Pulling a single sentence from Ed Hare's "treatise": There are no radiated
emissions limits below 30 MHz and no limits on the amount of noise that can
be conducted onto other wiring, .......
The reason for no radiated emissions below 30-MHz is often misunderstood by
the average amateur. In putting only conducted emissions into the
regulation for anything below 30 MHz, FCC realized that these devices would
be connected to usually long conductors acting as radiators, a.k.a.,
antennas. These long conductors could not be accommodated in the standard
OATS or semi-anechoic chambers - the standard for radiated emissions
assessments. So, in limiting the conducted emissions only effectively
limits the amount of energy coupled onto these long (and effective)
radiators, even the power grid. The reasoning for not providing radiated
emission limits below 30 MHz is technically sound.
Now my, hopefully, short "editorial" to Ed's "treatise".
My main gripe about ARRL doing this work is that the charter of FCC (CFR
47) was to do or contract to accredited labs what ARRL is doing - for a
fee. The labs aren't cheap!! Believe me. I've used them for over 40
years. Not that ARRL isn't doing a yeoman's job at the task, but they are
not being paid for the efforts as was the intention of the original tasks
set out for the FCC. They are performing these "services" at the expense
of us members of ARRL (yes, I'm a life member). That's you and me.
In some ways, yes, the efforts of ARRL wrt EMC/RFI are directly serving
amateur radio, but they should be paid for the efforts as FCC presently is
pretty much lax with enforcement. This was not the intention of the FCC
"charter" (CFR 47, and in particular, Part 15). At present, as far as the
FCC enforcement is concerned (from experience as an EMC/RFI engineer for
over 40-years) Part 15 may as well not exist.
Wall warts and switch mode power conversion units sail through customs with
no attention paid to EMC/RFI as they are considered "components''.
Components are exempted by FCC rjules. FCC takes no enforcement efforts to
sample final assemblies which contain these switchers. But, FCC rules
specifically point out that the final assemblers of a product are
responsible for the final EMC/RFI solution. AThe "solution" requires
passing established radiated and conducted limits set by the FCC (and the
EU). I've tested many of these and many do not pass the established FCC
(or EU) radiated emission limits. The vast majority wall warts do not pass
their conducted emission limits. Sampling and enforcement at the FCC is
sorely lacking!!
The reality of the situation is that China has "taught" the suppliers and
assemblers to cheat,.....yes, cheat. I won't belabor this point, but
anyone in my shoes as EMC/RFI engineers fully knows what I'm referring to
in that statement.
Well, this WAS going to be short.......
Ed and all at ARRL, I would be glad to serve on a local representative to
my area as an EMC/RFI trouble shooter if and when the ARRL establishes this
function. Yes, as a volunteer with no pay. I have a relatively complete
RF lab with some of the instruments (and antennae) quite portable.
ONE FINAL NOTE: It's sad that ARRL is underfunded. Their EMC/RFI efforts
are probably the most effective to us radio amateurs. But the whole
organization is sorely underfunded. HELP........
Enough.........
Respectively Submitted:
Dave - WØLEV
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On Fri, Jul 26, 2024 at 11:20 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
>
> [You don't often get email from dcsubs@molniya1.com. Learn why this is
> important at https://aka.ms/LearnAboutSenderIdentification ]
>
> 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
> -----------------
>
> _______________________________________________
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> RFI@contesting.com
> http://lists.contesting.com/mailman/listinfo/rfi
>
--
*Dave - WØLEV*
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