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Re: [RFI] New ARRL Mission statement > Was solar fix

To: "Hare, Ed, W1RFI" <w1rfi@arrl.org>, "Hare, Ed, W1RFI via RFI" <rfi@contesting.com>
Subject: Re: [RFI] New ARRL Mission statement > Was solar fix
From: mstangelo--- via RFI <rfi@contesting.com>
Reply-to: mstangelo@comcast.net
Date: Mon, 29 Jul 2024 08:17:06 -0400 (EDT)
List-post: <mailto:rfi@contesting.com>
Ed has a point.

Most of the interference we are concerned about is to the MF and HF bands. 
Interference to these bands do not concern the general public for the most 
part. AM stations are still on the air to be eligible for FM repeaters. The AM 
stations in my area also broadcast on FM.

The HF bands are used for emergency and communications traffic on a backup 
basis. I had the privilege of working for ITT and AT&T while they had HF 
coastal stations. Both companies could not wait to close down the stations.

If you read the FCC docket regarding the $35 fee for Amateur Radio licenses you 
will se the FCC no longer considers the Amateur Radio service to be an 
emergency service.

If the interference affects services used by the general public, emergency, 
utility, government or military the FCC will be forced to act on such 
interference.

Mike N2MS

> On 07/28/2024 3:22 PM EDT Hare, Ed, W1RFI via RFI <rfi@contesting.com> wrote:
> 
>  
> Actually, the large majority of devices DO meet the existing rules, including 
> noisy power lines, noisy solar panels and noisy appliances.   In a more 
> concise form, here are the major issues with the existing rules:
> 
> 
>   1.
>  There are no radiated emissions limits below 30 MHz.  The conducted 
> emissions apply ONLY to the AC mains, but not to all of other wiring that is 
> connected to many devices.  In the solar systems ARRL has tested, the AC 
> mains looked rather clean, but the wires going to inverters, panels and 
> optimizers did not.
>   2.
> There are a lot of exempted devices, exempt from any specific emissions 
> limits.  These include incidental emitters such as power lines, older 
> electric motors and any devices that operate with internal fundamental 
> signals less than 9 kHz and all types of devices classified as "appliances."
>   3.
> The manufacturer is required only to have a design that meets the emissions 
> limits.  Manufacturers are not legally responsible for harmful interference.
>   4.
> The emissions limits are higher than levels that would offer protection to 
> licensed radio services.
> 
> Jim is correct, not only would it take years to change the rules, the end 
> result would still have emissions limits that do not solve all problems  Once 
> the door is open, could we imagine some industries seeking more exemptions?   
> That may not be a door we want to open.
> 
> Right now, the FCC decides interference cases on the basis of harmful 
> interference.  The ARRL Lab has made it clear to FCC that interference will 
> result from legal devices, so FCC generally accepts that strong noise that 
> may be otherwise legal is causing interference, so FCC does take some 
> actions.  I could imagine that if FCC lowered the limits, it would say that 
> any device below those limits is not actionable, so the theoretically 
> unconditional protection about harmful interference could go away, replaced 
> by slightly more stringent limits.
> 
> Also, right now, the Lab has made quite a bit of inroads with manufacturers, 
> often securing a surprising amount of cooperation.  If there were an 
> adversarial rulemaking in progress, that mutual "engineer-to-engineer" 
> cooperation would probably be stopped, with the corporate lawyers insisting 
> that all communication with ARRL go through them.
> 
> Right now, the best approach is to continue to get the FCC to act on actual 
> harmful interference and to begin to call more attention to FCC OET about 
> devices not meeting the current limits, and to make it aware of interference 
> involving exempted units.  That is the only way I can think of that will 
> raise the FCC awareness that the rules need to be changed.  That is a 
> long-term process that has been moving, albeit slowly.  In the meantime, use 
> the existing processes to get actual interference resolved.
> 
> Ed, W1RFI
> 
p://lists.contesting.com/mailman/listinfo/rfi

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