Hi, Dave,
A few amateurs have directly engaged the FCC. If they do so in a professional
and respectful way, this really doesn't cause much harm, although over decades
of time, ARRL staff have managed to have built a relationship with the right
people that, for the most part, do make reasonable decisions. To get there,
though, ARRL did have to agree to undertake a lot of work, to work directly
with the amateur, to ensure that the case really is interference, that the
correct source has been identified and that reasonable efforts have been made
to try to resolve the problem directly by the involved parties.
Unfortunately, by the time cases get to us, whether directly by the ham or
through the FCC, relationships with neighbors and utilities have often been
rather, well, tense and cooperation can sometimes be difficult. The FCC has
helped there quite a bit, but that, too, is a political tightrope, because the
little old lady whose only joy is watching TV on a large-screen TV causing
interference is going to get a lot more sympathy than a ham-radio operator that
no one understands. FCC fears that the little old lady or someone on her behalf
will go to their Congressperson or Senator and add a political layer to the
whole case. Keep it neighborly! We have had hams trespass with test equipment
into backyards when neighbors aren't home, caught on security cameras, which
really and truly made our work with the FCC a lot harder. Yes, the FCC staff
we know understands that not all hams will be appropriate, so they keep the
program going, but that really has to be the exception rather than the rule,
because one word from the Commissioners or Bureau Chief could be disastrous.
When hams directly approach the FCC, they may get to the people in the FCC Call
Center. This results in stock answers, often the same ones that the FCC gives
regular RFI complaints, because only Amateur Radio has an informal agreement
with FCC staff to do more than simply provide information. They may get to
field offices, which we have seen make wildly inaccurate investigations and
decide things like the inability to find the source proves that it is not
harmful interference. We need to get these cases to the people that know our
process, know how to handle things in a way that does resolve a number of
cases, although it can take an extraordinary long time.
The easy ones for us are S9 noise from power companies. The ones from other
businesses are a bit tougher. Interference from neighbors is harder yet, and
the really tough nut to crack is that interference that is very real to the
ham, but below the unspoken threshold that we believe the FCC will deem to be
harmful interference. We, and the FCC staff we work with, try to avoid that
decision, because they can and do send letters that encourage cooperation, even
in cases where is it probable that FCC might decide to just close the case.
As I said, for these marginal cases, it may be needed for the ham to do a lot
of legwork to identify the source. If you have S4 noise that used to be S2 and
the source is a power-line problem a mile away, honestly, the power company
won't be able to find it. They may not have it register on their
instrumentation, designed to find serious problems. They may find a closer
source that doesn't propagate down the line, maybe fix it, and then conclude
that the ham will never be satisfied. If, on the other hand, the ham correctly
locates that pole, they usually will fix it, or respond to the FCC letter we
can ask be sent if they don't respond initially.
This is not the case of ARRL being high and mighty thinking it knows best,
because, after 20 years of fine tuning these processes, finding and keeping the
right FCC staff to work on this, that experience really is going to be more
effective than a ham that may or may not understand all the legal, social and
political issues that make RFI to licensed users more than a technical problem.
Ed Hare, W1RFI
ARRL Lab Manager
________________________________
From: RFI <rfi-bounces+w1rfi=arrl.org@contesting.com> on behalf of David
Eckhardt <davearea51a@gmail.com>
Sent: Tuesday, September 22, 2020 7:14 PM
To: Rfi List <rfi@contesting.com>; rfi-owner@contesting.com
<rfi-owner@contesting.com>; rfi-request@contesting.com
<rfi-request@contesting.com>
Subject: [RFI] A LOSING BATTLE
If I read between the lines and, in summary, the first contact should be
with the ARRL. They (still) have the capability of working on a technical
basis with the amateurs and, most importantly, still have the ear of the
FCC when required. We DO NOT,...N O T.... want to spoil that
relationship!!!
I've been at this (losing) battle as an EMC/RFI engineer professionally for
nearly 40-years. I've seen the changes and experienced the RF Fog caused
by the 'digital revolution'. No war stories here, but you might want to
read the last paragraph of my QRZ page, WØLEV.
FCC has set regulatory limits which should legally be honored. Yes, these
limits *do* precipitate problems for the typical amateur living in the
cities. Problem is, these days, China has shown by example that cheating
gains sales, legal or not (how many labels do you want?). Other upstanding
US suppliers have taken notice and are following suit. Per in-place FCC
rules, these offenders are not being pursued as they should. The burden of
proof falls on us EMC/RFI engineers. There aren't enough of us nor do we
have the clout with the FCC (and cheating lab tests- if any - from China)
that we should. FCC USED to do this function. No longer. All they're
left with is enforcement, which they do not accomplish in a responsible
manner (my editorial comment on the process).
But we amateurs need to recognize there are limits in place that should,
legally, be adhered to. The honor system (self declaration and Customs
inspections) is not working with the incursion of a multitude of electronic
'toys' and SMPS's from China and the precedents set by China (and others)
in ignoring the rules.
Dave - WØLEV
EMC Design & Test, LLC
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