I don't know why the FCC didn't follow up, but the lack of follow-up was on our
end. A lot was going on at the time. Now that we can test again, I want to
pick up on this, so poor W1VLF is going to have some work to do. 😊
-----Original Message-----
From: RFI <rfi-bounces+w1rfi=arrl.org@contesting.com> On Behalf Of Dave Cole
Sent: Wednesday, September 23, 2020 11:30 AM
To: rfi@contesting.com
Subject: Re: [RFI] RFI - A Losing Battle
Can you expand on why the FCC failed to follow up on Home Depot? Also,
congratulations on Walmart, I had not heard of that one... THANK YOU!
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 7:40 AM, Hare, Ed W1RFI wrote:
> We did have a good case against Home Depot, although for a number of reasons,
> this didn't get followed up. We also had a problem with a Walmart device,
> but they stopped selling it after stockout, as good as I think we could have
> expected voluntarily. I think we need to repeat the Home Depot and Lowe's
> reporting, because this is still an issue. Some devices labeled "industrial"
> actually pass Part 15 B consumer limits, so each suspect device needs to be
> purchased in a way that shows it is being marketed to consumers, tested,
> documented and then reported. Typically, about 15 to 20 staff hours per case
> right now, which means we have to be selective.
>
> 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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>>>
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