Yes, we might all benefit from a “new agency,” but this is not going to happen,
so we will continue to do the best we can.
To really understand this problem, we need to look at Sec. 15.3 closely. Here
is the definition of “harmful interference.” The emphasis is added.
(m) 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.}
Note that the criteria for protecting a radio navigation services or safety
service is different than for other services.
Note also that the definition talks about degradation to a service, NOT to an
individual communication within that service.
Yes, S7 noise would be harmful interference if it were taking place over an S6
signal, although amateurs are quite capable of digging signals out of the
noise. But S2 noise would be harmful to an S1 signal and there is simply no
way that the FCC is going to deem S2 noise to be harmful interference and,
depending on the person at the FCC asked to make the determination, S7 noise
could be dismissed as being interference, but not harmful interference as
defined in the rules because other operators in the *service* are able to carry
out the desired communication. Even when applied down to the individual
operator, as it usually is, the same “not harmful interference” conclusion can
be reached. ARRL has seen an FCC field agent unable to find noise deem S9 noise
to not be harmful interference because he couldn’t find the noise and the
amateur could still hear some signals. We got that one sorted out, but this is
the risk we run when we start demanding the FCC enforce rules. In this case,
the amateur did an end run around our processes and ended up getting a local
field agent out to do something about the case, when to that agent, the most
expeditious thing to do is whatever could close the case.
We do NOT want the FCC to draw a line in sand, because if it did, the FCC will
draw a line that we don’t like. If anything, the FCC will draw a line that is
based on the median values of man-made noise described in the ITU-R
Recommendation P372.14, and that typically would be S5 to S7 on HF. We are
much better off not drawing that line and allowing the FCC to tailor advisory
letters and degree of response to the degree of interference. Yes, we can get
the FCC to act when a power company creates S9 noise, but if that noise were S3
from a mile away, the FCC is not likely to act past that advisory letter, so in
that case, the ham better find the pole that the utility will never find and
the ham, ARRL and the FCC can usually convince the utility to fix it. The
biggest problems we face wrt interference cases are the utilities and/or
neighbors not knowing how to find noise sources, finding the wrong ones or,
worse, a non-cooperating responsible party.
In many cases, these are neighborhood disputes that have been made worse by the
involved amateurs. Neighbors, most business operators and some utilities do not
understand the complex issues we disagree over on this forum. Hams need to
understand this lack of knowledge and not ride the high horse but walk the high
road. For those “marginal” interference cases, although the FCC may write an
advisory letter, if the neighbor or utility are given reasons not to cooperate,
the problem won’t get fixed and the FCC will possibly not back the ham with a
finding of harmful interference. In almost all cases, if actions can secure
cooperation, cooperation and help from ARRL staff to the utility, neighbor or
ham will be a more effective solution than taking a crap shoot with the FCC.
Ed, W1RFI
Sent from Mail<https://go.microsoft.com/fwlink/?LinkId=550986> for Windows 10
From: Jim McCook<mailto:w6ya@cox.net>
Sent: Wednesday, September 2, 2020 10:54 PM
To: RFI List<mailto:rfi@contesting.com>
Subject: [RFI] RFI - A Losing Battle
There is a lot here that doesn’t make any sense to me.It appears to be a
fantasy that there is a FCC regulation to prevent harmful interference
to licensed radio communication.Interference is interference.S-7 noise
is harmful when the signal interfered with is S-6.If the signal is S-3
and the offending noise is S-4, it is exactly the same situation.All
these special rules for different devices, incidental radiators,
unintentional radiators, intentional radiators, ad nauseam, concern
devices that need NOT cause interference above or below 30 MHz _if
properly designed_.We all know “FCC Compliance” is a joke where lobbying
and politics rule. It appears on a label that may have come from a
roll of labels printed in China and slapped onto electronic garbage that
indeed causes RFI.The switching power supply for my K3 sits inches from
the radio._It creates NO RFI_.
Government (FCC) is supposed to be working FOR US, but what really
happens is that FCC obviously has abandoned Part 15.3 (n) when it comes
to Amateur Radio.Ed and Paul at ARRL make a huge effort to help hams by
picking up the void left by FCC that has placed ridiculous limits
allowing interference to occur unless that interference reaches a
certain arbitrarily determined signal level, never mind that it DOES
cause interference to amateur radio. This responsibility should NOT be
on the shoulders of ARRL. It is a HUGE burden.
A different agency consisting of _engineers and enforcement_ is needed
to replace FCC that can properly deal with amateur radio interference.It
should be funded by our tax money that is being thrown away on many
foolish, wasteful political agencies.Until this happens we will continue
to slowly lose our HF spectrum due to rapidly increasing sources of
devastating RFI.We are rapidly losing this battle.
Jim W6YA
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