice my concerns that BPL - in it's current state of development cannot be deployed without major adverse effect on users of the HF spectrum, which include the Amateur Radio Service.

RESPONSE

The following numbered sections follow the numbering in Canada Gazette notice SMSE-005-05

3. General Description of BPL Systems

At this time, the Department is proposing to adopt the following definition for Access BPL systems:

Access Broadband over Power Line (Access BPL): A carrier current system installed and operated on an electric utility service as an unintentional radiator that sends radio frequency energy on frequencies between 1.705 MHz and 80 MHz over medium-voltage lines or over low-voltage lines to provide broadband communications and is located on the supply side of the utility service’s points of interconnection with customer premises.

The Department seeks comment on the above definition and its suitability for describing Access BPL. ` Response: I agree with the description of BPL

3.3 In-house BPL

At this time, the Department is proposing to adopt the following definition7 for In-house BPL systems:

In-house broadband over power line (In-house BPL): A carrier current system, operating as an unintentional radiator, which sends radio frequency energy by conduction over electric power lines that are not owned, operated or controlled by an electric service provider. The electric power lines may be aerial (overhead), underground, or inside the walls, floors or ceilings of user premises. In-house BPL devices may establish closed networks within a user’s premises or provide connections to Access BPL networks, or both.

The Department seeks comment on the above definition and its suitability for describing In- house BPL.

Response: I agree with the description of BPL

6.0 Discussion and Proposals

Suggested Reply: This is the where you have the opportunity to comment on the record of BPL to date, the effect it will have on all HF communications including Amateur Radio. Comment on the effect on Amateur Radio communications in emergencies, you could refer to the Asian Tsunami for instance. This is also the place to comment on any specific standards you may think necessary.

6.1 Equipment Standard and Approval Process

The Department is considering the development of a new Interference Causing Equipment Standard (ICES) for Access BPL equipment. With regard to demonstrating compliance with the technical standards, the Department has a number of options ranging from Declaration of Compliance to Certification.

Industry Canada believes that the potential for interference to existing radio communication services warrants an approach that will ensure equipment compliance with the technical standard. Therefore, the Department is proposing that the certification process be used for Access BPL equipment. The certification process will include the submission of a test report that will demonstrate compliance with the standards in the appropriate ICES.

Response: ”An Interference Causing Equipment Standard (ICES) is required. The certification process needs to include both the equipment and the installed system. Rationale: It is not necessarily the equipment that radiates the interference rather it is the power lines the equipment uses to conduct the data that radiates interference. Therefore the complete system must comply with the standards.

The Department seeks comment on the proposed certification process and what, if any, alternative approaches could be used to authorize BPL equipment and systems. Please provide rationale.

6.2 Prospective Technical Requirements

(a) Emission Limits

Access BPL systems operating below 30 MHz will be subject to following limits:

Frequency (MHz) Field strength Measurement (microvolts/metre) Distance (metres) 1.705-30.0 30 30

Access BPL systems operating above 30 MHz will be subject to the following limits:

Frequency (MHz) Field strength Measurement (microvolts/metre) Distance (metres) 30-80 90 3

The Department seeks comment on the above limits and their suitability for Access BPL systems in Canada. Please provide technical rationale.

Response: The emission limits proposed are far to strong. The emission limits should be no more than 1 uV/meter at 30 meters.

Rationale: The average urban lot where the majority of Amateur Radio Operators live is about 50 feet by 100 feet or 30 meters by 15 meters, with medium voltage power lines across the back or front of the lot. That means that the amateur’s antenna would always be inside the maximum emission coverage area. Amateur Radio operators routinely communicate at or just above the noise floor. The noise floor in our urban area here in Winnipeg and probably applicable to all urban areas across Canada is around S 4 on our receiver’s signal strength meter or 1 uV/m at the antenna.

(b) Interference Mitigation Requirements for Access BPL Systems In addition to establishing appropriate emission limits, the Department is proposing that Access BPL equipment/systems incorporate adaptive interference mitigation techniques to minimize the potential for interference to radio communication users. These include:

• remote controllable shut-down features; • remote power reduction; and, • notch filtering and/or frequency avoidance.

Please provide rationale.

Response: All three techniques should be employed. In addition BPL systems should permanently notch the Amateur Radio frequencies or avoid these bands altogether. In any case BPL signals should be below 1 uV/M on all ham bands.

Rationale: See section 6.2 (a)

The Department has proposed a number of technical requirements to address the use of Access BPL equipment and to minimize the potential for interference to authorized services from deployed Access BPL systems.

The Department seeks comment on any additional technical requirements for access BPL system. Please provide supporting technical rationale.

No Response

6.3 Operational Requirements

(a) Prohibited Frequency Bands

Response: In order to co-exist with BPL, as it is currently developed, and to protect the “authorized users” as stated in para 3 of the intent of this consultation paper, I believe that all authorized users of the MF, HF & VHF spectrum must have their frequency bands excluded from use by BPL systems.

(b) Geographical Frequency Restrictions and Coordination Requirements

The Department believes that there could be specific geographic areas where Access BPL systems should not be deployed and that coordination with specific authorized users may be necessary.

Please provide rationale.

Response: (1) BPL should only be installed in rural areas where there is no other option for broadband connectivity or there is no other service offering available. (2) As stated in (1), if BPL is installed in rural areas, then frequencies used by the Amateur Service should be notched out. (3) BPL, should (if allowed to be installed in specified un-service by other broadband services) should employ remote ability to notch out frequencies that it may be interfering with. As soon as any interference is reported. An authorized user of the spectrum should not have to prove their case to a service that is not authorized or licensed. It should be that the BPL provider, must prove that there is no interference or radiation.

The Department is considering requirements for BPL operators to address potential interference complaints. In particular, individuals and organizations with complaints would be asked to directly contact Access BPL operators to investigate and resolve problems. If a problem could not be resolved satisfactorily or in a timely manner, the Department would address the problem as an interference complaint under the Radio communication Act.

Please provide rationale.

Response: Industry Canada should be the first point of contact and should be prepared to resolve the interference within 24 hours .The department has to be prepared to treat all authorized users of the spectrum equally. The Amateur Radio service should be treated no different than any commercial radio service. All complaints not resolved by the BPL operator with 24 hours, needs to be passed to the department to investigate immediately.

Industry Canada believes that establishing a publicly accessible database would assist in the timely resolution of interference complaints. Therefore, the Department is of the opinion that a database of BPL installations should be developed and maintained.

Please provide rationale.

Response: Experience shows us that a web site maintained by the BPL operators plays games and is not friendly. See the The ARRL Letter Vol. 24, No. 40 October 14, 2005 available on their web site at http://www.arrl.org. If a database is to be established, then it must be maintained by the Department with real time entry of complaints to the database and real time transmissions of the complaints to the BPL operator. Cost of this system should be borne by the BPL operator. Monitoring of timely resolving of complains should be done by the department.

Conclusion

• As BPL is an unlicensed service that is known to radiate energy into the radio spectrum. It must be held accountable for ALL INTERFERENCE it causes, no matter how small. The Amateur Radio service is a worldwide service, which uses very low signal strength to receive distant communications. Any additional signals to the noise floor will result in the inability to use the service as it is known today. Amateur Radio receivers today are extremely sensitive and it has been proven that BPL trails in the USA, Australia, & New Zealand have caused interference severe enough to totally wipe out the ability to receive even a strong HF signal on the Amateur Radio bands. The Amateur Radio service is the last line of communication and the first line in a disaster. BPL has the potential to remove this important service, which in turn can cause more loss of life. Recent Hurricanes Katrina & Rita come to mind, as well as the Ice storms of Quebec and Ontario and the 1997 flood in Manitoba, as well as the forest fires in BC in 2004. Doesn’t Amateur Radio’s ability to provide a service to the community out weigh the interference that BPL can cause? Or does lose of life and property not mean as much as a power companies need to generate more revenue. If BPL is not implemented, then other forms of broadband will make its way to the smaller rural communities that BPL now wants to serve. BPL is just one of many services that allow for broadband technology. DSL (Digital Subscriber Lines), Cable Television, WiFi and WiMax, Mesh Networks, Wireless Internet Service Providers (WISPs), Fiber. Satellite. Technology improvements are happening every day. Costs to implement known technologies are dropping fast. Competition will find the rural market. The department should be encouraging interference free technologies rather than allowing BPL, which will cause interference.

Yours sincerely,

Rob Boux VE4RRB Valerie Byers 3291 Chaucer Avenue North Vancouver, B.C. V7K 2C2 Tel: 604-890-1083 e-mail: [email protected]

November 23, 2005

Director General, Spectrum Engineering Branch Industry Canada 300 Slater Street Ottawa, ON K1A 0C8 [email protected]

Subject: Response to Canada Gazette Notice SMSE-005-05 dated July 19, 2005, Consultation Paper on Broadband over Power Line (BPL) Communications Systems

Dear Sir: I have been a licensed amateur radio operator for 4 years, and am a member of the North Shore Amateur Radio Club, 147 East 14th Street, North Vancouver, B.C. V7L 2N4. I am also a member of the BCYLARA organization , (B.C. Young Ladies Amateur Radio Association) a group which encourages and fosters female hams. While I am still very new to the hobby I would like to comment on several points concerning the introduction of BPL with the proposed emission limits, following the numbering in Canada Gazette notice SMSE-005-05. 3. General Description of BPL Systems No comment 6.0 Discussion and Proposal Our local ham radio club (North Shore Amateur Radio Club) is active in supplying MF , HF and VHF communication for various local events and has an active connection with local and Provincial emergency management operations using various bandwidths. The great Okanagan fires and a major mudslide here in North Vancouver used amateur radio extensively to assist in the emergency response. As I understand it, the proposed BPL systems can interfere with or totally prevent such radio operations. 6.1 Equipment Standard and Approval Process Since power lines as such are not designed for efficient transfer of Broadband signals, it becomes very important that any new such systems be designed so as to harmonize with existing Amateur radio HF usage, so such new systems not create harmful interference to other licensed or authorized users of the spectrum, such as coast guard , aviation and emergency services responders.

6.2(a) Emission Limits The proposed 30 microvolts signals for below 30 MHz are substantially greater then the typical weak HF signals from distant stations and will cause interference so great as to make reception and transmission very difficult, particularly adjacent to The neighbourhood power lines. A suggested limit of 40dB less, or 0.3 uV/metre at 30 metres would solve this problem

6.2(b) The use of remote controllable shut-down features, remote power reduction and Notch filtering and or frequency avoidance are helpful. The most helpful would be to avoid the Amateur radio bands. Re: additional technical requirement: No comment 6.3(a) There are parts of the MF/HF/low VHF spectrum such as 30-50 MHz where BPL would least affect amateur emergency operations; the Department has the ability to carefully choose bandwidths so as to protect existing services, and to locate BPL in segments least likely to harm them. 6.3(b) 1. No comment 2. BPL transmissions would be best if not transmitting on amateur radio bands 3. The Department has the power to prepare regulations and procedures that would require BPL operators to communicate with and respond to spectrum users filing interference Complaints. 6.3(c) 1.If the BPL operator is the first point of contact, there must be time frames for both the BPL parties response to a notice of interference, and for the actions to resolve such interference. 2. If the BPL operator does not respond/resolve interference problems in a timely Manner, the Department then needs to intervene and insure compliance. 3. Re: a suggested database to assist with complaints: The ARRL has reported that web sites maintained by the BPL operators are not easily accessible and usage is restricted. Therefore, the Department should maintain the web site(s). Conclusion: Radio operators are not against BPL per se. However, given the interference problems that have been experienced by radio amateurs in various countries to date from BPL system radiation; it is imperative that the Department regulate BPL equipment and systems so as to to minimize interference to all HF radio services. It would appear that this is possible! There are certain low voltage designs of BPL systems that are apparently not interfering as much (Motorola?)

Your’s sincerely Valerie Byers, VA7 FEY, Member, North Shore Amateur Radio Club.

I have been an amateur radio operator for five years and hold all related certificates: Basic, Morse Code, and Advanced. It is common knowledge that the last 80 or so years has seen the mushrooming of radio spectrum congestion. In an effort to secure reliable communications all wireless communications operators have been forced to use higher power levels and larger antennas to overcome this background of increased radio activity. At the same time there has always been the responsibility of operators to use the least amount of power to achieve communication. I currently use a tenth of the power I am entitled to use. As each step is taken by all involved parties to be heard over this radio noise floor we all will be forced to use more power and larger antennas.

The mentality of the 'cold war' where one problem escalates to a bigger problem is all but over. I hope those involved with this experiment of imposing radio frequency signals onto arguably the largest antenna network I can imagine (the power lines)do their job properly and insure the airwaves don't become a new environment of "keeping up with Jones". Please ensure that I can continue to use the smallest amount of transmission power to be heard rather than defaulting to my maximum legal limit. On this point I hope we can all agree.

Many thanks, David Cameron VA7DAC 4547 Dumfries St. Vancouver, BC

22 November 2005

David Cheney 338 Arlington Cres. Beaconsfield QC H9W 2K3 (514) 694-3240 [email protected]

To: Director General, Spectrum Engineering Branch Industry Canada, 300 Slater Street, Ottawa, ON K1A 0C8

Subject: Response to Canada Gazette Notice SMSE-005-05 dated July 19, 2005 Consultation Paper on Broadband over Power Line (BPL) Communications Systems

Dear Sir:

GENERAL

I, David Cheney, wish to comment on the document referred to above. Industry Canada's decisions on the matter of BPL can have a severe impact on the ability of licensed and authorized radio users to receive and communicate on MF, HF and VHF spectrum, and in particular, on the future of the Amateur Radio Service.

I have been a licensed amateur radio operator for 5 years in the community of Beaconsfield, and I am involved in radio communications for personal enjoyment, as well as for the benefit of our community, and in particular to provide communications during local, national and international emergencies where other communications means have failed.

RESPONSE

The following sections follow the numbering in Canada Gazette notice SMSE-005-05:

3. General Description of BPL Systems No Comment

6.0 Discussion and Proposals

The Department also seeks comment on any other specific issue or concern relating to the Department’s role in the deployment and regulation of BPL systems in general.

6.1 Equipment Standard and Approval Process

6.2 Prospective Technical Requirements

6.2 (a) Emission Limits

Access BPL systems operating below 30 MHz will be subject to following limits:

Frequency (MHz) Field strength Measurement (microvolts/metre) Distance (metres) 1.705-30.0 30 30

Access BPL systems operating above 30 MHz will be subject to the following limits:

Frequency (MHz) Field strength Measurement (microvolts/metre) Distance (metres) 30-80 90 10

The Department seeks comment on the above limits and their suitability for Access BPL systems in Canada. Please provide technical rationale.

Most Amateur Radio stations are located within 30m of a LV or MV power line, and more likely within 10m in a residential area. A dipole antenna located near a BPL power line (often less than 30 m) will intercept an interfering BPL signal that is substantially greater than the typical weak-signal from a distant station. An emission level of 30 uv/m would block all reception except for the very strong signals, which are not typical.

6.2 (b) Interference Mitigation Requirements for Access BPL Systems

• remote controllable shut-down features; • remote power reduction; and, • notch filtering and/or frequency avoidance.

The Department seeks comment on whether: (1) Access BPL equipment should incorporate adaptive interference mitigation techniques as described above; and,

(2) additional or alternative interference mitigation techniques, if any, should be used to minimize the potential

for interference to authorized services.

Please provide rationale

All three techniques should be employed, particularly the avoidance of the amateur radio bands, for the reasons given in section 6.2 (a) above.

The Department seeks comment on any additional technical requirements for access BPL system. Please provide supporting technical rationale.

No comment

6.3 Operational Requirements

6.3 (a) Prohibited Frequency Bands

6.3 (b) Geographical Frequency Restrictions and Coordination Requirements

6.3 (c) Interference Resolution

Submitted by: David Cheney, VA2DGC

M. Collette Box 97 St Pierre-Jolys,Manitoba r0a1v0 November 21, 2005

Dr. Robert McCaughern Director General Spectrum Engineering Industry Canada, 300 Slater Street, Ottawa, ON K1A 0C8

Subject: Response to Canada Gazette Notice SMSE-005-05 dated 2005-07-30 Consultation Paper of Broadband over Power Line (BPL) Communications Systems

Dear Dr. McCaughern:

GENERAL

I consider that it must emphasize its concerns that BPL in it's current state of development cannot be deployed without major adverse effect on users of the HF spectrum which include the Amateur Radio Service.

RESPONSE

The following numbered sections follow the numbering in Canada Gazette notice SMSE-005-05

3. General Description of BPL Systems

At this time, the Department is proposing to adopt the following definition for Access BPL systems:

The Department seeks comment on the above definition and its suitability for describing Access BPL. ` No Comment

3.3 In-house BPL

At this time, the Department is proposing to adopt the following definition7 for In-house BPL systems:

The Department seeks comment on the above definition and its suitability for describing In- house BPL.

No Comment

6.0 Discussion and Proposals

6.1 Equipment Standard and Approval Process

Industry Canada believes that the potential for interference to existing radiocommunication services warrants an approach that will ensure equipment compliance with the technical standard. Therefore, the Department is proposing that the certification process be used for Access BPL equipment. The certification process will include the submission of a test report that will demonstrate compliance with the standards in the appropriate ICES.

An Interference Causing Equipment Standard (ICES) is required. The certification process needs to include both the equipment and the installed system. Rationale: It is not necessarily the equipment that radiates the interference rather it is the power lines the equipment uses to conduct the data that radiates interference. Therefore the complete system must comply with the standards.

The Department seeks comment on the proposed certification process and what, if any, alternative approaches could be used to authorize BPL equipment and systems. Please provide rationale.

6.2 Prospective Technical Requirements

(a) Emission Limits

Access BPL systems operating below 30 MHz will be subject to following limits:

Frequency (MHz) Field strength Measurement (microvolts/metre) Distance (metres) 1.705-30.0 30 30

Access BPL systems operating above 30 MHz will be subject to the following limits:

Frequency (MHz) Field strength Measurement (microvolts/metre) Distance (metres) 30-80 90 3

The Department seeks comment on the above limits and their suitability for Access BPL systems in Canada. Please provide technical rationale.

• remote controllable shut-down features; • remote power reduction; and, • notch filtering and/or frequency avoidance.

Please provide rationale.

All three techniques should be employed. In addition BPL systems should permanently notch the ham bands or avoid these bands altogether. In any case BPL signals should be below 1 uV/M on all ham bands.

Rationale: See section 6.2 (a)

The Department seeks comment on any additional technical requirements for access BPL system. Please provide supporting technical rationale.

No comment

6.3 Operational Requirements

(a) Prohibited Frequency Bands

In order to co-exist with BPL, as it is currently developed, and protect “authorized users” as stated in para 3 of the intent of this consultation paper, I believe that all authorized users of the HF spectrum must have their frequencies bands excluded from use by BPL systems

(b) Geographical Frequency Restrictions and Coordination Requirements

The Department believes that there could be specific geographic areas where Access BPL systems should not be deployed and that coordination with specific authorized users may be necessary.

Please provide rationale.

No comment

Please provide rationale.

Industry should be the first point of contact and should be prepared to resolve the interference within 21 days.

Please provide rationale.

Conclusion

Radio amateurs are not against BPL per se and recognize that BPL may benefit some Canadians. However, given the interference problems that have been experienced by radio amateurs in various countries to-date from BPL system radiation, radio amateurs strongly believe that it is incumbent upon the Department to regulate BPL equipment and systems to minimize interference to all HF radio services from these unconventional, non-radio data and telecommunications systems.

Yours sincerely, Marc Collette, VA4CQD To Director General, Spectrum Engineering Branch Industry Canada, 300 Slater Street, Ottawa, ON K1A 0C8 :

From Francois Daigneault 520 rue De Gaspe Apt 510 Verdun QC H3E 1G1 514-762-1722 [email protected]

Subject: Response to Canada Gazette Notice SMSE-005-05 dated July 19, 2005 Consultation Paper on Broadband over Power Line (BPL) Communications Systems

Date 2005 11 28

Dear Sir, I must express serious concern over some of the proposals in your Consultation Paper and more precisely over the proposed emission limits. As an Amateur Radio operator (licensed 1969), I have a certain perspective on the matter.

The following sections follow the numbering in Canada Gazette notice SMSE-005-05:

6.2 (a) Emission Limits

Other individuals with a suitable engineering background will have commented that the proposed limits are likely to produce wideband noise which would obliterate MF and HF reception of signals in the range of 1 to 3 microvolts (after travelling hundreds and thousands of kilometres ).

6.2 (b) Interference Mitigation

Frequency avoidance is likely to compound the problem for others not-so-lucky users of the spectrum (i.e., most of the bandwidth would be carried in their segments): another argument for very stringent emission limits.

6.3 (c) Interference Resolution

Given that most of the population using the radio spectrum lacks the technical savvy to identify interference problems, the Department must play an active and central role in resolving interference complaints.

Conclusion

The HF spectrum is a unique commodity. Please ensure that it remains usable. Remote areas may be the very places with the greatest dependence on a clean radio spectrum. Vince Davies, VE4JIL # 158 – 144 Portsmouth Blvd. Winnipeg., Manitoba R3P1B6 Canada

Dr. Robert McCaughern Director General Spectrum Engineering Industry Canada, 300 Slater Street, Ottawa, ON K1A 0C8

Subject: (Vince Davies, VE4JIL)Response to Canada Gazette Notice SMSE-005-05 dated 2005-07-30 Consultation Paper of Broadband over Power Line (BPL) Communications Systems

Dear Dr. McCaughern:

GENERAL

As part of the 50,000 licensed Canadian amateur radio operators, (Vince Davies) appreciate the opportunity to comment on this important document. Industry Canada's decisions as a result of this consultation could have a severe impact on the future of the Amateur Radio Service (expand).

(I, Vince Davies, a licensed HAM radioist consider(s) that it must emphasize its concerns that BPL in it's current state of development cannot be deployed without major adverse effect on users of the HF spectrum which include the Amateur Radio Service.

RESPONSE

The following numbered sections follow the numbering in Canada Gazette notice SMSE-005-05

3. General Description of BPL Systems

At this time, the Department is proposing to adopt the following definition for Access BPL systems:

The Department seeks comment on the above definition and its suitability for describing Access BPL. Reply: I disagree with this method.

3.3 In-house BPL

At this time, the Department is proposing to adopt the following definition7 for In-house BPL systems:

The Department seeks comment on the above definition and its suitability for describing In- house BPL.

Answer “I disagree”

6.0 Discussion and Proposals

6.1 Equipment Standard and Approval Process

Industry Canada believes that the potential for interference to existing radiocommunication services warrants an approach that will ensure equipment compliance with the technical standard. Therefore, the Department is proposing that the certification process be used for Access BPL equipment. The certification process will include the submission of a test report that will demonstrate compliance with the standards in the appropriate ICES.

Reply: An Interference Causing Equipment Standard (ICES) is required. The certification process needs to include both the equipment and the installed system. Rationale: It is not necessarily the equipment that radiates the interference rather it is the power lines the equipment uses to conduct the data that radiates interference. Therefore the complete system must comply with the standards.

The Department seeks comment on the proposed certification process and what, if any, alternative approaches could be used to authorize BPL equipment and systems. Please provide rationale.

6.2 Prospective Technical Requirements

(a) Emission Limits

Access BPL systems operating below 30 MHz will be subject to following limits:

Frequency (MHz) Field strength Measurement (microvolts/metre) Distance (metres) 1.705-30.0 30 30

Access BPL systems operating above 30 MHz will be subject to the following limits:

Frequency (MHz) Field strength Measurement (microvolts/metre) Distance (metres) 30-80 90 3

The Department seeks comment on the above limits and their suitability for Access BPL systems in Canada. Please provide technical rationale.

Reply: The emission limits proposed are far to strong. The emission limits should be no more than 1 uV/meter at 30 meters.

Rationale: The average urban lot where the majority of Amateur Radio Operators live is about 50 feet by 100 feet or 30 meters by 15 meters, with medium voltage power lines across the back or front of the lot. That means that the amateurs antenna would always be inside the maximum emission coverage area. Amateur Radio operators routinely communicate at or just above the noise floor. The noise floor in our urban area here in Winnipeg and probably applicable to all urban areas in Canada is around S 4 on our receivers signal strength meter or 1 uV/m at the antenna.

• remote controllable shut-down features; • remote power reduction; and, • notch filtering and/or frequency avoidance.

Please provide rationale.

Reply: All three techniques should be employed. In addition BPL systems should permanently notch the ham bands or avoid these bands altogether. In any case BPL signals should be below 1 uV/M on all ham bands.

Rationale: See section 6.2 (a)

The Department seeks comment on any additional technical requirements for access BPL system. Please provide supporting technical rationale.

Reply: “I disagree”

6.3 Operational Requirements

(a) Prohibited Frequency Bands

Reply: In order to co-exist with BPL, as it is currently developed, and protect “authorized users” as stated in para 3 of the intent of this consultation paper, (I, Vince Davies) believe that all authorized users of the HF spectrum must have their frequencies bands excluded from use by BPL systems

(b) Geographical Frequency Restrictions and Coordination Requirements

The Department believes that there could be specific geographic areas where Access BPL systems should not be deployed and that coordination with specific authorized users may be necessary.

Please provide rationale.

Reply: 1) if there was a way not to infringe on the HF bands to bring BPL to remote areas, then I’d say that it shouldn’t be prohibited. 2) Access BPL systems should not be able to operate at all in side all of the HF bands. 3) Just do not allow BPL to operate in the HF bands.

Please provide rationale.

Reply: Industry should be the first point of contact and should be prepared to Resolve the interference within (your opinion) days.

Please provide rationale.

Reply: (I would like to see cooperative information access, and social responsibility combined with the use of common sense & respect. The ARRL experience is that the web site maintained by the BPL operators plays games and is not friendly. See the The ARRL Letter Vol. 24, No. 40 October 14, 2005 available on their web site at www.arrl.org)

Conclusion

Broadband over Power Lines (BPL) or Power Line Communications (PLC) has the potential to substantially increase the noise floor and have a negative impact on many users of the Radio Spectrum.

There are ways to deliver broadband that do not pollute the radio spectrum as Broadband over Power Line (BPL) does. These include fiber-to-the-home, cable, DSL, and wireless broadband. The ARRL--The National Association for Amateur Radio-- is supportive of broadband access for all Canadians; however, it opposes BPL as a way to achieve this goal because of its high potential for causing interference to radiocommunication.

Yours sincerely,

Vince Davies, VE4JIL # 158 – 144 Portsmouth Blvd. Winnipeg., Manitoba R3P1B6 Canada Page 1 of 4

David C. Dawson (VE7HP / VE7HDC / Sponsor for Kerrisdale Community Centre VA7KRA) #105 – 2121 West 44th Avenue Vancouver, BC V6M 2G5 November 13 2005

Director General, Spectrum Engineering Branch Industry Canada, 300 Slater Street, Ottawa, ON K1A 0C8

Subject: Response to Canada Gazette Notice SMSE-005-05 dated July 19, 2005 Consultation Paper on Broadband over Power Line (BPL) Communications Systems

Dear Sir: I, David Dawson wish to comment on the document referred to above. Industry Canada's decisions on the matter of BPL can have a severe impact on the ability of licensed and authorized radio users to receive and communicate on MF, HF and VHF spectrum, and in particular, on the future of the Amateur Radio Service.

I have been a licensed amateur radio operator for 15 years in the community of Vancouver, BC who is involved in radio communications for personal enjoyment, as well as for the benefit of our community, and in particular to provide communications during local, national and international emergencies where other communications means have failed.

RESPONSE

The following sections follow the numbering in Canada Gazette notice SMSE-005-05:

3. General Description of BPL Systems

No Comment

6.0 Discussion and Proposals

The Department also seeks comment on any other specific issue or concern relating to the Department’s role in the deployment and regulation of BPL systems in general.

6.1 Equipment Standard and Approval Process

Page 2 of 4

6.2 Prospective Technical Requirements

6.2 (a) Emission Limits

Access BPL systems operating below 30 MHz will be subject to following limits:

Frequency (MHz) Field strength Measurement (microvolts/metre) Distance (metres) 1.705-30.0 30 30

Access BPL systems operating above 30 MHz will be subject to the following limits:

Frequency (MHz) Field strength Measurement (microvolts/metre) Distance (metres) 30-80 90 10

The Department seeks comment on the above limits and their suitability for Access BPL systems in Canada. Please provide technical rationale.

Most Amateur Radio stations are located within 30 m of a LV or MV power line. A dipole antenna located near a BPL power line (often less than 30 m) will intercept an interfering BPL signal that is substantially greater than the typical weak-signal from a distant station. An emission level of 30 uv/m would block all reception except for the very strong signals, which are not typical. I t should be noted that a dense network of electrical transmission lines carrying BPL within a city will increase the noise floor to far above that generated by an effective point source or a few scattered point sources.

6.2 (b) Interference Mitigation Requirements for Access BPL Systems

• remote controllable shut-down features; • remote power reduction; and, • notch filtering and/or frequency avoidance.

The Department seeks comment on whether: (1) Access BPL equipment should incorporate adaptive interference mitigation techniques as described above; and,

(2) additional or alternative interference mitigation techniques, if any, should be used to minimize the potential

for interference to authorized services.

Please provide rationale

Page 3 of 4

All three techniques should be employed, particularly the avoidance of the amateur radio bands, for the reasons given in section 6.2 (a) above.

The Department seeks comment on any additional technical requirements for access BPL system. Please provide supporting technical rationale.

No comment

6.3 Operational Requirements

6.3 (a) Prohibited Frequency Bands

6.3 (b) Geographical Frequency Restrictions and Coordination Requirements

(1) No comment. (2) Operation of BPL would be acceptable if the amateur, utility and short wave broadcast radio bands were avoided. (3) The Department must prepare regulations and protocols that require BPL operators to communicate with, and respond to, spectrum users filing interference complaints. 6.3 (c) Interference Resolution

Page 4 of 4

The Department seeks comment on the establishment of a publicly accessible database and its potential to ensure the timely resolution of interference complaints. In particular: (1) What specific information should be included in the database? (2) How could the information be accessed and who should have access to the database? (3) Who should develop, maintain and manage the database? Please provide rationale. (1) No comment (2) I believe the information should be available to any interested party on a publicly accessable website. (3) The USA experience as reported by ARRL is that the web sites maintained by BPL operators are not readily available to affected parties, and usage is restricted. Therefore, the website should be maintained by the Department.

Submitted by David C. Dawson (VE7HP)

Ramesh Dhami 3327 Smoke Tree Road Mississauga, Ontario. L5N 7M5. Tel. 905.824.7260

Email: [email protected]

November 18, 2005

Director General, Spectrum Engineering Branch Industry Canada, 300 Slater Street, Ottawa, ON K1A 0C8

Subject: Response to Canada Gazette Notice SMSE-005-05 dated July 19, 2005 Consultation Paper on Broadband over Power Line (BPL) Communications Systems

Dear Sir:

GENERAL

Thank you for the opportunity to respond to the aforementioned Consolation Paper. I am pleased to comment on the document herewith. Industry Canada's decisions on the matter of BPL can have a severe impact on the ability of licensed and authorized radio users to receive and communicate on MF, HF and VHF spectrum, and in particular, on the future of the Amateur Radio Service.

I have been a licensed amateur radio operator for twenty-three (23) years. Having reviewed your Paper and other available literature on the subject, I believe that the introduction of BPL with the proposed emission limits will create harmful interference to authorized and legitimate uses of the radio spectrum. In its current state of development, wide-area BPL could have a devastating effect on radio users in the range 2 – 80 MHz and beyond, and deprive them of a legitimate use of this spectrum.

RESPONSE

The following sections follow the numbering in Canada Gazette notice SMSE-005-05:

Page 1 of 4

3. General Description of BPL Systems

No Comment

6.0 Discussion and Proposals

The Department also seeks comment on any other specific issue or concern relating to the Department’s role in the deployment and regulation of BPL systems in general.

6.1 Equipment Standard and Approval Process

I agree that a technical standard is required for the equipment and the operating system. However, because the power-line is not designed for efficient transfer of Broadband signals, it is essential that the installed system be made compliant with a system standard that does not create harmful interference to other licensed or authorized users of the spectrum.