Mr. Leonard Downie Jr.
Dear Mr. Downie:
We, the members of the Ole Virginia Hams (OVH) amateur radio
club, are writing in the hopes that a reporter from the Washington Post would
be willing to listen to the complaints of amateur radio operators in
While many of the issues described in this letter may be
technical in nature, the actions of the FCC call into question their focus,
direction and influence on the future of radio services in the
Our complaints regarding BPL technology and its deployment
Since its inception, amateur radio has been an important proving ground in the development of various facets of science and engineering. One of the reasons cited by the FCC for amateur radio’s existence is the express intent that operators “contribute to the advancement of the radio art.” For many years, amateur radio has acted as a first-step introduction for young people into the world of technology, sparking interests that carry on for the rest of their lives. Amateur radio has also served as an “ambassador,” fostering international goodwill through contacts with amateur radio operators in other countries. This too is cited in the FCC’s basis and purpose for amateur radio.
Amateur radio operators have always been active in providing communications during emergencies and natural disasters. Post 9/11, the role of amateur radio operators has proven to be an invaluable asset to the nation, providing free services that assist our nation’s first responders.
The high frequency (HF) communications spectrum used by amateur radio operators is unique in its ability to provide long and medium range communications without requiring an underlying communications infrastructure (as is the case with cell phones, the internet, etc.) This stand-alone capability is threatened by BPL interference. If you assume a potential “loss” of an amateur radio station at $1000 (for a modest installation), and multiply that by the number of amateur radio operators in the United States licensed to operate in the HF spectrum, you come up with a net loss to the country of hundreds of millions of dollars of “free” emergency communications infrastructure.
The Amateur Radio service is defined under FCC Part 97 regulations. FCC Part 15 regulations apply to individual appliances (computers, cordless phones, etc.). If you look at the labels on most consumer appliances, you will see the following FCC-mandated warning:
“This device complies with Part 15 of the FCC Rules. Operation is subject to the following two conditions: (1) This device may not cause harmful interference, and (2) This device must accept any interference received, including interference that may cause undesired operation.”
Under a recent amendment to Part 15, however, the FCC is now extending the same Part 15 certification for BPL systems to an entire metropolitan area, something that was never the intent of Part 15 regulations. The amended Part 15 wording for BPL also contains a subtle wording change that has the ability to change the focus of blame for interference. Normally, Part 15 equipment must live with whatever interference it receives, meaning that the licensed radio service takes precedent. The new wording, however, indicates that interference complaints must be addressed while not interrupting BPL service. Quoting the FCC’s Report and Order (FCC04-245, paragraph 58) regarding harmful interference to HF communications:
“…BPL system operators to expeditiously resolve any instances of interference that may occur, without the need to cease operations and thereby disrupt the broadband data services they provide to their subscribers.” [Emphasis added]. It is conceivable that licensed radio services could eventually face intense pressure from unlicensed interests once their business operations are impacted by interference. In effect, licensed radio services could become subservient to unlicensed interests!
Of the myriad broadband options offered today, BPL has been promoted as a potential solution to the industry’s “last mile” problem of cost-effectively providing service to individual homes and businesses. In particular, BPL has been touted as a solution to the last mile problem for rural users, where power lines are plentiful and residents are few and far between. Despite the promise of serving rural customers, however, BPL test deployments at present have only focused on urban and suburban settings where a larger customer base is available.
Unfortunately, the bandwidth offered by BPL is too limited
to meet realistic customer growth requirements when compared with the more
common Wi-Fi and Wi-Max wireless standards.
Unlike Wi-Fi and similar systems that were designed to
operate in a multi-user environment with moderate levels of interference, BPL
is not robust and can be interfered with by licensed HF radio transmitters.
This was demonstrated by the OVH recently for News Channel 8 with two mobile
amateur radio stations, even though in one location the area had been
configured by the
Utilities in other locations that have setup demonstration
networks have, in almost every case, shutdown their experiments and abandoned
BPL technology altogether. BPL deployment was suspended in
Interference specifications and measurement techniques for BPL have not yet been fully established. Already, there are technical squabbles between the FCC and The National Association for Amateur Radio (also known as the American Radio Relay League or ARRL) as to how to properly measure interference. Although (according to the NTIA recommendations) BPL providers are supposed to measure system performance and insure compliance with these to-be-defined interference parameters, it is doubtful that they will address these issues in a timely manner since they run counter to their revenue-generating mission. As a proponent of BPL, it is unlikely that the FCC will allocate money to an “interference squad” to look for cases of non-compliance, even though the FCC is responsible for tracking down illegal transmitters and illegal or non-complaint use of the radio spectrum.
While the OVH has attempted to complain about the looming
problem of BPL interference in
To date, the FCC has only paid “lip service” to complaints
lodged by amateur radio operators and the ARRL regarding the
The effects of political pressure are evident by the change
in tone from the first NTIA report on BPL interference (NTIA Report 04-413) to
the second report (BPL Comments,
The city of
What is not widely known, however, is that
Equally disturbing are the actions by the city of
BPL is a significant threat to HF radio communications and
is inferior to traditional broadband services such as cable, DSL, etc. The FCC
has failed to take the concerns of amateur radio operators seriously and, as a
regulatory agency, has acquiesced to political objectives that are unsupported
by sound engineering practices. Lastly, political actions on the part of the
FCC and the city of
To illustrate the gravity of this situation, the OVH would
like to extend an invitation to the Washington Post to witness a demonstration
of BPL interference and susceptibility in
Our point of contact for BPL issues is:
Mr. Robert Zaepfel
Amateur Radio Operator K4HJF
Ms. Krieger may be contacted at:
Phone: (703) 369-6751
We welcome the opportunity to meet with a reporter and to share this story with your readers.
Donald W. Blasdell, Director Charles Dale, Director
John Zorger, Director Arthur Whittum, Director