Short rebuttal to long essay: the current rules aren't good enough.
On 2024-07-26 09:06, Hare, Ed, W1RFI via RFI wrote:
First, with respect to noisy devices, there are FCC rules related to the amount of noise
devices can make. The manufacturers of devices must meet these requirements and must use
"good engineering practice" (for whatever that means.) There are also rules
that state that if harmful interference occurs to licensed radio services (amateur, CB,
broadcast, business, etc.) then the operator of the offending device needs to address the
interference.
These rules are not intended to prevent all interference, no more so than the
amateur rules on harmonics emissions are intended to prevent all interference
to neighboring equipment. To achieve that goal would require many tens of dB
more suppression, adding considerably to the costs of equipment (amateur gear
and consumer equipment.) The rules are intended to reduce the likelihood of
interference to a small-enough incidence of occurrence that it is practical to
deal with interference on a case-by-case basis. (Amateurs that caused
interference to nearby over-the-air TV receivers, for example, had to add
additional filtering to their transmitters, even though they met the
emissions-limits rules.) The limits also ensure that if there is interference,
it is local and thus easy to identify, rather than possibly coming from over a
mile away.
It would be wonderful for the rules to be changed, but that would be nearly impossible at
worst, and take years of time (as do most FCC proceedings) at best. The inadequacy of
the rules is most apparent in a few glaring areas. First, many devices are categorically
exempt from specific emissions limits. Conventional electric motors, for example. More
important to amateurs, devices classified as "appliances" are exempt from
emissions limits. This would include devices used for cooking, heating, cooling and
cleaning.
Also, interference is controlled below 30 MHz by setting limits on the amount
of noise conducted onto the AC mains. (The premise is that small devices are
not good HF antennas, but wires connected to them are, and the AC mains are
long wire antennas that can and do radiate. There are no radiated emissions
limits below 30 MHz and no limits on the amount of noise that can be conducted
onto other wiring, such as speaker leads, interconnection wires, etc. This
worked, sorta', for most devices, but now that we are seeing more and more
digital wiring in houses and solar systems that have lots of wires that are not
AC mains, we are seeing the inadequacy of these rules.
The ARRL Lab has done a lot of testing of devices and, based on its testing,
most of the devices that it has tested have complied with the rules. (For
reasons described above, interference still does occur.) There have been
exceptions. When indoor gardening became more popular, some high-powered
lighting was found to cause interference. The Lab obtained a number of grow
lights and tested them. Some were found to be as much as 58 dB over the
emissions limits. (To put that into lay terms, one device was making as much
noise as 650,000 legal devices.) The Lab reported this to the FCC and
simultaneously contacted the major importer. The importer ended up
discontinuing the worst of the models and started adding filtering to its
product line. This was not an ideal solution, but most of the interference
problems did get resolved.
The Lab have also worked out a semi-formal process with FCC to get interference
to amateurs resolved. Although this has not been 100% successful, I would
estimate the success rate at over 90%, albeit in some cases taking years to
resolve. In this program, the FCC refers all cases it receives to the ARRL
Lab. The Lab takes some important steps. It first determines that the problem
would meet the FCC criteria for harmful interference. Interference that is
very sporadic would probably not be acted on by the FCC, and a ham that goes
from S1 to S2 noise is still well below the median values of human-made noise,
so FCC is not going to see a rules violation. The Lab has worked successfully
a few cases that do fall into both categories, although FCC action is not
likely. (The position the Lab takes is that if a single source of interference
can be reasonably corrected, it is reasonable to expect it will be. FCC has
followed up on a few of those cases with some letters encouraging the parties
to fix interference).
The Lab also ensures that the correct source has been identified, following
step-by-step procedures to ensure that a noisy device in the hams' own homes
are not blamed on power-line noise, for example. The Lab has found that almost
half of the reported cases turn out to be something different than the ham
first thought. ARRL also determines that the involved parties have tried to
resolve this directly. In some cases, they do. So the ham must talk to the
involved neighbor, or to his or her power company or other identified utility.
The result of the latter is sometimes effective, sometimes not. If not. ARRL
contacts the involved parties, with a letter written under the wing of ARRL's
staff-level agreements with the FCC. The letter explains the rules and what
needs to be done to correct the problem. This is sometimes effective. If not,
the Lab now has a well-documented case to turn over to the FCC. The FCC
Enforcement Bureau evaluates the case and when it almost always agrees with
ARRL's determination, it follows up with letters to the involved parties. So
although this process is not 100% perfect, the League and FCC are both doing
quite a bit to try to move RFI cases forward and resolving quite a number of
them.
The Lab is just now in the process of developing a similar process to be able
to more systematically report noisy devices that appear to exceed the limits to
the FCC Office of Engineering and Technology.
In conjunction with this process, the Lab also maintains significant contact
with industry. The recent case involving solar interference discussed
extensively on this reflector is a good example. In this case, Solar Edge did
make significant improvements to its product, resolving over 500 cases of
interference known to date, this system continued to make noise. Tesla was also
involved, with the battery chargers. At first, Tesla did not get involved, but,
as a result of communications from ARRL, Solar Edge and FCC, it ultimately sent
an EMC engineer to look at the system and an effective solution was put into
place.
As an aside to this, the League is also implementing local RFI teams of
volunteers, and supporting teams that have sprung up spontaneously. This is
being built into a national program and the Lab may ultimately recommend that
this become an official ARRL function.
No, it doesn't stop there. The League is also involved heavily with industry.
It serves as a voting member on the US C63 EMC Committee that writes industry
standards often incorporated into the FCC rules by reference. Lab staff are
also involved heavily with the IEEE EMC Society, serving as a member of its
standards board, overseeing the development of industry standards on EMC.
These are not seats at the back of the room. In my time serving in that role,
I was elected to the EMC Society Board of Directors and then elected by that
Board to be its Vice President for Standards. On C63, I served as the Chair of
Subcommittee 5 on Immunity. This work has been effective, because for a
number of years, interference by amateur radio to other equipment has become
more and more rare.
The League also funded a consultant to help the IEEE write a standard on the
procedures electric utilities should use to resolve power-line noise. This
standard is the first of its kind and can serve as a model for similar
standards involving solar-system noise, for example. Std. 1897-2024 is now
available from the IEEE and my guess is that it will be widely adopted and
used, especially if FCC letters to utilities point to it.
So, the question was asked: When will we see the ARRL doing something to
address noise. This has all been happening for over a decade, much of it
reported in bits and pieces. So, yes, the question is correct. When will hams
see what is being done and continue to support the continuation and expansion
of these programs. Keep in mind that most of this has been done by one or two
HQ staffers, who also have numerous other responsibilities, so I'd say that
it's a mean and lean machine doing good for amateur radio.
Ed Hare, W1RFI
ARRL Lab Manager 1987-2023
Current ARRL Lab Volunteer
From: RFI <rfi-bounces+w1rfi=arrl.org@contesting.com> on behalf of Mike Fatchett W0MU
<w0mu@w0mu.com>
Sent: Thursday, July 25, 2024 11:04 PM
To: rfi@contesting.com <rfi@contesting.com>
Subject: [RFI] New ARRL Mission statement > Was solar fix
The ARRL today release a new Mission statement. 2nd on the list is
protection of Ham Radio. I am very curious to see what that plan is.
Does it include stopping/reduction RFI emission from devices that
continue to pollute the ham bands making harder and harder for people to
enjoy the hobby? Is that enough to get the FCC to start actually doing
their job?
W0MU
73, Pete N4ZR
On 7/25/2024 3:42 PM, David Colburn wrote:
You made it 'political'.
This has nothing to do with a constitutional-conservative preference for
less government and more liberty.
It has to do with corruption by monopolies and the relocation of funds
from enforcement to enabling-profit of corporations that donate to the
Party-in-power. (Consider who that was for the past 16 years -
there's been
no push for "small government" for at least 12 of the 16, and
precious little
the other 4.)
If it were about "small government" the FCC would have a smaller budget
and clearly-defined priorities - which would include keeping the
spectrum
clean.
IMHO, YMMV ... KD4E
On 7/25/24 14:22, David Eckhardt wrote:
They're gone in the name of "small government".
I do not consider this political, please, it's reality.
I'll attempt to keep my fingers off the keyboard in the future
addressing
this issue.
Dave - WØLEV
_______________________________________________
RFI mailing list
RFI@contesting.com
http://lists.contesting.com/mailman/listinfo/rfi
_______________________________________________
RFI mailing list
RFI@contesting.com
http://lists.contesting.com/mailman/listinfo/rfi
_______________________________________________
RFI mailing list
RFI@contesting.com
http://lists.contesting.com/mailman/listinfo/rfi
_______________________________________________
RFI mailing list
RFI@contesting.com
http://lists.contesting.com/mailman/listinfo/rfi
--
-----------------
David E. Crawford
Indian River City
Florida Libre
-----------------
_______________________________________________
RFI mailing list
RFI@contesting.com
http://lists.contesting.com/mailman/listinfo/rfi
|