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Re: [RFI] RFI - A Losing Battle

To: Dave Cole <dave@nk7z.net>
Subject: Re: [RFI] RFI - A Losing Battle
From: Richard F DiDonna NN3W <richnn3w@gmail.com>
Date: Wed, 23 Sep 2020 14:57:48 -0400
List-post: <mailto:rfi@contesting.com>
Depending on where  you live, it is not really a choice.  Virtually all new
construction is HOA controlled property.

73 Rich NN3W

On Wed, Sep 23, 2020 at 2:14 PM Dave Cole <dave@nk7z.net> wrote:

> That is a choice the ham made by living in an HOA, and hence, not as
> much of a driver I would expect, as say a ham that does not live in an HOA.
>
> We are in the process of looking for a new place, and there will be no
> HOA, or restrictive CC&Rs, period!
>
> I will also run an RFI test overnight if possible,
> (https://www.nk7z.net/sdr-rfi-survey-p1/), or a full drive around if
> time is short...
>
> 73, and thanks,
> Dave (NK7Z)
> https://www.nk7z.net
> ARRL Volunteer Examiner
> ARRL Technical Specialist, RFI
> ARRL Asst. Director, NW Division, Technical Resources
>
> On 9/23/20 8:54 AM, Richard F DiDonna NN3W wrote:
> > One issue that pops up in terms of enforcement is the ability to even
> > make a complaint - especially with respect to neighbors.  If you live in
> > a HOA, your ability to demand changes to a neighbor's RF emitting
> > devices gets kind of diminished given the fact that many amateurs aren't
> > supposed to even have antennas with which they can hear the RFI in the
> > first place.
> >
> > 73 Rich NN3W
> >
> > On Wed, Sep 23, 2020 at 11:08 AM Hare, Ed W1RFI <w1rfi@arrl.org
> > <mailto:w1rfi@arrl.org>> wrote:
> >
> >     Part of the problem is that "enforcement" of harmful interference is
> >     handled by the Enforcement Bureau, which we have working somewhat
> >     well.  The emissions and marketing violations are enforced by the
> >     Office of Engineering and Technology, which knows of us, holds ARRL
> >     in high esteem, but we haven't worked out a process like we have
> >     with EB.  I think I can get that to change.
> >
> >     Ed
> >
> >
> >
> >     -----Original Message-----
> >     From: Dave Cole <dave@nk7z.net <mailto:dave@nk7z.net>>
> >     Sent: Wednesday, September 23, 2020 1:06 AM
> >     To: Hare, Ed W1RFI <w1rfi@arrl.org <mailto:w1rfi@arrl.org>>;
> >     rfi@contesting.com <mailto:rfi@contesting.com>
> >     Subject: Re: [RFI] RFI - A Losing Battle
> >
> >     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 <http://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
> >     <mailto:arrl.org@contesting.com>> on behalf of
> >      > Dave Cole <dave@nk7z.net <mailto:dave@nk7z.net>>
> >      > *Sent:* Tuesday, September 22, 2020 5:00 PM
> >      > *To:* rfi@contesting.com <mailto:rfi@contesting.com>
> >     <rfi@contesting.com <mailto: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
> >      >>
> >      >>
> >      >>
> >      >>
> >      >>
> >      >> Sent from Mail<https://go.microsoft.com/fwlink/?LinkId=550986>
> for
> >      >> Windows 10
> >      >>
> >      >> From: Jim McCook<mailto:w6ya@cox.net <mailto:w6ya@cox.net>>
> >      >> Sent: Wednesday, September 2, 2020 10:54 PM
> >      >> To: RFI List<mailto:rfi@contesting.com <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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