The marketers group urged the New York PSC to base its examination of BPL on that basic assumption.

          The PSC is exploring the setting of BPL rules (RT, 1/20), but has already decided the service should be competitive and that regulated utilities shouldn't get into the business except to rent access to "unaffiliated BPL providers."

          Today's BPL technology "represents the convergence opportunity that was once envisioned but never realized," NEMA noted.

          It could be a "windfall" for putting already built and paid-for power networks to another use -- providing a "large enough digital pipe into virtually every home," NEMA noted.

          Other benefits include:

          •  Lowering utilities' cost of capital in building reliability upgrades by boosting asset valuations, and

          •  Improving power line surveillance, grid reliability, blackout prevention, isolation and migration as well as homeland security.

          It's vital, NEMA argued, that utilities provide non-discriminatory open access at just and reasonable rates.

          The PSC already is leaning that way, NEMA noted, but needs to adopt an affiliate code of conduct that governs how utilities do business with BPL providers.

          The code should:

          •  Bar utility subsidies of non-regulated activities;

          •  Prohibit tying regulated utility services to products or services provided by affiliated or non-affiliated BPL providers;

          •  Require that the same tariff and rate provisions apply to all, and

          •  Separate utility operating employees from those working for unregulated affiliates.

          The PSC should consider who gets the potentially substantial dividend to utilities for operating as BPL carriers, NEMA urged.

          Utilities should spend this money on BPL-related infrastructure that boosts reliability, security, power quality and more accurate, cost-effective metering.

          The technology, NEMA noted, uses very little power and takes up an "infinitesimal" amount of space on a power line.

          The PSC shouldn't bother to require utilities to compute the embedded or marginal costs that could be only a fraction of a penny.