Ed,
Keep at it, the ARRL, and you, are helping the RIF issues, even if in
small increments, all changes that reduce RFI are good.
73, and thanks,
Dave (NK7Z)
https://www.nk7z.net
ARRL Volunteer Examiner
ARRL Technical Specialist, RFI
ARRL Asst. Director, NW Division, Technical Resources
On 9/23/20 7:42 AM, Hare, Ed W1RFI wrote:
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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