Actually, Jim, the language in the rules is critically different:
§ 15.5 General conditions of
operation.<https://www.ecfr.gov/current/title-47/section-15.5>
(b) Operation of an intentional, unintentional, or incidental radiator is
subject to the conditions that no harmful interference is caused and that
interference must be accepted that may be caused by the operation of an
authorized radio station, by another intentional or unintentional radiator, by
industrial, scientific and medical (ISM) equipment, or by an incidental
radiator.
(c) The operator of a radio frequency device shall be required to cease
operating the device upon notification by a Commission representative that the
device is causing harmful interference. Operation shall not resume until the
condition causing the harmful interference has been corrected.
So, until the Commission determines that "harmful interference" is occurring,
the operator does not have to stop using it.
I have had long talks with the Commission staff about "harmful interference,"
and they have been crystal clear that not all interference is going to deemed
to be actionable. The median values of man-made noise are typically S6 down to
about S2 on HF, depending on frequency, so that moderate level of noise exists
in lots of places. Yes, a ham's location may have once been quiet, but noise
comes; noise goes, and if the noise ls below that median value, the Commission
has all but told me that it would not consider it actionable, and, as this post
started, it would indeed say, "live with it. Hams across the country do."
Look also at the Part 15 definition of harmful interference:
Harmful interference. Any emission, radiation or induction that endangers the
functioning of a radio navigation service or of other safety services or
seriously degrades, obstructs or repeatedly interrupts a radiocommunications
service operating in accordance with this chapter.
This says nothing about interference to an individual licensee, but it
describes interference that endangers the operating of a service. I know from
the BPL days that is the lawyers get involved, they will take the position that
an individual case of RFI is not degrading the entire service, with lots of
legal arguments.
The bottom line is that we don't want to force this issue, because it is a
lose/lose for everyone. I have avoided at all costs forcing the FCC to make a
decision about harmful interference, because I know we will not like that
decision. To keep them engaged, ARRL is working with these manufacturers, to
get them to do more than the rules require, because they do not want new rules.
We don't either, because then, the first line of defense by manufacturers will
be that they meet the rules.
The vast majority of cases have been resolved. The manufacturers would like
the FCC to get them off the hook on the remainder of cases, but I have
persuaded the FCC not to make that determination yet, but to work to try to
find better solutions for the remaining cases that seem to require more
supression that has been successful for most cases. I am about to put a few
panels on my roof and see what solutions can be designed.
So, be careful what you ask for, because you might get it. The industry doesn't
want more rules, but neither do we,, because any levels will be set so high
that we will not like them. The only radiated emissions limits that apply
below 30 MHz are for carrier-current devices and intentional emitters, and
those limits are a defacto S9.
Keep the cooperation going; it will bet us more than rules and force will ever
get us, unless you want to see this all resolved by the lawyers.
Ed Hare, W1RFI
________________________________
From: RFI <rfi-bounces+w1rfi=arrl.org@contesting.com> on behalf of Jim Brown
<jim@audiosystemsgroup.com>
Sent: Wednesday, May 25, 2022 2:26 PM
To: rfi@contesting.com <rfi@contesting.com>
Subject: Re: [RFI] Solar Panel RFI Awareness At Dayton
On 5/25/2022 1:38 AM, Dave (NK7Z) wrote:
> Respectfully I am saying that at some point there is a level at which
> the FCC will say too bad, live with it. That level will be above what
> things were before the solar installation arrived.
FCC Rules say that if a product interferes with licensed radio operation
that use of it must be discontinued.
73, Jim K9YC
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