I can attest to how useful the ARRL lab has bee n for me... I had a
long term issue with an indoor garden. I carefully documented things to
Steve Anderson's liking, provided both movies, and tapes of the issue,
including how DFing was performed, and with what gear. A letter soon
followed to the home owner, (it was a rental), and the issue ended one
day shortly after the letter was sent. After five years of not being
able to use 40 meter, I have now had five years of being able to use 40
again... I can't thank the ARRL enough for this. I was very reticent
to contact the person living in the rental as the place looked very
sketchy...
73, and thanks,
Dave (NK7Z)
https://www.nk7z.net
ARRL Volunteer Examiner
ARRL Technical Specialist, RFI
ARRL Asst. Director, NW Division, Technical Resources
I never learned from a man who agreed with me. (HeinLein)
On 7/26/24 16:27, martin glazer via RFI wrote:
Agree.
Sent from Yahoo Mail for iPhone
On Friday, July 26, 2024, 4:22 PM, Hare, Ed, W1RFI via RFI <rfi@contesting.com>
wrote:
<Short rebuttal to long essay: the current rules aren't good enough.>
In general, I agree, but changing FCC rules, especially to make unlicensed emissions
limits more stringent, is not the best solution, because it can take an incredible
amount of time and the outcome is not certain. I can say with certainty that the FCC
will never set those limits low enough to prevent all interference to amateur
radio. The political resistance would not be futile.
I could have written a dozen more paragraphs, but one point worth mentioning is that we now
have more interest by OET in these noisy devices. Now that we have an inroad to report devices
that exceed the emissions limits, the Lab can and will do more testing, once they are
identified. And even for otherwise legal devices, the FCC is taking some action wrt
harmful interference. Both types of FCC contact and cooperation will continue and the
Lab staff will continue to work with industry. ARRL is uniquely positioned to do both.
________________________________
From: David E. Crawford <dcsubs@molniya1.com>
Sent: Friday, July 26, 2024 6:56 PM
To: Hare, Ed, W1RFI <w1rfi@arrl.org>; Mike Fatchett W0MU <w0mu@w0mu.com>;
rfi@contesting.com <rfi@contesting.com>
Subject: Re: [RFI] New ARRL Mission statement > Was solar fix
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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
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David E. Crawford
Indian River City
Florida Libre
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