STA Request Narrative Statement

0078-EX-ST-2007 Text Documents

CENTERPOINT ENERGY INC

2007-02-05ELS_79538

                                                                       CenterPoint Energy, Inc.
                                                                            BPL STA Request
                                                                                    Page 1 of 2


                    STA REQUEST – NARRATIVE STATEMENT


         CenterPoint Energy, Inc. (“CenterPoint”) hereby requests special temporary authority
(“STA”) to test, evaluate and demonstrate its broadband over power line (“BPL”) equipment (the
“Equipment”) in the Houston, Texas area. The information below is provided pursuant to Part 15
of the rules of the Federal Communications Commission.


       I.      Need for Expedited STA

               CenterPoint respectfully requests expedited review of the STA request so that it
               immediately may commence test of the BPL Equipment at the sites specified
               herein. CenterPoint needs to construct and operate a BPL trial network in order
               to fully test and evaluate the viability of the Equipment. These tests will be used,
               in part, to further develop utility applications to be used for CenterPoint Energy
               internal requirements.

               CenterPoint Energy provides electric transmission and distribution service in the
               Houston metropolitan area and provides gas service in Arkansas, Louisiana,
               Minnesota, Mississippi, Oklahoma and Texas to combined total of 5 million
               customers. CenterPoint plans to deploy BPL to pass 45,000 electric customers
               and to 20,000 gas customers. The BPL systems will be used to test utility
               applications, such as automated meter reading services as well as other utility
               power applications. CenterPoint Energy will also be testing the scalability of
               BPL technology, which will determine the extent to which CenterPoint deploys
               BPL further.

       II.     Overview of Proposed Operation

               Through these tests, CenterPoint will test multiple aspects of the Equipment,
               including its performance, capacity, signal quality, data rates, interference
               potential and user acceptability.

       III.    Details of Proposed Operation

               Details regarding the technical parameters of the proposed operation are provided
               below:

               Time Period

                       Six months: February 15, 2007 – August 15, 2007


                 Location(s)/ Geographic Area

                          Houston, TX (Harris County), location of equipment is at the corner of
                          1111 Louisiana with a radius of 100 kilometers. The zip code of
                          operation is 77002

                 Equipment

                          The Equipment will include 200 overhead node equipment devices.

                          Manufacturer: Corinex
                          Model #: CXP-MVA-GNR-AB
                          FCC Type Acceptance: FCC testing to begin 2007
                          Emission Designator: OFDM with 1536 carriers

                 Frequency Range

                          2 MHz to 34 MHz

                 Maximum ERP or EIRP, if applicable

                          Tests will comply with Part 15 emissions limits

        IV.      Certifications

                 CenterPoint certifies as follows regarding the proposed operations:

                 (i)      It will not market, sell or lease equipment to end users;
                 (ii)     It will not charge fees for use of equipment;
                 (iii)    At the conclusion of the testing period, it will recall and recover all
                          devices that do not comply with FCC regulations;
                 (iv)     It understands that operation of unapproved devices must not cause
                          interference and will takes steps to resolve any interference,
                          including discontinuance of operation;

         Granting the STA request would serve the public interest in BPL deployment, and is
consistent with Section 7 of the Communications Act1 by encouraging the development of new
technologies and services to the public. These tests would also promote the public interest in
energy efficiency and reliability.2 CenterPoint Energy has committed significant resources
towards these tests, and delaying testing would impose enormous costs that would cause undue
harm. For all these reasons, CenterPoint Energy respectfully requests that the Commission grant
special temporary authority in order to test BPL equipment.




1
  47 U.S.C.§157.
2
  See e.g. Energy Policy Act of 2006 (requiring utilities to implement advanced metering and meet service
reliability standards).



Document Created: 2007-02-05 18:18:11
Document Modified: 2007-02-05 18:18:11

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