ARRL Chief Executive Officer David Sumner, K1ZZ, and General Counsel Chris Imlay, W3KD, made the rounds of the five FCC Commissioners' offices during November to acquaint them with the ARRL's position on the regulation of interference from Broadband over Power Lines (BPL) systems. The meetings were conducted in accordance with the rules governing ex parte communications in pending rulemaking proceedings, in this case the Further Notice of Proposed Rule Making (FNPRM) in ET Docket No. 04-37.

On November 2, Sumner and Imlay met with advisors to Commissioners Robert McDowell, Mignon Clyburn, Meredith Attwell Baker and Michael Copps; on November 24, they met with Priya Aiyar, the Legal Advisor for Wireline Competition and International Issues to Chairman Genachowski. In each instance, they emphasized that while BPL is not currently a major source of radio interference -- owing to its marketplace failure as a consumer broadband delivery medium -- interference does exist and could become a much greater problem if BPL becomes part of the "smart grid" deployment that is intended to improve the efficiency and reliability of electric power distribution and to reduce peak demand.

Sumner and Imlay were able to offer a "win-win" scenario if 35 dB notches to protect the HF amateur bands are mandated, along with a scientifically based extrapolation factor for the measurement of BPL emissions. Such notches are consistent with current industry practice, but there is no way to ensure that future deployments will implement notching unless it is a regulatory requirement.

"We did not expect much feedback from these meetings and were not disappointed in that regard," observed Sumner. "However, in stark contrast to the Commission under its previous two chairmen, no one we met with was 'cheerleading' for BPL as a viable 'third wire' for consumer broadband delivery."