I think many need to carefully read what Ed writes here. Be extremely
careful of wanting hard-set limits because that's what we'll get.
Imagine "USC X.XX.XX Para 7 states radiated emission will be no more
than x.xx uW (or dBm or uV/m or...) specified by the following
spectrograph using a standard measurement technique of <blah blah
blah>..." This could be disastrous for someone next door but "Meh" a a
few houses away. What we have is imperfect and a PITA but be very
careful what is asked for because it might just be granted.
It isn't possible to make everything utterly RF silent: it simply isn't.
It needs to be quiet enough for the particular situation and even that
will be a compromise. I don't like the fact that we have noisy
electrical and electronic equipment: I'd love to see things as silent as
they were when Marconi was a kid, but they aren't and never will be. We
need to be skillful in how we approach the problems and work with the
problems to make them quiet *enough.*
Kim N5OP
On 9/22/2020 2:39 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>
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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--
Kim Elmore, Ph.D. (Adj. Assoc. Prof., OU School of Meteorology, CCM, PP
SEL/MEL/Glider, N5OP, 2nd Class Radiotelegraph, GROL)
/"A great second violinist plays second fiddle to no one." //– Robert C.
Marsh, Chicago Sun-Times./
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