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Re: [RFI] DEFINITION OF "HARMFUL INTERFERENCE"

To: David Eckhardt <davearea51a@gmail.com>
Subject: Re: [RFI] DEFINITION OF "HARMFUL INTERFERENCE"
From: "Hare, Ed, W1RFI" <w1rfi@arrl.org>
Date: Sat, 21 Jan 2023 12:38:38 +0000
List-post: <mailto:rfi@contesting.com>
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
>


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