**APPENDIX A**

RELEVANT PART 15 PROVISIONS

Part 15 provisions regarding field strength limits and compliance
measurements are quoted or paraphrased below. Observations relevant to
the application of these provisions to BPL systems are presented in
footnotes.

# A.1 PROVISIONS REGARDING FIELD STRENGTH LIMITS

§15.15(c) \"*Parties responsible for equipment compliance should note
that the limits specified in this part will not prevent harmful
interference under all circumstances.*\"

§15.109(a) \"\...*the field strength of radiated emission from
unintentional radiators at a distance of 3 meters shall not exceed the
following values\...*\" [^1]

§15.109(e) \"*Carrier current systems used as unintentional
radiators\...shall comply with the radiated emission limits for
intentional radiators provided in* §15.209 for the frequency range 9 kHz
to 30 MHz.\"

§15.109(g) \"*As an alternative to the radiated emission limits shown in
paragraphs (a) and (b) of this section, digital devices may be shown to
comply with the standards contained in the Third Edition of
International Electrotechnical Commission (\"IEC\"), International
Special Committee on Radio Interference (\"CISPR\") Pub. 22
(1997)\...\"*

§15.113(b) \"*The operating parameters of a power line carrier system
(particularly the frequency) shall be selected to achieve the highest
practical degree of compatibility with authorized or licensed users of
the radio spectrum*.\" [^2]

§15.113(c) \"*Power line carrier system apparatus shall be operated with
the minimum power possible to accomplish the desired purpose.*\"

§15.205(a) \"*\...only spurious emissions are permitted in any of the
frequency bands listed below:..*\" [^3]

§15.209(a) *\"\...emissions\...shall not exceed* *the field strength
levels specified in the following table*\...\" [^4]

# A.2 PROVISIONS SPECIFYING COMPLIANCE MEASUREMENTS

§15.31(a) \"*The following measurement procedures are used by the
Commission to determine compliance with the technical requirements of
this part.*\"

§15.31(a)(6) Digital devices are to be measured using procedures
specified in American National Standards Institute (ANSI) C63.4-1992 to
determine compliance with the technical requirements of Part 15.

§15.31(b) \"*All parties making compliance measurements on equipment
subject to the requirements of this part are urged to use these
procedures.*\"

§15.31(d) Measurements are to be made at a calibrated test site to the
extent possible. CCS are cited as a case where measurements can be made
only at an installation site. Measurements \"\...*shall be performed at
a minimum of three installations that can be demonstrated to be
representative of typical installation sites.*\" [^5]

§15.31(f) \"*To the extent practical, the device under test shall be
measured at the distance specified in the appropriate rule section.*\"
The measurement distance is applied horizontally with respect to a
boundary around the device and any interconnection cables.[^6]

§15.31(f)(1) \"*At frequencies at or above 30 MHz,*\...*measurements are
not made in the near field except where it can be shown that near field
measurements are appropriate due to the characteristics of the device;
and it can be demonstrated that the signal levels needed to be measured
at the distance employed can be detected by the measurement
equipment*.\"[^7] \"*When performing measurements at a distance other
than that specified, the results shall be extrapolated to the specified
distance using an extrapolation factor of* \...\" [^8]

§15.31(f)(2) \"*At frequencies below 30 MHz,* *measurements may be
performed at a distance closer than that specified in the regulations;
however, an attempt should be made to avoid making measurements in the
near field.*\" \"\...*when performing measurements at a closer distance
than specified, the results shall be extrapolated to the specified
distance\...*.\"

§15.31(f)(4) \"*When measurements of 30 meters or less are specified in
the regulations, the Commission will test the equipment at the distance
specified unless measurement at that distance results in measurements
being performed in the near field*.\"

§15.31(f)(5) \"*The maximum field strength at the frequency being
measured shall be reported in an application for certification*.\" [^9]

§15.31(g) \"*Equipment under test shall be adjusted, using those
controls that are readily accessible to or are intended to be accessible
to the consumer, in such a manner as to maximize the level of emissions.
For those devices to which wire leads may be attached by the consumer,
tests shall be performed with wire leads attached. The wire leads shall
be of the length to be used with the equipment if that length is known.
Otherwise, wire leads one meter in length shall be attached to the
equipment.*\" [^10]

§15.31(h) \"*For a composite system that incorporates devices contained
either in a single enclosure or in separate enclosures connected by a
wire or cable, testing for compliance with the standards in this part
shall be performed with all of the devices in the system functioning.*\"
[^11]

§15.31(i): \"*The emission tests shall be performed with the device and
accessories configured in a manner that tends to produce maximized
emissions within the range of variations that can be expected under
normal operating conditions.*\"

§15.31(j): \"*If the equipment under test consists of a central control
unit and external or internal accessory(ies) (peripheral) and the party
\...applying for a grant of equipment authorization manufactures or
assembles the central control unit and at least one of the accessory
devices that can be used with the control unit, testing of the control
unit and/or the accessory(ies) must be performed using the devices
manufactured or assembled by that party, in addition to any other needed
devices which the party does not manufacture or assemble.*\"

§15.31(k): \"*If the individual devices in a composite system are
subject to different technical standards, each such device must comply
with its specific standards. In no event may the measured emissions of
the composite system exceed the highest level permitted for an
individual component*.\"

§15.33(b)(1) \"\...*the spectrum shall be investigated from the lowest
radio frequency signal generated or used in the device, without going
below the lowest frequency for which a radiated emission limit is
specified, up to the frequency shown in the following table*\...\"

§15.35(a): The limits are based on measurement using a CISPR quasi-peak
detector and related bandwidths. [^12]

[^1]: NTIA recommends a uniform ten (10) meter measurement distance.
    *See* Section 7.5.

[^2]: In Section 7, NTIA has identified potential means for enhancing
    compatibility of BPL systems with radio systems.

[^3]: NTIA recommends consideration of excluding BPL use of certain
    narrow frequency bands, but further study is needed to determine
    whether these exclusions can be specified on a geographical basis.
    Generally, BPL systems should not operate in certain frequency bands
    in order to protect distress, alarm, urgency or safety
    communications in accordance with ITU Radio Regulations (*see* RR
    No. 4.22).

[^4]: NTIA recommends a uniform ten (10) meter measurement distance.
    *See* Section 7.5.

[^5]: *See* Section 7.9.

[^6]: None of the three proprietary access-BPL measurement reports
    reviewed by NTIA applied §15.31(f). Instead, these measurements were
    performed on radials at distances measured from the \"telephone\"
    pole on which the BPL device was mounted.

[^7]: NTIA\'s Phase 1 Study indicates that BPL emissions must be
    measured in the near-field because of its large expanse.

[^8]: NTIA\'s Phase 1 Study shows that BPL radiation characteristics may
    not be consistent with the extrapolation factors specified in
    §15.31(f). Further study is needed.

[^9]: Regardless of whether certification ultimately is required for BPL
    authorizations, under NTIA\'s recommended measurement provisions
    (Section 7) the maximum field strength at a given measurement
    frequency is determined from measurements made while operating the
    BPL system at each frequency at which it is capable of operating.

[^10]: The \"consumer\" for outdoor BPL devices normally will be the BPL
    system operator, whereas the consumer for indoor BPL devices
    normally will be the BPL subscriber. The length of outdoor \"wire
    leads\" used with access and in-house BPL devices vary substantially
    among the potential BPL installation sites and, as recommended by
    NTIA (Section 7.9), the representative power lines selected for BPL
    testing should encompass various features that significantly affect
    peak field strength levels. In no case can a one-meter or other
    short length of power line be used for BPL compliance measurements
    because standing waves associated with peak field strength will not
    be manifest.

[^11]: NTIA interprets §§15.31(h), (i), (j) and (k) to mean that at any
    frequency, during measurement and operational use, a network of BPL
    devices may not generate an aggregate field strength that exceeds
    the field strength limit for BPL systems. See Section 7.3.

[^12]: *See* Publication 16 of the International Special Committee on
    Radio Interference (CISPR) of the International Electrotechnical
    Commission. Measurement bandwidths of 9 kHz and 120 kHz are to be
    used with a quasi-peak detector at frequencies below and above 30
    MHz, respectively.