Part of the problem is that "enforcement" of harmful interference is handled by
the Enforcement Bureau, which we have working somewhat well. The emissions and
marketing violations are enforced by the Office of Engineering and Technology,
which knows of us, holds ARRL in high esteem, but we haven't worked out a
process like we have with EB. I think I can get that to change.
Ed
-----Original Message-----
From: Dave Cole <dave@nk7z.net>
Sent: Wednesday, September 23, 2020 1:06 AM
To: Hare, Ed W1RFI <w1rfi@arrl.org>; rfi@contesting.com
Subject: Re: [RFI] RFI - A Losing Battle
How can I help set this up Ed? I 100% agree... You all handed the FCC an open
and shut case with Home Depot, and as far as I know, nothing ever happened...
That does not bode well for enforcement...
73, and thanks,
Dave (NK7Z)
https://www.nk7z.net
ARRL Volunteer Examiner
ARRL Technical Specialist, RFI
ARRL Asst. Director, NW Division, Technical Resources
On 9/22/20 4:58 PM, Hare, Ed W1RFI wrote:
> Yeah, although we do get the FCC to do some enforcement anyway.
>
> What is needed is a campaign to identify aggregious devices and report
> them to the FCC. ARRL has filed a few complaints about illegal
> devices, but until that turns into a number of cases, it is hard to
> get more than staff-level cases. Just as we got that underway, W1MG
> retired and it took a while to get W1VLF into the role. He hit the
> ground running, but actual cases keep him pretty busy. We did get
> started with testing devices for compliance, even without a fully
> certified lab to to do, although we do duplicate the ANSI C63 test
> methodology the FCC specifies in the rules. It certainly is good
> enough testing to justify a complaint, considering that we give a
> number of dB leeway. I want cases that will pass all muster when we can go
> live with this.
>
> COVID-19 ground that to a halt, as ARRL staff had to work remotely
> only, then had to comply with only 50% occupancy and other requirements.
>
> Still, we are preparing to re-engage this at our earliest opportunity.
> We need to identify devices, though. To file a complaint, we have to
> buy one on the open market, from a US seller, test it, document the
> tests and get a formal complaint filed. W1VT identified over 10,000
> potential emitters on the walmart.com site alone, so there is simply
> no way to test them all. The hard part of this is that the limits are
> too high to please any of us, so device causing S7 noise from the
> house next door may well be in compliance. It can still be harmful
> interference, but if we are talking filing complaints against illegal
> devices, we need, well... actual illegal devices.
>
> We did this with grow lights and found two models, similar, so
> probably the same PC board, 58 dB over the FCC limits. Translation:
> One device was creating as much noise as 650,000 legal devices. (That
> is not a typo -- QST figured it was and changed it to 650! lol!) We
> tested LED bulbs from the big box stores and found them all in
> compliance, although the next batch may or may not be the same.
>
> Ed, W1RFI
>
>
> ----------------------------------------------------------------------
> --
> *From:* RFI <rfi-bounces+w1rfi=arrl.org@contesting.com> on behalf of
> Dave Cole <dave@nk7z.net>
> *Sent:* Tuesday, September 22, 2020 5:00 PM
> *To:* rfi@contesting.com <rfi@contesting.com>
> *Subject:* Re: [RFI] RFI - A Losing Battle Perhaps the FCC will use
> that $50.00 per renewal they are talking about to perform RFI
> enforcement?
>
> Sorry, I had too... :)
>
> 73, and thanks,
> Dave (NK7Z)
> https://www.nk7z.net
>
>
> On 9/22/20 12:39 PM, Hare, Ed W1RFI wrote:
>> 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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