Comments. to Industry Canada. regarding SMSE Issue 2 of ICES-006

Transcription

1 Comments to Industry Canada regarding SMSE Issue 2 of ICES-006 By: Ludo Bertsch, Horizon Technologies Inc. (250) ; ludob@horizontec.com Date: October 9, 2009 These comments are directed at Canada Gazette, Part 1, AC Wire Carrier Current Devices (Unintentional Radiators), Notice No. SMSE , (Issue 2 of ICES-006) and are in addition to our earlier comments submitted by on September 19, 2009 to Industry Canada. 1.0 Comments regarding the Addition of in-house BPL definition: As noted in the Preface of the new ICES-006 document, the definition of in-house BPL has been added 1. The new definition in section 2 states: In-house BPL means 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 underground or inside the walls, floors or ceilings of user premises." Include Aerial (overhead) in In-House BPL Definition On July 19, 2005, Industry Canada released its Consultation Paper on Broadband over Power Line (BPL) Communication Systems 3, gazette notice SMSE Industry Canada in the consultation paper discusses ICES-006: In Canada, In-house BPL equipment is regulated under Interference Causing Equipment Standard 006, AC Wire Carrier Current Devices (Unintentional 1 ICES-006, Issue 2, Preface 2 ICES-006, Issue 2, Section 2, Page 2 3 Consultation Paper on Broadband over Power Line (BPL) Communication Systems, Industry Canada, July Ludo Bertsch, Horizon Technologies Ref: 2009.Powerline.ICES006.Comments.004.doc Page 1 of 11

2 Radiators) (ICES-006) after reviewing the FCC s final rules in the context of the Canadian regulatory environment, the Department believes that separate definitions are required to differentiate between the two forms of BPL to prevent confusion. ICES-006 will be modified accordingly to reflect the adopted definitions for inhouse systems. At this time, the Department is proposing to adopt the following definition 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 [emphasis added] The Department seeks comment on the above definition and its suitability for describing In-house BPL. 6 We submit that the SMSE notice and follow-up comments to that notice was the process used by Industry Canada to provide its direction of the publication of the 2 nd Issue of ICES-006, and we find no evidence of any other input that was being used for the 2 nd Issue. We note that the new definition of in-house BPL for ICES-006 Issue 2 does not include aerial (overhead) power lines this is contrary to the suggestion in the SMSE consultation paper (as shown above) and to FCC. We note that approximate 39 companies 7 and 100 individuals 8 submitted comments in November 2005 to the consultation paper, which included aerial (overhead) in the definition. 4 Consultation Paper on Broadband over Power Line (BPL) Communication Systems, Industry Canada, July 2005, Page 6, Section Consultation Paper on Broadband over Power Line (BPL) Communication Systems, Industry Canada, July 2005, Page 6, Section Consultation Paper on Broadband over Power Line (BPL) Communication Systems, Industry Canada, July 2005, Page 6, Section Comments to SMSE from Private Individuals. 8 Comments to SMSE from Private Individuals. Ludo Bertsch, Horizon Technologies Ref: 2009.Powerline.ICES006.Comments.004.doc Page 2 of 11

3 Those comments include: a) Six companies/associations 9 and over 40 individuals 10 submitted the following comment: 3. General Description of BPL Systems No Comment 11 These respondents specifically noted the section, General Description of BPL Systems, which contains the definition of In-house BPL and by doing so, even with No Comment, we submit that generally these respondents would have at least read that section and would not have had any significant issues with the inclusion of aerial (overhead) in the In-House BPL definition or else they would have noted such issues. b) Approximate 8 individuals 12 copied the definition of In-house BPL of Section 3.3 into their documents, and then noted No Comment 13. We submit that by specifically including the In-House BPL definition in their documents, it is now certain, that these respondents did read the definition with the inclusion of aerial (overhead) and did not have any issue with it. c) One company/association 14 and 3 individuals 15 copied the definition of In-house BPL of Section 3.3 into their documents, and then noted they agreed to the statement or felt it was acceptable. It is very clear, we submit, that these respondents agreed with the inclusion of aerial (overhead) in the In-House BPL definition. d) Five companies/associations 16 (including Radio Advisory Board of Canada RABC - who represents a broadly representative group ) 9 BC Frequency Modulation Communications Association, Burnaby Amateur Radio Club, Lambton Country Radio Club, Nortown Amateur Radio Club, Ottawa Valley Mobile Radio Club, Westcoast Amateur Radio Association of Victoria BC. 10 Comments to SMSE from Private Individuals Appendix A. Selected comments from BC Frequency Modulation Communications Association are shown in Appendix A, which illustrates how this group of respondents had replied all others in this group replied in a similar fashion 12 Comments to SMSE from Private Individuals Appendix B. Selected comments of G. Bawden is shown in Appendix B, which illustrates how this group of respondents had replied all others in this group replied in a similar fashion. 14 Appendix C. Selected comments of Wolseley Repeater Group to SMSE Appendix D. Selected comments from Individuals to SMSE Appendix E. Selected comments from Companies/Associations to SMSE Ludo Bertsch, Horizon Technologies Ref: 2009.Powerline.ICES006.Comments.004.doc Page 3 of 11

4 specifically discussed the definition of In-house BPL of Section 3.3 in their documents and although they had comments, generally agreed to the definition by taking into account their comments, and did not indicate any issue with including aerial (overhead) in the definition. It is very clear, we submit, that these respondents agreed to inclusion of aerial (overhead) in the In-House BPL definition. e) Three companies/associations 17 specifically discussed the definition of In-house BPL of Section 3.3 in their documents. They disagreed with the use of unintentional radiator and therefore, disagreed with the definition. We submit that these respondents did not have issue to inclusion of aerial (overhead) in the In-House BPL definition. In total, this shows strong support of 15 companies/associations and over 50 individuals for the inclusion of aerial (overhead) in the In-house BPL definition. We also note that no respondents specially suggested removing aerial (overhead) from the definition. We also note that with ICES-006 Issue 2, Industry Canada is moving away from FCC, with no particular reason to do so. Therefore, we submit, that there is ample evidence for including aerial (overhead) in definition of In-House BPL and no evidence for removing aerial (overhead) from the definition. If the definition of In-house BPL remained as written in ICES-006 Issue 2, with the exclusion on aerial (overhead), we submit, would introduce a confusing and unfair situation in the marketplace. Certain products would be allowed for homes with underground power line feeders and others for aerial power line feeders would this mean the type of power line feeder would need to be labeled on the box of a retail product. This detailed technical information is well beyond what one would expect for a typical consumer. In addition, it would be hard to enforce regulations that allowed products only into houses without aerial feeders. In-house BPL devices, unlike Access BPL, can be moved from house to house and can be purchased at retail stores. If aerial (overhead) feeders were allowed in the US but not in Canada, it would cause unneeded differences and confusion between the US and Canada markets. This would contradict the direction as noted by the Radio Advisory Board of Canada: Clearly, a substantial degree of harmonization of technical standards and 17 Appendix F. Selected comments from Companies/Associations to SMSE Ludo Bertsch, Horizon Technologies Ref: 2009.Powerline.ICES006.Comments.004.doc Page 4 of 11

5 procedures with the US would be preferred, if Canadian users are to obtain foreign-made equipment at reasonable prices, or if there is any chance that a Canadian supplier might wish to serve the entire North American market. 18 Therefore, as supported by the issues noted above, we submit there is further support that aerial (overhead) power line feeders should be allowed for In-House BPL devices. 1.2 Use other terms than In-House We note that the RABC in their November 2005 comments to SMSE stated: the board considers that the phrase in-premise should be used rather than in-house to ensure clarity premise makes it clear that several different types of buildings may be considered. 19 We also note that the Canadian Electricity Association stated: it is recommended to use the term In-Building BPL or On-Site BPL since either of these terms are more comprehensive and appropriate that the proposed term In-House BPL because it would cover residential and commercial buildings such as hotels, hospitals, apartment buildings, and industrial buildings. In-House BPL taken in the physical sense, would not generally be understood to include an industrial complex. 20 We agree that terms such as those suggested by RABC and CEA are more appropriate than In-House BPL. We submit that since In-House BPL is being defined for the first time in this Issue 2 of ICES-006, it would also be an appropriate time to include more suitable terms, such as those suggested by RABC and CEA; inpremise, in-building or on-site. 1.3 Add description of Broadband in definition In its comments to the November 2005 Consultation Paper, Horizon Technologies noted that in the definition statements there were no mentions of broadband (only in the title) it is suggested broadband be referenced within the definition statements Appendix E, RABC, Page 6 of Appendix E, RABC, Page 8 of Appendix E, CEA, Page 10, Item Appendix E, Horizon Technologies, Page 3, Section 3.3 Ludo Bertsch, Horizon Technologies Ref: 2009.Powerline.ICES006.Comments.004.doc Page 5 of 11

6 In the Issue 2 of ICES-006, no change has been made, and the word broadband is used in the term In-house broadband over power (In-house BPL) 22 [emphasis added], but there is still no reference in its definition to what broadband means in this context, and therefore may encompass a wider range of products that is intended. UTC Canada in its comments to Industry Canada s consultation paper, suggested to add to provide broadband communications on frequencies between and 80 MHz 23 to the definition of In-house BPL. As noted by UTC Canada, otherwise, certain legacy systems, such as low speed power line carrier systems, for example, could be inadvertently swept up by the rules that apply to Access BPL 24. We submit that not including the MHz and 80 MHz frequencies in the In-house BPL definition is an in-appropriate situation and that without such clarification, this existing definition could lead to unnecessary ambiguity and misinterpretation. Industry Canada in its consultation paper noted that: Historically, power utilities have used alternating current (AC) power line distribution facilities to carry information by coupling radio frequency (RF) energy to AC electrical wiring in houses or buildings. In the past, these devices have operated on frequencies below 2 MHz with limited communications capabilities. 25 However, technological advancements have resulted in the development of new systems that which have overcome these technical obstacles. Trials have demonstrated that high-seed communications voice and data services can be achieved using the existing medium-voltage (MV) and low-voltage (LV) power distribution grid. 26 BPL technology has evolved rapidly over the past two years. While the technology appears promising, there are a number of issues with respect to its operation as well as the possibility of it interfering into radio services in the 2-80 MHz range. 27 We submit that Industry Canada, in statements noted above, clearly shows 22 Consultation Paper on Broadband over Power Line (BPL) Communication Systems, Industry Canada, July 2005, Page 6, Section Appendix E, UPLC/UTC, Page 7, Item III. 24 Appendix E, UPLC/UTC, Page 7, Item III. 25 Consultation Paper on Broadband over Power Line (BPL) Communication Systems, Industry Canada, July 2005, Page 1, Section Consultation Paper on Broadband over Power Line (BPL) Communication Systems, Industry Canada, July 2005, Page 1, Section Consultation Paper on Broadband over Power Line (BPL) Communication Systems, Industry Canada, July 2005, Page 1, Section 2. Ludo Bertsch, Horizon Technologies Ref: 2009.Powerline.ICES006.Comments.004.doc Page 6 of 11

7 that it considers BPL to be new technology above 2 MHz 28 and we submit that the wording of the definition of In-house BPL will need to be enhanced in order to reflect that. 1.4 Define Access BPL for MV and In-house BPL for LV We re-iterate the comment #2 in our September 18 , which suggested that the Issue 2 of ICES-006 be released at the same time as the new Access BPL regulation. We note in the comments of the Radio Amateurs of Canada attached to the RABC response to the consultation paper: However, significant problems remain with the mitigation of interference from BPL Access distributed over Medium Voltage (MV) power lines. RAC recommends that in formulating the standards for BPL systems, Industry Canada examine and encourage the use of BPL Access over LV lines instead of over MV lines As discussed by Richard Fryer in his comments to the Consultation Paper: Motorola developed a solution that does not use medium-voltage wiring, greatly reducing high-frequency (HF) interference. 30 None of the systems cause the level of interference and disruption that a MV BPL system would cause to the existing licensed users in high frequency bands. There is overwhelming evidence that the current proposal for broadband overpower line using medium voltage unshielded open wire transmission will cause significant interference to licensed users. 31 Edward J. Frazer, P. Eng notes: The result is high Standing-Wave, high attenuation, and high levels of radiation along the power line. This is particularly troublesome with BPL on MV lines, where the signal is carried on the top-most conductor, at pole heights of 40 to 50 feet. What is created is a huge long-wire antenna which radiates continuously along its route, and also at great distances under favorable propagation conditions. Even though BPL is considered a unintentional radiator, the system creates huge problems for other spectrum users because of this radiation. 32 From the statements above, we suggest that an important differentiating factor of BPL systems is the type of power line that are used; Medium Voltage (MV - 28 For the purposes of this discussion, we shall assume that 2 MHz is a shorthand for MHz and will be considered the same. 29 Appendix E, RABC, Page 4 of 28, Radio Amateurs 30 Appendix G, Richard Fryer, Page 3 31 Appendix G, Richard Fryer, Page 4 32 Appendix G, Edward J. Frazer, Page 2 Ludo Bertsch, Horizon Technologies Ref: 2009.Powerline.ICES006.Comments.004.doc Page 7 of 11

8 typically 12.5 to 36 kv) or Low Voltage (LV - typically 120/240 or 347/600 Volts). As noted above, MV lines are more prone to generating interference with runs of many miles and greater heights than LV lines of typically less than a few hundred feet. The voltage levels in electrical transmission are increased to reduce the losses for long distances, so by their very nature LV lines are shorter. In its November 28, 2005 comments to the Consultation Paper, Horizon Technologies suggested that the best way to define them is that as far as regulations are concerned Access BPL is medium voltage and In-House is low voltage. 33 An added benefit by this characterization is that it aligns with the type of products to be installed. The LV products, using typical 120/240V, would typically be sold in retail stores through direct sales to customers who would plug and play. On the other hand MV products would typically be sold via wholesale companies directly to installation companies or utilities used to installing high voltage equipment using ladder trucks or similar. In addition, Horizon Technologies stated: The discussion and definition considers an In-House BPL as not owned, operated or controlled by an electricity service provider.... The relationship to an electricity service provider is not helpful and should be removed. 34 As discussed in CABA s Oct 6, 2004 submission to the FCC on the same topic, there was an example of controllable hot water heaters being activated by the power utility over an In-House BPL system but according to the definition it would not be allowed and be considered an Access BPL system. 35 Therefore, we continue to support, and we submit that the definition of Access BPL should be limited to medium voltage, In-House BPL (or In- Premise) be limited to low voltage, and relationship to an electric service provider be removed. 1.5 Conclusion Suggested definition Therefore, we offer the following suggestion for the definition of Inpremise BPL (replacing In-house BPL ) and Low Voltage Electric Power Line : In-premise BPL means a carrier current system, operating as an unintentional radiator, which sends radio frequency energy to provide 33 Appendix E, Horizon Technologies, Page 2, Section Appendix E, Horizon Technologies, Page 3, Section Appendix E, Horizon Technologies, Page 3, Section 3.3 Ludo Bertsch, Horizon Technologies Ref: 2009.Powerline.ICES006.Comments.004.doc Page 8 of 11

9 broadband communications on frequencies between MHz and 50 MHz 36 by conduction over low voltage electric power lines. The electric power lines may be aerial (overhead), underground or inside the walls, floors or ceilings of user premises. Low Voltage Electric Power Line: Power line carrying low voltage (e.g. 120/240 volts or 347/600 volts) from a distribution transformer to a customer s premise, and throughout the premise. 2.0 Comments regarding the Addition of in-situ testing: As noted in the Preface of the new ICES-006 document, Additional in-situ testing requirements have been added 37. A new Section 4.3 has been added titled: Additional Measurement for AC Wire Carrier Current Devices 38. We re-iterate and copy below a portion of our comment #3 in our September 18, to Industry Canada: In the development of Issue 1 of ICES-006, there was significant work with Industry into setting the output voltage levels which would result in acceptable radiation levels. It was understood (and supported by the Industry) that by requiring only an output voltage test, manufacturers would not require complex and expensive test equipment setup. With the addition of the "in situ testing" for "three typical installations", section 4.3, manufacturers would now have more expensive test setups, and negates the understanding and foundation on which ICES-006 was developed. 39 We note that Section 4.3 is written in the Issue 2 in such a manner as to apply for both broadband (BPL) and other carrier current devices (non-bpl) within ICES It is the coverage of both types of these devices that we have concerns with, and therefore suggest the section be removed or modified. We suggest that the main thrust of the November 2005 Consultation Paper was aimed at BPL devices only (and not non-bpl devices), and that Section 4.3 was intended for those devices only. We also suggest that there is no evidence in the Consultation Paper or elsewhere to support adding new tests for non-bpl devices. 36 We understand there are some discussions about whether the upper limit should be 80 MHz or 50 MHz; for the purposes of this topic, we shall consider 80 MHz and 50 MHz the same and leave discussion to that issue elsewhere 37 ICES-006, Issue 2, Preface 38 ICES-006, Issue 2, Page 3, Section Horizon ed Comments to ICES-006, Sept 18, 2009, Comments #3 40 ICES-006, Issue 2, Page 3, Section 4.3 Ludo Bertsch, Horizon Technologies Ref: 2009.Powerline.ICES006.Comments.004.doc Page 9 of 11

10 In conclusion, we submit that the Issue 2 of ICES-006 had no intentions of changing the regulations or tests for non-bpl devices, and therefore we submit that the applicability of the test needs modification by changing Section 1.2 to: 1.2 Subject to subsections 1.3 and 1.4, sections 3, 4.1, 4.2, 5 to 7 apply to every AC wire carrier current device that is manufactured or imported into Canada, except AC wire carrier current devices manufactured or imported solely for export purposes. In addition, section 4.3 applies to Inpremise BPL systems only. In addition, we submit that the title for Section 4.3 should be: Additional Measurement for In-premise BPL devices We also submit that the first sentence of Section 4.3 should be: In-situ testing is required for testing of carrier current system functions of In-premise BPL devices. As far as the further detailed wording within Section 4.3, we submit that it is premature to further comment on the wording of this section until it is clarified the exact wording for Section 1.2 and what the intention of Section 4.3 really is if no changes are planned for Section 1.2, we submit that Section 4.3 should be completely removed. Ludo Bertsch, Horizon Technologies Ref: 2009.Powerline.ICES006.Comments.004.doc Page 10 of 11

11 APPENDICES Ludo Bertsch, Horizon Technologies Ref: 2009.Powerline.ICES006.Comments.004.doc Page 11 of 11

12 Appendix A British Columbia Frequency Modulation Communications Association c/o Onno Onneken, W.10 th Avenue, Vancouver, BC, V6J2A5 Phone: , fax: ve7onn@telus.net November 21, 2005 Director General, Spectrum Engineering Branch Industry Canada, 300 Slater Street, Ottawa, ON K1A 0C8 Subject: Response to Canada Gazette Notice SMSE dated July 19, 2005 Consultation Paper on Broadband over Power Line (BPL) Communications Systems Dear Sir: GENERAL The BCFMCA wishes 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. The BCFMCA represents over 100 licenced amateur radio operators in the community of Vancouver who are 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. Having reviewed your Paper and other available literature on the subject, we 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. 1

13 Appendix A RESPONSE The following sections follow the numbering in Canada Gazette notice SMSE : 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 (microvolts/metre) Measurement Distance (metres) Access BPL systems operating above 30 MHz will be subject to the following limits: Frequency (MHz) Field strength (microvolts/metre) Measurement Distance (metres) The Department seeks comment on the above limits and their suitability for Access BPL systems in Canada. Please provide technical rationale. 2

14 Appendix B

15 Appendix B

16 Appendix C Jerry Dixon, VE5DC Box 124 Sintaluta, SK S0G 4N0 November 1, Dr. Robert McCaughern Director General Spectrum Engineering Industry Canada, 300 Slater Street, Ottawa, ON K1A 0C8 Subject: (Wolseley Repeater Group) Response to Canada Gazette Notice SMSE dated B 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, we 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. The problem with BPL as has been shown in several test cases in the U.S. is that it generated interference to the amateur radio spectrum. In some cases this interference has been so bad as to make communications impossible. We, the Wolseley Repeater Group 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 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 MHz and 80 MHz over medium-voltage lines or over low-voltage lines to provide

17 Appendix C 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. ` We agree with the above. 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 Inhouse BPL. We agree with the above definition. 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.

18 Appendix D 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 dated 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, I 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. If BPL is allowed to be implement without strict rules on emissions, my ability to perform a service to my community via Amateur Radio will be severely limited. In fact it may even result in no public service being rendered because of BPL interference. 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.

19 Appendix D RESPONSE The following numbered sections follow the numbering in Canada Gazette notice SMSE 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 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 Inhouse 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

20 Appendix D DerekHay, VE4HAY 51 St. Hilaire Place Winnipeg, MB R2J 4B5 October 24, 2005 Dr. Robert McCaughern Director General Spectrum Engineering Industry Canada, 300 Slater Street, Ottawa, ON K1A 0C8 Subject: Derek Hay, VE4HAY Response to Canada Gazette Notice SMSE dated 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, I 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. If BPL is allowed to be implement without strict rules on emissions, my ability to perform a service to my community via Amateur Radio will be severly limited. In fact it may even result in no public service being rendered because of BPL interference. 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 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

21 Appendix D between 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 Inhouse 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 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. Response: An Interference Causing Equipment Standard (ICES) is required. The certification

22 RESPONSE to GAZETTE NOTICE SMSE Appendix D John White, VA7JW 344 Oxford Drive Port Moody, B.C. V3H 1T2 Tel va7jw@shaw.ca 23 November 2005 Director General, Spectrum Engineering Branch Industry Canada, 300 Slater Street, Ottawa, ON K1A 0C8 Subject: Response to Canada Gazette Notice SMSE dated July 19, 2005 Consultation Paper on Broadband over Power Line (BPL) Communications Systems Dear Sir: 1. GENERAL As a concerned Amateur Radio operator, I wish to provide comment on Gazette Notice SMSE as evidence to date indicates BPL will likely have a serious and detrimental effect on not only Amateur Radio operations but for all users of the MF, HF and lower VHF Spectrum. The effect of this action would discourage and disperse qualified technical and operating personnel, and register a serious loss to emergency services throughout the country that depend on Amateur Radio for backup and support in dire times. The impact on manufacturers of HF related equipment is hard to assess but is not inconsequential. I have been licensed since 1959 and became fully qualified as Advanced Amateur in I have been active from then until now. I am a Professional Engineer (P. Eng), now retired after 38 years in the telecommunications industry, always employed by manufacturers of equipment. Twenty of those years were as a designer from the circuit level to the system level. As a product designer, I acquired expertise in matters pertaining to issues raised in the Consultative Paper. All product required compliance to European, American, Canadian and In House requirements for electromagnetic compatibility. EMC was a particular area of expertise having built and operated an anechoic test chamber lab to measure product emissions, apply remedies and perform verifications. I have no doubt that the introduction of BPL in its current implementation will create harmful interference at an unprecedented level to authorized and legitimate uses of the radio spectrum. Further, the existing standards to which these products would be tested are inadequate by a significant margin in terms of interfering levels. 23 November VA7JW

23 RESPONSE to GAZETTE NOTICE SMSE Appendix D 2. RESPONSE Comments are provided in accordance with section numbering in the Consultative Paper. Section Description of Access BPL System The description of Access BPL is acceptable. Section 3.3 Description of In House BPL System The description of In House BPL is acceptable. Section 6 Discussion and Proposals The Amateur Radio Service has an outstanding record of community and emergency service. It also provides a basis for those technically inclined to pursue a career in the art and science of radio communications. Amateur radio also supports a major equipment industry. The success of this service to foster technical and operational expertise is dependent on the ability of licensees to build, operate and conduct communications in an environment conducive to their activities. This requires that the amateur bands be kept free of harmful interference. The Amateur Radio Service depends to a great extent on the ability to communicate on the HF band. This band is employed to communicate locally, regionally and internationally to world wide extent. Correspondingly, signal strengths vary from a few millivolts per meter to much less that 1 microvolt per meter. BPL systems, in their present form, have the capability of interfering with and preventing radio operations. BPL exhibits field strengths much above these levels as demonstrated by the many field tests and technical papers commonly available for review. The amateur community expects that Industry Canada s mandate to protect all users of the spectrum from harmful interference will apply in this case as well as all other cases. Section 6.1 Equipment Standard and Approval Process NEW Technical Standards to control this technology are ABSOLUTELY required. Existing standards, such as ICES-003, Digital Systems and ICES-006, AC Wire Carrier Current Devices, do not address the electromagnetic compatibility issues associated with the current BPL designs. 23 November VA7JW

24 Appendix E Canada Gazette Notice No. SMSE Consultation Paper on Broadband over Power Line (BPL) Communication Systems Published in the Canada Gazette, Part 1 dated 30 July 2005 Bell Wireless Alliance Comments on behalf of Aliant Telecom Inc. Bell Mobility Inc. NMI Mobility Inc. NorthernTel Mobility Saskatchewan Telecommunications and Télébec Mobility 28 November 2005

25 - 2 - Appendix E 5. The BWA notes that the proposed definition is the same as the definition of Access BPL in the FCC's BPL rules. The BWA concurs with this definition. However, similar to the FCC's clarification in its definition for Access BPL, i.e., that it does not include power line carrier systems and In-house BPL systems, the BWA recommends the inclusion of a similar statement clarifying that Access BPL does not include power line carrier systems as currently defined in RSS-Gen (Section 8), and In-house BPL which is expected to be defined in ICES Further, the BWA recommends that the definition of power line carrier system in RSS-Gen would need to be updated to clarify that it is an unintentional radiator and operated within the band khz. In addition, the provision of rules for the operation of power line carrier systems, similar to the FCC rules would need to be investigated. 3.3 In-house BPL 7. At this time, the Department is proposing to adopt the following definition 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. 8. It would be desirable to provide the definition of In-house BPL in the ICES-006 document. 4.2 Deployment Issues 9. Besides the potential interference to various authorized radio services in the 2-80 MHz frequency range as stated, the deployment of Access BPL systems has the potential to create significant interference problems with telecommunications services specifically under the two situations as described below.

26 Appendix E November 28, 2005 Mr. Robert W. McCaughern Director General Spectrum Engineering Branch Industry Canada 300 Slater Street Ottawa, Ontario K1A 0C8 Dear Mr. McCaughern: SUBJECT: CEA Reply to the Industry Canada Consultation Paper on Broadband over Power Line (BPL) Communication Systems 1. The Canadian Electricity Association (CEA) is pleased to provide this submission on the Industry Canada (IC) Consultation Paper on Broadband over Power Line (BPL) Communication Systems. The CEA does support the deployment of BPL communication systems in Canada, when issues identified in this submission are resolved and where appropriate. The CEA submission is from the perspective of the utility electrical infrastructure. 2. In summary, the CEA submits that: There should be no CRTC regulation of BPL systems that are used for internal utility communications; Regulatory uncertainly limits and delays the deployment of BPL in Canada; 1

27 Appendix E Distribution transformers are viewed as part of the medium voltage (MV) power lines rather than the low-voltage power lines. CEA Comments on Section 3.3 on In-House BPL 20. It is recommended to use the term In-Building BPL or On-Site BPL since either of these terms are more comprehensive and appropriate than the proposed term In-House BPL because it would cover both residential and commercial buildings such as hotels, hospitals, apartment buildings, and industrial buildings. In-House BPL taken in the physical sense, would not generally be understood to include an industrial complex. Comments on Section 5 on Current Status of BPL 21. It is recommended that the last sentence be revised in Section 5.1 on International Activities to highlight the recent international trials and partnerships on BPL in China, Switzerland and Australia, which may reflect a greater willingness for international trials. 22. In the second paragraph of Section 5.2 on United States Activities, related to technical and operational requirements for Access BPL, there is no discussion about electrical distribution technical and operational requirements. 10

28 Appendix E November 28, 2005 Dr. Robert McCaughern Director General Spectrum Engineering Branch Industry Canada 300 Slater Street Ottawa, Ontario K1A 0C8 Subject: Response to SMSE ; Consultation Paper on Broadband over Power Line (BPL) Communication Systems Dear Robert McCaughern; We would like thank Industry Canada for the opportunity to respond to the Canada Gazette notice SMSE ; Consultation Paper on Broadband over Power Line (BPL) Communication Systems. Please find below some of the issues: Gazette Notice Timing Issue/Suggestion: There was not enough time given for a response and we ask for more time for consideration of this important topic. Comments: We would like to point out that the Gazette Notice was released in the middle of the summer and comments due November 28. I chair the standards committee of the Continental Automated Buildings Association (CABA) and although the committee is interested in the notice, it is still putting its official position together. CABA is a not-for-profit industry association dealing with integrated systems and automation in homes and buildings. For clarification this response is not CABA s position, but that of Horizon Technologies Inc. Use of the term BPL Issue/Suggestion: Since there are two different types of BPL systems, In-house and Access, we ask that it be very clear what type of BPL system is being discussed throughout SMSE and the various Industry Canada documentation. We suggest that when BPL is used alone, it means both In-house and Access. In- House BPL and Access BPL would then be used corresponding for those systems. Comments: For example, in the background of the Gazette Notice SMSE it states BPL is a new technology that uses the power distribution grid to deliver highspeed Internet services to customers, businesses and industries. One would have to assume that this really means Access BPL. Similiarly, by the title of the gazette notice Consultation Paper on Broadband over Power Line (BPL) Communication Systems one would assume that Access BPL is intended. Ludo Bertsch Horizon Technologies Inc Access BPL Letter to Industry Canada Page 1

29 Appendix E However, this is contradicted within the Consultation Paper itself, chapter 3, General Description of BPL Systems covers both Access BPL and In-House BPL. In addition, it makes it hard to comment properly on the paper, when it is not clear what is being presented even whether or not to comment at all on this Gazette Notice. Definition of Access Broadband over Power Line (Access BPL) section Issue/Suggestion: There may be several issues with the definition, and the wording should be clarified it is suggested that: - all Access BPL systems are actually the medium voltage portion (MV) (remove low voltage (LV); this portion is already covered by ICES-006) - upper frequency limit be 50 MHz, for TV broadcasts, particularly in Canada - clarify that it specifically does not include powerline carrier or In-House systems Comments: How is an Access BPL system that uses only low voltage lines different from In-House systems? Perhaps the best way to define them is that as far as regulations are concerned Access BPL is medium voltage and In-House is low voltage. Medium voltage is kV and low voltage is 120/240 or 347/600 volts. LV only BPL Systems section Issue/Suggestion: In section End-to-End Access BPL there is a reference to LV only BPL systems as Access BPL systems. We suggest that this reference to clarified or removed. Comments: What exactly is a LV (Low Voltage) Access BPL system? if it only goes on the low voltage system, what is the difference to In-House BPL systems. How does the wide area signal get to the LV systems? If there is a distinction between LV only (Access) BPL systems and In-house BPL systems, a drawing may help; in which case, it should clearly show the difference between the two. If it only uses the low voltage, why not use ICES-006? Drawing of In-House BPL section Issue/Suggestion: Figure 1 shows the In-House BPL system covering only the house, and not the wiring to the distribution transformer. It is suggested that the drawing include the wiring to the distribution transformer. Comments: The signals of many In-House BPL systems propagate to the wiring from the house to the distribution transformer and onto the other houses being fed by that distribution transformer, and not including it may imply such systems are Access BPL systems. Ludo Bertsch Horizon Technologies Inc Access BPL Letter to Industry Canada Page 2

30 Appendix E Drawing of Hybrid Access BPL System section Issue/Suggestion: In section a second hybrid was discussed, as I can determine, includes a wide area network wireless system and low voltage powerline system. This is not clear, and should be clarified with its own diagram or removed. Comments: If this system does not use the medium voltage powerline, is it a Access BPL system? How is it different from an In-House BPL system. Is not the concern really about the emissions of the long wires feeding the medium voltage powerline system. Low voltage emissions are already covered by ICES-006. In-house BPL discussion and definition section 3.3 Issue/Suggestion: The discussion and definition considers an In-House BPL as not owned, operated or controlled by an electricity service provider.... The relationship to an electricity service provider is not helpful and should be removed. In the definition statements there are no mentions of broadband (only in the title) it is suggested broadband be referenced within the definition statements. The definition should be very clear in differentiating between In-House and Access BPL other changes may be appropriate. Comments: As discussed in CABA s Oct 6, 2004 submission to the FCC on the same topic, there was an example of controllable hot water heaters being activated by the power utility over an In-House BPL system but according to the definition it would not be allowed and be considered an Access BPL system. New Gazette Notice referencing ICES-006 Issue/Suggestion: In order to ensure proper notice is given to the In-House BPL industry, it is suggested that a new gazette notice be issued to open up discussions or decisions relating to In-house BPL systems and reference be made to ICES-006 in the notice itself. Comments: Reading the Gazette Notice SMSE there is no reference to In- House BPL systems, and therefore it is not clear to the industry that the Consultation Paper deals with In-House BPL systems inside the paper it even requests comments on the definition of In-House BPL systems. As mentioned above, the definition of BPL in the notice relates to Access BPL only, and not all BPL systems. Even if the ICES-006 regulation is not changed itself, any definition of In-House BPL systems within the Access BPL regulations, all should be alerted. In this document are a few of the many items (others - testing, procedures) in SMSE that cause us concern and we encourage further dialogue on the issue. Thank you for considering our comments, Ludo Bertsch, P. Eng President, Engineer Horizon Technologies Inc., Victoria, B.C. (250) abpl@horizontec.com Ludo Bertsch Horizon Technologies Inc Access BPL Letter to Industry Canada Page 3

31 Appendix E Radio Advisory Board of Canada Conseil consultatif canadien de la radio File: 3300-BPL Dr. Robert McCaughern Director General Spectrum Engineering Industry Canada 300 Slater Street Ottawa, ON K1A 0C8 Subject: Radio Advisory Board of Canada Response to Canada Gazette Notice SMSE dated Consultation Paper of Broadband over Power Line (BPL) Communication Systems Dear Dr. McCaughern; Attached is the Radio Advisory Board of Canada s response to Canada Gazette notice SMSE dealing with Broadband over Power Lines (BPL). The Radio Advisory Board of Canada commends the Department for the timely release of this consultation paper. This response was prepared by a broadly representative group with participants from Canada, the USA and Europe. This response was balloted to Board members. Fifteen of 22 members voted: Five Approved; Seven Approved with comment; Two Abstained; and One Disapproved, with comment. Members comments, which form an integral part of the Board s response, are: Radio Advisory Board of Canada Conseil consultatif canadien de la radio 116 Albert Street, Suite 811 Phone: Ottawa, ON r.a.b.c@on.aibn.com K1P 5G3 Fax: Web site:

32 Appendix E Because of noise from BPL transmitters, a guard band for each aeronautical channel or band excluded from BPL will be required. Re. RABC Response para. 6.3 (b) Geographic restriction Physical separation protection criteria between power lines carrying BPL service and aeronautical ground receivers will need to be applied. NTIA and ITU studies for HF and VHF aeronautical receiver protection should be considered. NAV CANADA can provide the particulars of sites that require protection upon request. Radio Amateurs Radio Amateurs of Canada (RAC) was an active participant in the preparation of this response and generally concurs with the content. However, RAC offers the following additional comments, based in part on new information that has come to the attention of RAC. The Annexes to the letter outline the frequency band exclusions and exemptions requested by some participants. They are extensive, and if implemented in their entirety, would really leave little room for BPL in the spectrum below 30 MHz. Clearly this would create problems in the development of standards for BPL equipment and systems and in the management of BPL operations. Since the RABC response was drafted, RAC has learned that advances in BPL Access technology over Low Voltage (LV) power lines have shown that it is possible to reduce interference to radio services below 30 MHz to acceptable levels. In addition, RAC has also learned that some BPL Access systems over Medium Voltage (MV) lines use the frequency band 30 to 50 MHz to minimize interference to radio services in the more heavily used spectrum below 30 MHz. However, significant problems remain with the mitigation of interference from BPL Access distributed over Medium Voltage (MV) power lines. RAC recommends that in formulating the standards for BPL systems, Industry Canada examine and encourage the use of BPL Access over LV lines instead of over MV lines, and in the 30 to 50 MHz frequency band. The demarcation between telecommunication and radiocommunication systems is becoming blurred as technological advances increasingly enable their merger. RAC sees BPL Access as a data and telecommunications technology whose distribution over power lines, while potentially beneficial to some Canadians, has demonstrated severe and continuous interference to radio services, especially the amateur service, in the spectrum 2 to 80 MHz. Although the Department is approaching its development of interferencereducing measures and equipment/system certification standards from the perspective of the Radiocommunication Act, RAC is unclear on the exact Canadian regulatory framework governing BPL deployment and operations and the impact that this framework should have for both Canadian radio spectrum users and BPL Access service providers. BPL Access is competing with other Internet Access service providers. These other providers must provide, at their own cost, the infrastructure for Internet Access by means such as wireless, cable or satellite. These services are non-interfering; that is, they can co-exist with other radio services without any Page 4 of 28

33 Appendix E Response General The RABC appreciates that BPL is a developing data transmission and telecommunications technology that may benefit both the Canadian public and Canadian power utilities. At the same time, BPL developments and trials over the past five years have shown that BPL has marked potential to interfere with radiocommunication services in the LF, MF and HF bands as high as 80 MHz. Interference from BPL systems has been examined in equipment and system trials over the past five years, and remains a controversial subject even though there have been advances in BPL technology and interference mitigation techniques. The electrical power grid provides an existing, but not a purpose-designed, infrastructure for the transmission of data by BPL, and as such can act as an antenna system for BPL radiation. The RABC accepts the definition of BPL systems as unintentional radiators as currently defined in Canadian standards. The RABC notes that they are different in kind from conventional electrical and electronic devices especially in that the radiation is continuous. The RABC trusts that Industry Canada will take appropriately stringent measures to protect radiocommunciation services from harmful interference. Given the nature of radio propagation, particularly at HF frequencies, BPL has the potential to interfere with radiocommunication services in both Canada and other countries. The consideration of standards for BPL systems and interference mitigation techniques must, therefore, take into account both domestic and international radio regulatory requirements. Currently, the ITU-R is studying the potential effects of BPL on radiocommunciation services below 80 MHz and is examining the need for new regulations to protect them. Article S of the Radio Regulations states that: administrations shall take all practicable and necessary steps to ensure that the operation of electrical apparatus or installations of any kind, including power and telecommunication distribution networks, but excluding equipment used for industrial, scientific and medical applications, does not cause harmful interference to a radiocommunication service and, in particular, to a radionavigation or any other safety service operating in accordance with the provisions of these Regulations (in this matter, administrations should be guided by the latest relevant ITU-R Recommendations). In Section 2 of its document, the Department provides a number of reasons why it should authorize BPL systems in Canada. For example, at page 2 it says, Considering the similarities between the U.S. and Canadian power distribution grids BPL manufacturers will view Canada and the U.S. as a common marketplace. The RABC appreciates that equipment manufacturers, especially foreign ones, may view Canada as an extension of the US market. Clearly, a substantial degree of harmonization of technical standards and procedures with the US would be preferred, if Canadian users are to obtain foreignmade equipment at reasonable prices, or if there is any chance that a Canadian supplier might wish to serve the entire North American market. Nevertheless, there may be valid reasons in a variety of areas for Canada to take a somewhat different approach in its implementation of BPL from that of the US. Flexibility to do so should not be compromised by a quick, across-the-board adoption of US operational and equipment standards. Page 6 of 28

34 Appendix E The RABC suggests that the Department needs to be as stringent in providing standards and procedures for BPL as it does in all other areas of spectrum management. BPL cannot be treated any differently than, for example cable television, where leakage of RF noise can be harmful to authorized users operations. Authorized users include those citizens listening to international HF Broadcast and Amateur Radio Operators who, in the most part, live in urban areas and will be most affected by unintentional BPL emissions. 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 MHz and 80 MHz over medium-voltage lines or over lowvoltage 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. The Board concurs with this definition. However, similar to the FCC s clarification in its definition for Access BPL that it does not include power line carrier systems or In-premise BPL, the Board recommends the inclusion of a similar statement clarifying that the Access BPL does not include power line carrier systems as currently defined in RSS-Gen (Section 8), and Inpremise BPL which is to be defined in ICES-006. This clarification could be provided in the scope of the proposed Interference Causing Equipment Standard (ICES) for Access BPL equipment. Further, the Board recommends that the definition of power line carrier system in RSS-Gen would need to be updated to include that it is an unintentional radiator and operated within the band khz. In addition, the provision of new rules for the operation of power line carrier systems would need to be investigated. 3.3 In-house BPL At this time, the Department is proposing to adopt the following definition 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 Inhouse BPL. Page 7 of 28

35 Appendix E The Board considers that the phrase in-premise should be used rather than in-house to ensure clarity premise makes it clear that several different types of buildings may be considered. The Board observes that definitions are still evolving, but the Board remains committed to inpremise for clarity. 4.2 Deployment Issues Besides the potential interference to authorized radio services in the 2-80 MHz frequency range as noted, the deployment of BPL systems could also cause harmful interference to non-radio services and devices, such as, the following: Telephone network including DSL and Very High Bit Rate Digital Subscriber Line services (VDSL); Life-supporting medical equipment in hospitals; and AC Wire Carrier Current Devices installed in premises under ICES-006 could be subject to conducted interference since they could share the same low voltage wires as the Access BPL systems. In addition there is a potential for BPL harmonic and inter-modulation interference to bands below 2 MHz and above 80 MHz see Annex D. 6.0 Discussion and Proposals The following sections invite comment on specific standards and requirements for Access BPL systems. 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 RABC s detailed comments follow. 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 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. 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. Page 8 of 28

36 Appendix E Driving the Development Of Broadband Over Power Line Solutions for Utilities & Their Partners The Telecommunications and Information Technology Association for Utility, Energy And Other Critical Infrastructure Organizations in Canada

37 Appendix E

38 Appendix F VE7NY / VE7APM C/O Alan MacMillan amacmill@shaw.ca November 25, 2005 Director General, Spectrum Engineering Branch Industry Canada, 300 Slater Street, Ottawa, ON K1A 0C8 Subject: Response to Canada Gazette Notice SMSE dated July 19, 2005 Consultation Paper on Broadband over Power Line (BPL) Communications Systems Dear Sir: The Canadian Broadcasting Corporation Employees Amateur Radio Society (CBCEARS) wishes 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. CBCEARS represents 13 licensed amateur radio operators in the Lower Mainland of British Columbia who are 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. Having reviewed your Paper and other available literature on the subject, we 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 MHz to 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 : Access BPL We see a misuse of the word unintentional radiator in paragraph 5. We believe that if you know that it is going to occur then it can t be unintentional. A more appropriate word would be superfluous. 3.3 In House BPL We see a misuse of the word unintentional radiator in paragraph 6 again.