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Re: [RFI] LED Bulbs

To: "EDWARDS, EDDIE J" <eedwards@oppd.com>, "'Dale J.'" <dj2001x@comcast.net>, RFI Reflector <rfi@contesting.com>
Subject: Re: [RFI] LED Bulbs
From: Dale <svetanoff@earthlink.net>
Reply-to: Dale <svetanoff@earthlink.net>
Date: Thu, 13 Feb 2014 11:55:47 -0600 (GMT-06:00)
List-post: <rfi@contesting.com">mailto:rfi@contesting.com>
Eddie,

Well said.  I also want to clear up a point that you addressed to a certain 
extent.  Regarding extra testing, filtering, or whatever, the FACTS are that 
the emission limits of Part 15 for Classes B and A are what they are.  Yes, 
there are unscrupulous manufacturers who knowingly violate even those rather 
generous allowances.  As another post mentioned, the FCC is clearly in need of 
reallocating some resources, and until they do (if ever), field inspection and 
testing of such violating devices will continue.  Keep in mind: In the past, 
FCC has raided and confiscated stocks of illegal CB radios, and they have done 
the same for some notorious Part 15 devices, as well. I also advise readers to 
revisit the recent posting about the illegal light fixture emissions that wiped 
out a cell site and FCC actions for that.

I do think too many readers on this site still do not understand that the 
legally allowable emissions from Part 15 devices are too high for radio system 
location in close proximity.  Those are the facts.  In some cases, some devices 
actually do not cause serious interference levels.  In others, the RFI can be 
controlled by application of various measures, but doing so means that unless 
the affected hams happen to be the owners of such devices, they will have to 
suck it up and go talk with their neighbors who do own such devices (plasma 
TVs, for example).  

If it is any consolation to those of us in the USA, it has been FCC policy for 
years to "harmonize" their requirements with those in some other countries, 
notably those in the European Union, issuers of the CE mark.  That means limits 
for emissions in most European countries are very similar to those here.  On 
the down side, the one main area NOT addressed by FCC action has been 
susceptibility.  The EU held fast and insisted on having most electronic 
equipment meeting at least some modest levels of RF immunity.  That is one 
reason why when I buy computer equipment, I make sure it has both the FCC and 
CE marks - much of it does.  That's proof (to my eyes) that the arguments from 
manufacturers to the FCC about cost factors in implementing RF immunity 
requirements was mostly bovine fertilizer designed to maximize profits.

So, yes, any hams who are affected by RFI from Part 15 equipment need to take 
action.  If they own the equipment, contact the manufacturer and complain.  If 
your neighbors own the equipment, try to get them to do the same or make your 
own complaint.  I agree - saying or doing nothing gets exactly that done.  
While you are at it, don't forget to check for markings that indicate FCC 
compliance.  No markings for devices that fall under Part 15 rules = violator.  
FCC markings but lots of noise MAY indicate altered designs (see a previous 
post of mine), an illicit marking (marked, but not tested), or a legal device 
that just happens to produce a lot of RFI in the part of the spectrum you want 
to use.  Remember, there are no radiated Part 15 requirements for HF.

73, Dale
WA9ENA                    


-----Original Message-----
>From: "EDWARDS, EDDIE J" <eedwards@oppd.com>
>Sent: Feb 13, 2014 11:18 AM
>To: "'Dale J.'" <dj2001x@comcast.net>, RFI Reflector  <rfi@contesting.com>
>Subject: Re: [RFI] LED Bulbs
>
>Dale, 
>
>I agree with "squeaky wheels get the grease".  That's why most posts are 
>saying it's important to call or file RFI complaints with the neighbor first, 
>then the FCC, ARRL, CPSC, NCIS or any other acronym agency that you think 
>might be interested.  If the FCC doesn't get any complaints, then there is no 
>RFI problem to address.  A ham with a noisy TV next door and has not filed a 
>complaint simply proves there is no real RFI problem.
>
>From all the links provided during this discussion, it looks like squeaky 
>complainers are getting action.  On the power line noise side of things, I 
>know firsthand that FCC complaints result in FCC letters to CEOs, and CEOs 
>don't like to get letters from the federal government.  The result is 
>immediate action and resolution of RFI problems.  
>
>On the consumer product side, it's more complicated, but many do get some 
>resolution eventually.  We deserve inaction if that's all that we provide. 
>
>I get the feeling from Dale J's posts he wants more testing for better 
>filtering.  But testing by who?  The FCC?  3rd party contractors?  And how 
>much testing?  Random, continuous, or 100 percent?  And how much enforcement?  
>And who will pay for it all?  The consumer of course in higher prices.  I'm 
>guessing there are probably more consumers who vote than hams who vote.
>
>This all reminds me of the old 50s/60s TVI issue of adding high pass filtering 
>to all of the TVs sold out there so they won't pick up RFI from hams even 
>though more than 99.9% of TVs won't be located near an active ham station.  
>Does it make any sense to spend millions of dollars (billions in today's 
>dollars) to add the high pass filters to ever TV including the 99.99% that do 
>not need them, or is it maybe more efficient to add the HP filters to only 
>those located near active ham stations?  I seriously doubt we hams will win 
>that debate.
>
>Most of today's RFI issues are much more complex to resolve than the old TVI 
>filters issue.  But it still comes down to a balance between how much the 
>consumer is willing to pay versus how willing the ham operator is willing to 
>take action for a resolution to the RFI problems.  Based on this, I'd say 
>we're lucky to have the FCC and regulations somewhat on our side.  But it's 
>still up to us amateur radio operators to get up off our duffs if we want any 
>action at all.
>
>73, de ed -K0iL
>
>-----Original Message-----
>From: RFI [mailto:rfi-bounces@contesting.com] On Behalf Of Dale J.
>Sent: Wednesday, February 12, 2014 6:37 PM
>To: n0tt1@juno.com
>Cc: rfi@contesting.com
>Subject: Re: [RFI] LED Bulbs
>
>Yes, Ed pretty well summed it up.  Paul made some interesting comments too.  
>
>To all, thankyou for this discussion it was enlightening for me.  The old 
>saying goes, squeaky wheels get the grease.  Keep it up.  If we remain quiet, 
>then nobody hears.  Hopefully the message will at least be read, by someone, 
>somewhere.    
>
>73
>Dale, k9vuj
>
>
>On 12, Feb 2014, at 17:59, <n0tt1@juno.com> wrote:
>
>> 
>> On Wed, 12 Feb 2014 10:53:51 -0600 Ed Douglass <efdouglass37@gmail.com>
>> writes:
>>> David Robbins' argument is interesting but it takes the focus away, 
>>> it
>>> seems to me, from what should be the primary point of our efforts.  
>>> The
>>> point is that the FCC's job in the first instance is to regulate 
>>> the
>>> manufacturers and importers of electronic equipment so that the 
>>> equipment
>>> does not cause interference to licensed users of the radio spectrum. 
>>> If
>>> such regulation had been enforced, then we amateurs would not need 
>>> to be
>>> approaching our neighbors about their RFI-generating appliances.
>>> 
>>> For the RFI-generating equipment already in the country, then we 
>>> will have
>>> to approach our neighbors and hope we have the FCC's backing if our 
>>> efforts
>>> fail.
>>> 
>>> For the long haul, however, we need to use ourselves and our ARRL to 
>>> get
>>> the FCC to enforce its rules (and tighten them, where necessary).
>>> 
>>> 73 de Ed, AA9OZ


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