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Re: [RFI] RFI - A Losing Battle

To: "Hare, Ed W1RFI" <w1rfi@arrl.org>, "rfi@contesting.com" <rfi@contesting.com>
Subject: Re: [RFI] RFI - A Losing Battle
From: Dave Cole <dave@nk7z.net>
Date: Tue, 22 Sep 2020 22:06:06 -0700
List-post: <mailto:rfi@contesting.com>
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





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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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