Now, when it comes to Part 15, I agree; much more is needed. Hams are
suffering interference from all sorts of devices regulated by Part 15. ARRL
wants reports -- specific reports -- ie, the Model XYZ sold by Wal-Get-Depot is
causing S9 interference from my neighbor's house. IF we can get those kinds of
quality reports, we can and do act. With a report like that, we go to
Wal-Get-Depot, or the on-line US-based entity selling them, obtain one and test
it to the C63.4 standards that apply to conducted emissions. We can also test
radiated, but in an open field, not a calibrated site, but even that is good
enough to know that a device is operating much above the limits. We find a lot
of devices exceeding the permitted noise levels, and this week, with the ARRL
Board of Directors meeting here, I have had discussions with the Chair of the
EMC Committee and our DC counsel, and we are discussing just how the reports
and complaints we have can be brought into the "Part 15" arm of the FCC.
But, unfortunately, the reports we receive are sporadic, or similar to: "My
neighbor had a noisy LED bulb, but we replaced it and threw the bad one away.
I don't know what the model number is or where it was purchased." ARRL doesn't
have the financial resources or staff time to buy every possible device, and
every switching power supply that is sold with everything is a potential
source, so those specific reports really are a vital part of our work. When we
get those reports, we can and do purchase units and do quantified testing on
them to see if they exceed the limits.
I am seeing a lot of pessimism on this list about FCC, but I am not going to
get derailed by it. Fifteen years ago, FCC WAS doing nada about interference
to hams, but a "can do" mindset and ensuing actions built a program where
harmful interference is being addressed, even through a few glitches along the
way.
But now that we have that in place, it's time for the next step. Laura
addresses these issues on the basis of harmful interference. In that light, it
is not necessary to demonstrate that a device exceeds the emissions limits, so
no actual testing needs to be done. This is a good thing, because the
Enforcement Bureau can't do its own testing. Exceeding the limits is a matter
for the FCC Office of Engineering Technology and the FCC Lab.
ARRL has been identifying a few noisy devices that exceed the limits. We have
well-documented reports and I expect that we will be filing complaints soon.
When I do, I want to see what opportunities we may have to streamline the
process.
Ed
________________________________
From: David Eckhardt <davearea51a@gmail.com>
Sent: Thursday, January 19, 2023 5:23 PM
To: Hare, Ed, W1RFI <w1rfi@arrl.org>
Cc: KD7JYK DM09 <kd7jyk@earthlink.net>; Rfi List <rfi@contesting.com>
Subject: Re: [RFI] DEFINITION OF "HARMFUL INTERFERENCE"
Thanks, Ed. I realize FCC keeps most of the airwaves civil as opposed to
11-Meters. But I do feel they could be doing considerably more in enforcing
Part 15. This, especially due to the digital revolution and SMPSs from China
which sail through Customs as a component with no attention paid to RFI. True,
these are only the tip of the RFI iceberg.
Previous to all of this, I had no inkling that you, ARRL, were so involved in
RFI remediation when it comes to amateur radio. I had always believed that was
the duty of the FCC and us EMC/RFI engineers. I don't believe most of the
readers of QST and the other periodic publications by ARRL are aware of your
efforts. Would it be possible to author an article for QST on your efforts,
methods, and connections with the FCC? A few pictures in the article of the
ARRL lab might also "impress" the readers and other licensed hams.
Yea, I know you're busy enough, but I truly believe most hams are ignorant of
your RFI efforts and the capability at ARRL.
Dave - WØLEV
On Thu, Jan 19, 2023 at 7:26 PM Hare, Ed, W1RFI
<w1rfi@arrl.org<mailto:w1rfi@arrl.org>> wrote:
Two of those FCC lawyers helped create and maintain the process that ARRL and
FCC use to resolve harmful interference problems.
________________________________
From: RFI
<rfi-bounces+w1rfi=arrl.org@contesting.com<mailto:arrl.org@contesting.com>> on
behalf of David Eckhardt <davearea51a@gmail.com<mailto:davearea51a@gmail.com>>
Sent: Wednesday, January 18, 2023 2:59 PM
To: KD7JYK DM09 <kd7jyk@earthlink.net<mailto:kd7jyk@earthlink.net>>
Cc: Rfi List <rfi@contesting.com<mailto:rfi@contesting.com>>
Subject: Re: [RFI] DEFINITION OF "HARMFUL INTERFERENCE"
Yes, in my opinion, FCC is just a collection of overpaid lawyers who
wouldn't recognize RF if it bit them in the behind. Further, OET has been
gutted and Part 15, either subpart, is not enforced unless there is big $$
in it for the CFR 47 bureaucracy.
Just my opinion formed over the decades (six+ of those) as a licensed
amateur radio operator and an EMC/RFI engineer.
Dave - WØLEV
On Wed, Jan 18, 2023 at 7:51 PM KD7JYK DM09
<kd7jyk@earthlink.net<mailto:kd7jyk@earthlink.net>> wrote:
> > *Harmful interference.* Interference which endangers the functioning of a
> > radionavigation service or of other safety services or seriously
> degrades,
> > obstructs or repeatedly interrupts a radiocommunication service operating
> > in accordance with this chapter.
> >
> > This statement is reproduced in several places throughout CFR 47, but the
> > wording is essentially identical. Pretty general, but this is what FCC
> > legally plays to.
>
> No doubt the FCC addresses such, within moments of being reported, as it
> clearly violates their own rules, as defined by those experiencing it.
>
> Kurt
>
> _______________________________________________
> RFI mailing list
> RFI@contesting.com<mailto:RFI@contesting.com>
> http://lists.contesting.com/mailman/listinfo/rfi
>
--
*Dave - WØLEV*
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