Response to Complaint (Apr 26, 2004)

0050-EX-ML-2003 Text Documents

AMBIENT CORPORATION

2004-04-30ELS_65852

HOLLAND & KNIGHT LLP es Bethesda ues Tallahassee Boston Tampa Bradenton Washington, D.C. Chicago * West Palm Beach 2099 Pennsylvania Avenue, N.W. Fort Lauderdale Suite 100 Jacksonville International Offices: Washington, D.C. 20006—6801 Lakeland Caracas** Los Angeles Helsinki Miami Mexico Ci 202—955—3000 New York Rio de Jantgiro 202—955—5564 Fax Northern Virginia Sao Pauto wwwhklaw.com Orlando Tel Aviv** Portland Tokyo Providence St. Petersburg *Holland & Knight LLC San Antonio **Representative Office « GEORGE Y. WHEELER April 26, 2004 202—457—7045 gwheeler@hklaw.com AECEIVED — FCC APR 2 6 2004 VIA HAND DELIVERY ston Federal Communication Commis Jim Burtle Burgau / Office Chief, Experimental License Branch Office of Engineering and Technology Federal Communications Commission 445 Twelfth Street, S.W. Washington, DC 20554 Dear Mr. Burtle: This is in response to your email dated April 1, 2004 with regard to the complaint of Mr. E. Alan Crosswell dated March 31, 2004. 1. Ambient Corporation (Ambient) is conducting an ongoing test program for broadband over power line (BPL) technologies in Westchester County, New York under FCC experimental license, call sign WD2XEQ granted September 3, 2003. 2. Representatives of Ambient spoke with Mr. Crosswell on April 6 and April 14 to confirm that the company takes his interference concerns seriously and that it has been actively evaluating options to demonstrate and test techniques for operating in compliance with the non—interference requirements of the Part 15 rules. Part of these good faith efforts involves experimenting and testing the capability of notching out. 3. As mentioned in its experimental progress report filed March 4, 2004, the company is in the process of updating its test measurement program to reflect the FCC‘s proposals in its Notice of Proposed rulemaking ("NPRM") [FCC 04—29]

FCC 162 Approved by OMB April 2000 3060—0919 Federal Communications Commission Commission Registration System (CORES) CORES Certification Form I, Judy Norris certify that the FCC Registration Number (FRN) listed below is true and correct to the best of my knowledge, information and belief. FCC Registration Number (FRN) 0 0| 7| 1| 4| 7| 4] 3)| 2 ENTITY NAME A M B| 1| E P| O R A| T| I N # 1098341_v1

Jim Burtle April 26, 2004 Page 2 regarding carrier current systems, including BPL and amendment of Part 15 regarding new requirements and measurement guidelines for access broadband over power line systems in ET Docket No. 03—104/ET Docket No. 04—37, released February 23, 2004. Specifically its updates will be responsive to the FCC‘s proposals that Access BPL systems, including all BPL electronic devices, e.g., couplers, injectors, extractors, repeaters, boosters, concentrators installed on the electric utility overhead or underground medium voltage lines, etc., be measured in— situ to determine compliance with its Part 15 rules and that the measurement guidelines in Appendix C to its NPRM be used. The company is still studying these proposed guidelines and is considering how to introduce them into its test program at an early date. 4. In the interim, as part of its testing and experimental program, the company has and is conducting tests of notching out the 14 MHz amateur radio band (14.00 to 14.35 MHz). Initial results from field tests have shown feasibility of notching as a mitigation technique. However, full implementation of this feature will require upgrade of hardware some of which has been in the field for nearly two years. This upgrade will be completed in the near future. 5. The company intends to conduct test measurements as soon as feasible pursuant to the guidelines in Appendix C of the Commission‘s NPRM. When those results are available, the company will evaluate whether notching out is appropriate and/or whether it has other options to confirm its compliance with the Commission‘s rules and policies. In the event there are any comments or questions concerning this matter, please contact the undersigned. Very truly yours, cc: E. Alan Crosswell # 1854905_v1l


Document Created: 2004-04-30 11:50:13
Document Modified: 2004-04-30 11:50:13
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