Response from Mr. Julius Knapp (Aug 27, 2008)

0132-EX-RR-2007 Text Documents

AMBIENT CORPORATION

2009-01-14ELS_95652

Federal Communications Commissio~l Washington, D.C. 20554 August 27,2008 Christopher D. lmlay 14356 Cape May Road Silver Spring, MD 20904 Dear Mr. Ilniay This is iqresponse to your informal objection, on behalf of the National Association for Amateur Radio (ARRL) dated July 25,2007, to Ambient Corporation's (Ambient) pending renewal application (file no.: 01 32-EX-RR-2007) for experimental authorization for continued Broadband over Power Line (BPL) trials in BriarcliffManor, New York. You state several reasons why ARRL believes the Commission should deny this renewal application. You assert that the experimental authorization should not be renewed due to unresolved complaints of interference from Ambient's BPL operations. On this matter, we observe that the Commission's Enforcement Bureau recently concluded its investigation of Ambient Corporation's BPL operation in Briarcliff Manor, New York regarding whether it caused harmful interference to Amateur Radio stations. The Enforcement Bureau found that Ambient did violate the radiated emission limits of the Commission's rules, but that it has now replaced all of its first generation equipment with second generation equipment and that its measurement tests show compliance with the Commission's rules. (Id.) In addition, since the replacement of the older equipment, no interference complaints have been received by cither Ambient or the Commission. Based on the finding of interference and the remedy implemented by Ambient, the Enforcement Bureau issued a sanction. (Letter from Enforcement Bureau, FCC, to Dr. Yehuda Ccrn, Ambient Corporation, dated November 13,2007.) Accordingly, we consider this matter to be closed. You also state that since its initial grant of experimental authority to Ambient, the Commission h a adopted regulations for BPL operations, and you assert that Ambient has not provided sufficient justification to warrant the continuation of experimental operation rather than operation under the rules. You further contend that Ambient's renewal application should be denied because Section 5.71(b) of the Commission's rules (47 C.F.R. 5 5.71(b)) specifies that an experimental license should not be granted for a period longer than that required to complete the experiment. In this regard, we note that experimental licenses are frequently used to develop new or improved versions of previously approved equipment, and as stated above, Ambient continues to experiment with aspects of their system. In a letter of August 6, 2007 and progress reports of February, 2008 and August, 2008, Ambient provides information regarding its continued experimentation with aspects of its system and equipment to enhance its operation and capabilities and, states that it continues to make hardware and software changes to its equipment, as it develops a new generation of products to enhance its BPL systems with additional applications such as current and voltage sensing, which comply with the Commission's rules. Ambient states that it has implemented Class I and Class I1 permissible changes to its equipment based on testing under this Briarcliff Manor experimental authorization. Thus, Ambient's operations clearly fall within the scope of service for the Experimcntal Radio Service.

You also object that the rules do not require Ambient's experimental operation to be listed in the BPL database. You express concern that this allows Ambient to hide their operations from the publicand makes it difficult to resolve interference. We point out that although BPL operations performed under experimental licenses are not listed in the BPLdatabase, they are publicly available on the Commission's web site through the E x ~ r i m e n t a Licensing l System (ELS). In fact, the public can obtain more information through the ELS than is listed in the BPLdatabase as the ELS contains records for all applications, communication and reports associated with the experimental license. Finally, you question the grant of a nationwide license to Ambient. We acknowledge that such authority is not routinely granted. The scope of their ongoing tests described by Ambient includes developing, tesring, and demonstrating in different geographical areas as well as on different utility system topologies. Additionally, Ambient conlinues lo field requests for testing from power co~npaniesaround the country. By providing nationwide authority, Ambient can perform this development and tests without the need to apply for individual licenses in each instance. However, to ensure that the public has access to infi~mationregarding the location of their various tests, we required as a condition of the license that Ambient notify the Commission within 14 days of operations in a new city to include a cumulative list of all active testing locations, and notification of when testing has been completed in a given city, which ensures that the Commission and the public is fully apprised of their operations. bl light o l t h e foregoing, we are granting Ambient's request for renewal of experimental license, call sign WD2XEQ. Sincerely, C-/ Office of Engineering and Technology cc. George Y. Wheeler, Esq


Document Created: 2009-01-14 08:21:22
Document Modified: 2009-01-14 08:21:22
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