BPL Regulations for Access Networks

1. BPL Regulations for Access Networks CURRENT’s Experience

2. US FCC Investigations Into BPL • During 2003-2006, the United States Federal Communications Commission conducted an extensive investigation into Broadband Over Power Line (BPL) • Involved over 5000 submitted comments from interested parties, technical field investigations and testing. • Concluded with an endorsement of the potential of BPL systems for both broadband access delivery as well as improving electric utility operations.

3. General Findings • FCC concludes that BPL “offers the potential to give rise to a major new medium for broadband service delivery” • Residential, institutional, commercial users • Rural, underserved and competitively served areas • Promote U.S. leadership in broadband technology • FCC noted that many utilities are looking to BPL to enable a variety of “more sophisticated power distribution applications” • SmartGrid Applications include automated outage/restoration detection, remote monitoring and operation of network distribution equipment, remote connect/disconnect, demand-side management programs and power quality monitoring to detect faulty components before they fail. • “Access BPL systems will be able to operate successfully on an unlicensed, non-harmful interference basis”

4. FCC General Findings (continued) • “Harmful interference potential from Access BPL systems operating in compliance with the existing Part 15 emission limits for carrier current systems is low in connection with the additional rules” • “Potential for any harmful interference is limited to areas within a short distance of the power lines” and the potential “decays rapidly” with distance from the line • No evidence that BPL will raise the background noise level (“noise floor”) • No evidence that Access BPL will cause the power lines to act as miles-long antennae radiating RF energy along their full length • “Properly designed and operated” systems pose “little interference hazard” • The FCC reaffirmed that existing Part 15 limits for BPL systems should apply and will pose little interference risk. • Also maintained in-situ testing for compliance due to lack of evidence showing correlation from lab measurements to actual field levels

5. FCC Reaffirmed Part 15 Emissions Limits • Class A radiated emissions rules apply on MV wires • MV wires carry between 1,000 and 40,000 volts from a substation and may be overhead or underground • Class B radiated emissions rules apply on LV wires • LV wires carry “low voltage, e.g., 240/120 volts” from a distribution transformer to a customer premise • Class A provides for ~10 db more power then Class B • Distinction applies only above 30 MHz • FCC rejected requests for • emissions increases for rural areas (Main.net) • emissions increases of 10 db above Class A (Satius) • emissions decreases from amateurs applicable to ham bands • FCC will revisit emissions levels if “information develops that raising the limits might be possible without incurring unacceptable risk of interference” • No conducted emissions limits (including AM radio bands)

6. The FCC Rules Have Been Proven Right! • BPL has continued deployment in North America • CURRENT’s deployment experience shows that BPL can be deployed without interference • CURRENT has the two largest BPL deployments in North America • 55,000 homes in Cincinnati, Ohio (operational since 2004) • >60,000 homes in Dallas, Texas (operational since 2006) • Zero interference complaints of any kind • Even the National Association for Amateur Radio has stated that BPL done as CURRENT does it poses little interference risk. • CURRENT has shown that BPL can be deployed at the FCC limits without interference!