Mr. Leonard Downie Jr.

Executive Editor
The Washington Post
1150 15th Street Northwest
, DC 20071


November 16, 2004


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 Manassas, Virginia. Our complaints pertain to a Federal Communications Commission (FCC)-approved technology known as Broadband over Power Line (BPL), where high-speed data connections are provided over utility power lines. This issue involves the FCC, the city of Manassas, the city’s provider of BPL service (Communication Technologies), and the Manassas Journal Messenger/Potomac News newspaper.


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 United States. Similarly, the actions of the Manassas utility, and the FCC’s tacit approval of their efforts, shows a reckless disregard for complaints from anyone who does not share in their vision.


Our complaints regarding BPL technology and its deployment in Manassas can be summarized below:


  1. FCC Policy and Direction. The FCC is knowingly permitting unlicensed radio technology to intentionally interfere with licensed radio services. Any holder of a FCC license (amateur, commercial or otherwise) should be very concerned about the long term implications of this decision. Similarly, a pattern has emerged within the FCC where radio spectrum is treated as a commodity and everything is up for sale. As such, “non-moneyed” interests such as the scientific community, experimenters, and amateur radio are unable to exert the same level of influence in decision making as corporate interests. Ultimately, this has the effect of stifling creativity and technological development in this country.
  2. FCC Conduct. The FCC has engaged in a pattern of ignoring complaints while acting as the proponent of commercial technology deployment, including BPL. The FCC is not carrying out its mandate to serve as a neutral arbitrator and regulatory agency.
  3. Politics. As part of the current administration’s push for expanding broadband service throughout the country, the effects of politics are evident in two key technical reports issued by the National Telecommunications and Information Administration (NTIA), the technical arm of the Department of Commerce. The shift in tone between the NTIA reports strongly suggests that political gain quashed sound engineering judgment. Likewise, the Federal Emergency Management Agency (FEMA) changed its original position regarding BPL interference, suggesting similar political pressure was brought to bear. Benefiting from the FCC’s policies is the city of Manassas. The city manager is now applying political pressure to the local Manassas Journal Messenger/Potomac News newspaper (and to one reporter in particular) to stop reporting about problems with BPL technology and its effect on amateur radio operators.



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.


1. FCC Policy and Direction

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!


2. FCC Conduct

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. Philadelphia, for example, recently announced an initiative to setup a wireless network capable of serving the entire metropolitan area using Wi-Fi technology. Washington State is also considering deployment of a large-scale Wi-Fi network intended to serve rural areas while Lafayette, Louisiana has already deployed a Wi-Fi system.


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 Manassas utility for interference mitigation.


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 Japan specifically because of interference complaints by amateur radio operators. BPL even interferes with U.S. Government broadcasts, such as the National Institute of Standards and Technology (NIST) WWV time and frequency standard transmissions.


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 Manassas, proponents of BPL have repeatedly pointed to the utilities employment of Manassas Utilities Director Allen Todd (who happens to be an amateur radio operator) as a de-facto endorsement of BPL technology. Mr. Todd, however, is an employee for the city of Manassas. As such, he is not an impartial participant in the amateur radio/BPL debate. Quoting an old Murphy’s Law poster, “Where you stand on an issue depends on where you sit!”


To date, the FCC has only paid “lip service” to complaints lodged by amateur radio operators and the ARRL regarding the Manassas system, as well as other locations across the country. In Manassas, the utility company has actually stated that there were “no complaints” received regarding interference, even though amateur radio operators there did file complaints.

3. Politics

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, 06/04/2004). What was deemed unworkable in the first report was later revised to say that BPL was a “win-win” situation. The second report also strongly suggests that President Bush’s national objective of making broadband access available and affordable to every American by 2007 is behind the NTIA’s “revised” recommendations. Similarly, FEMA’s “revised” view on BPL interference smacks of the same political arm twisting. Incredibly, the NTIA report even suggests that, once utility companies made the necessary improvements to power lines to make BPL service realizable, it would end up benefiting both BPL and HF spectrum users!


The city of Manassas, looking for additional sources of revenue and attempting to provide a broadband infrastructure to its citizens, established a relationship with a BPL provider called Prospect Street Broadband LLC in 2003. During the initial setup of the system, the company pulled out of the BPL market, leaving the infrastructure to the city of Manassas. Another BPL provider, Communication Technologies, took over the network’s operation. Since then, the city has been engaged in bringing BPL service to Manassas residents. Given the city’s proximity to Washington, DC, and the intense promotion of BPL technology by Chairman Powell, the city has served as a de-facto test bed in the FCC’s “backyard.” This explains why Chairman Powell recently visited Manassas to witness a demonstration of BPL technology shortly before announcing the amendment to Part 15 regulations.


What is not widely known, however, is that Manassas amateur radio operators were excluded from this demonstration and that word of Chairman Powell’s visit spread just before his scheduled appearance. When asked if OVH representatives could attend the meeting, we were told that it was a “closed” affair. When asked if the OVH could distribute literature or protest outside, we were told that we would need a permit. When asked if the city would issue a permit in time for Chairman Powell’s visit, we were rebuffed. When one member asked what would happen if we just showed up and protested, we were told that we could be threatened with arrest.


Equally disturbing are the actions by the city of Manassas to pressure the Manassas Journal Messenger/Potomac News newspaper to stop reporting about BPL complaints. One reporter, Ms. Sari Krieger, initially reported in 2003 about BPL interference. She presented a balanced report documenting the concerns of the amateur radio community in Manassas while soliciting comments from the city of Manassas, its residents, FEMA, and the head of the ARRL. For her coverage of this story, she received an award from the ARRL. Attempting to report further about amateur radio operator complaints, Chairman Powell’s visit and the full deployment of the BPL system, she was told by the Manassas Journal Messenger/Potomac News to stop working on these stories. The reason given by her employer: she had a “conflict of interest” because her father happens to be an amateur radio operator! For the record, her father is not a member of the OVH.



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 Manassas set a disturbing precedent for any group that dares to challenge decisions made by government institutions.


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 Manassas. We are confident that a simple demonstration will show that this interference is real and that the BPL system installed in Manassas is far less reliable than other competing means of broadband delivery.


Our point of contact for BPL issues is:


Mr. Robert Zaepfel

Amateur Radio Operator K4HJF

9026 Longstreet Drive

Manassas, VA 20110-8830



Ms. Krieger may be contacted at:


Manassas Journal Messenger/Potomac News

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


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John Zorger, Director                                                   Arthur Whittum, Director


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