Daniel,
First, I applaud the fact that you seem to be the first (or one of very few)
manufacturers (or former manufactures, in your case) to address some comments
on the topic. As an EMC engineer and active ham, I have long decried the fact
that the FCC caved in to manufacturer cost issues and failed to implement any
amount of RF immunity in the Part 15 devices. Therefore, I have a bit more
respect for the EU regulatory folks who did provide for a modest amount of
immunity for devices sold in their market.
Having said that, amidst all of the weeping and wailing that has been going on
over "non-compliant" devices in the USA, I must remind hams (and others) of an
important FACT: Yes, there are certainly non-complying devices on the market
and being sold every day. Those need to be identified and pulled from sale and
distribution. As has been noted several times, the FCC has busted some of the
distributors and confiscated non-complying equipment when they are informed of
same and have time to act accordingly. BUT ... (and this is the BIG one), the
facts are that even complying devices still radiate more than is tolerable,
especially in the HF and lower VHF ranges, by a factor of at least 30 to 40 dB.
That is because the limits are set too high for allowable radiated emissions
when it comes to compatibility with radio communications installations.
How do I know this? Well, having worked for 10+ years in aerospace EMC, I had
to live by the requirements of MIL-STD-461 (versions B thru F, with G coming
soon) and RTCA DO-160. The DO-160 document is the commercial aircraft
requirement for EMC, with some portions very similar to the MIL document. I've
said this before, and I'll repeat it here: MIL-STD-461 was designed to allow
co-located communications equipment to operate on a non-interfering basis.
That's WHY it is around 30 to 40 dB tougher on emissions (plus it has immunity
requirements, too) than is Part 15.
It is time to wake up and smell the facts for what they are: if your neighbor
has a TV or LED lights or battery charger or whatever that screws up your HF
operating all evening and weekend, YOU (the ham op) need to work with your
neighbor to learn 2 things about the problem device: 1) What is it? 2) Does
it bear an FCC label and appropriate Part 15 warning information?
The problem then arises as to whether the device in question is legit and is
wiping out your HF operations because of the lack of FCC requirements for
emissions control to a level below what would cause the interference, or is it
because the device is NOT legit, although it is marked as being so? The only
way to know for sure is a retest of the device by an RF compliance test lab,
although examination of the device's "guts" could reveal if important
EMC-related components have been omitted. Alas, you are not likely to be able
to do any of this.
At this point is when the issue of non-interference enters the picture, and so,
YOU (the ham op) may then have to work with your neighbor to either replace his
gizmo with an RF clean one (at your expense) or take him to the ARRL and/or FCC
and try to get the squeeze put on him to shut down the device. Not much of a
win-win situation, for sure.
Remember 2 big factors about RFI to your station: 1) Interference must be
stopped at the source. Once radiated, the show is over. 2) RFI drops off by a
factor of distance squared once you are in the far field (if you don't know
what I mean, please go learn about it). Keep your antennas as far from your
house and your neighbors' as possible to minimize interference pick-up. Yes, I
know that is mission impossible for most urban and suburban dwellers, but
that's physics for you.
It's an ugly scene and not likely to get better anytime soon. As has been
noted on this reflector before, one thing that hams can do is eliminate many
noisy switching power supplies in their own home or shack. Most of the wall
warts you see today for various gadgets are RF-noisy switchers. You can
replace them with RF-quiet linear wall warts by either finding some on the
market or homebrewing your own. Designing and making small linear regulated
power supplies is not rocket science, but it does take some initiative on your
part to do it. I can't suggest doing the same for your neighbors' equipment
due to liability and warranty issues. OTOH, there are several switchers on the
market that are big enough to operate your rigs (13.8 VDC output), but they
generally employ emission control measures well in excess of those of Part 15.
The Astron SS-series of power supplies is a good example.
73 and happy RFI hunting,
Dale
WA9ENA in Iowa
-----Original Message-----
>From: Daniel Donnelly <kc7vda@gmail.com>
>Sent: Mar 21, 2014 1:51 PM
>To: rfi@contesting.com
>Subject: Re: [RFI] RFI Digest, Vol 134, Issue 12
>
>Hello to the group;
>I have followed your group for quite some time, and have used the tips I
>have picked up, some were very good, some frustrating, but mostly very
>good, in solving many problems.
>In this instance, Dale k9vuj is right on point.
>
>There are strict regulations that are designed to eliminate RFI, and they
>apply to the manufacturer as well as the owner of any commercial product
>As a former (now retired) manufacture I know where of I speak, I have had
>to comply with those regulations or pay a LARGE fine and/ or have my
>product seized and destroyed.
>That is one of the reasons that there is very little manufacturing ( and so
>few jobs) in the United States,
>
>To produce a product in the United States a manufacturer must comply with
>Trade mark, FCC regulation's,,ever changing workman's compensation as well
>as the minutia of State and Federal Health and safety regulations.
>The cost to simply comply with the paper work required is horrendous,
>Today, even small manufactures are almost forced to out source their
>product and simply put a pre-assembled Chinese board in a housing made in
>Honduras and add some stickers to say made in the USA. Manufacturers have
>been led to believe that by off shoring they are exempt from those and many
>other health and safety regulations. to a certain extent they are right, at
>least their costs are greatly reduced.
>
>HOWEVER, While Importing Manufactures are exempt from workman's
>compensation, as well as many of the health and welfare regulations, they
>are not now and never have been exempt from FCC or trade mark regulations.
> ANY product imported into the United States MUST be compliant with ALL
>applicable Federal regulations.
>The onus of proving compliance falls on the MANUFACTURER not any
>governmental agency. Every day US customs agent seize or reject thousands
>of items because of Trademark or technical violations that the manufacturer
>are required to correct. Many Manufactures, especially those whose home
>offices are outside the United States simply FAKE test results to receive
>an import certificate, those seized are required to be tested in federal
>approved laboratories and if found non-compliant must be either either
>reworked by the manufacturer or destroyed
>Without the complaints you send in those cheats would never be found out.
>When you do not complain about a shoddy or poorly made product you are
>condoning poor design practices and possible allowing unsafe equipment to
>be brought into the United States.
>That is the reason why you MUST complain when you find a product that
>produces excessive RFI, The report generated by your complain was designed
>into and is necessary for import law to function. You, and the complaint
>you send in, are a necessary and vital part of import law enforcement.
>
>Yes, your neighbor may not like having to buy a new, possibly very
>expensive, widget
>Yes, If many people send in RFI reports The FCC may be forced to do it's
>job and that may mean adding more agents now, but in the long run they will
>actually need fewer agents.
>
>Consider this, in 1940 The FCC had 1800 agents mostly involved with
>communications violations, Today there are less than a thousand agents with
>about 400 involved with Licensing and communications violations. As far as
>I can tell, there are less than 100 involved with RFI and import violations.
>The reduction in agents involved with amateur violations occurred because
>we became self policing. We became self policing for a very good reason,
>fines were stiff, and amateur operators could and did lose their licenses.
>Self interest forced us (amateur radio) to eliminate the troublemakers and
>become self policing, Manufacturing standards groups are moving in the
>same direction, for the same reason, $10,000 fines per day tend to get a
>manufacturers attention and those that lose their import certificate are
>out of business. Simple financial interests will in the long run force the
>cheats out of business
>But that will not happen if you don't do your job and complain... after all
>the squeaky wheel gets the grease, and we as radio amateurs have more
>reason to "squeak"than
>almost any other group.
>
> Daniel Donnelly KC7VDA
>> On 3/21/2014 9:06 AM, Kim Elmore wrote:
>> > How is this viewpoint helping to solve your RFI problems?
>> >
>> > Oh, and how much are you willing to pay to beef up the FCC's Enforcement
>> division to chase down and eradicate every one of these RFI sources, since,
>> as you point out, that's not *your* job?
>> >
>> > Kim N5OP
>> >
>> > "People that make music together cannot be enemies, at least as long as
>> the music lasts." -- Paul Hindemith
>> >
>>
>>
>> ------------------------------
>>
>> Message: 3
>> Date: Fri, 21 Mar 2014 08:53:35 -0500
>> From: "Dale J." <dj2001x@comcast.net>
>> To: "rfi@contesting.com Reflector" <rfi@contesting.com>
>> Subject: Re: [RFI] ARRL to FCC...
>> Message-ID: <065211AC-3FB7-4727-B372-C93AC2D511C7@comcast.net>
>> Content-Type: text/plain; charset=us-ascii
>>
>> I think you all are missing the point.
>>
>> The idea is to be proactive and stop the junk from ever hitting the
>> shelves in the first place. True, it's too late for the junk that's
>> already out there, If you want to go to war with your neighbors, fine,
>> complain and hope for the best, but your neighbors I don't believe will
>> take kindly to the FCC letter stating their TV is illegal and interfering
>> with a ham radio operator therefore must be shut down or risk a $10000 fine.
>>
>> Dale, k9vuj
>> Message: 5
>> Date: Fri, 21 Mar 2014 09:37:07 -0500
>> From: "Dale J." <dj2001x@comcast.net>
>> To: "rfi@contesting.com Reflector" <rfi@contesting.com>
>> Subject: Re: [RFI] ARRL to FCC...
>> Message-ID: <ABCA343D-BAF5-4355-8300-3F1AFA943437@comcast.net>
>> Content-Type: text/plain; charset=us-ascii
>>
>> Well Kim, the short answer is, I'm not willing to go to war with my next
>> door neighbor.
>>
>> Sure, I could complain to the FCC and may or may not get relief, but I'd
>> still have to live next door to my neighbors. That's why I would like to
>> see better oversight of potential RFI generators being sold to the general
>> public. The ultimate burden should, must be placed on the manufacturer of
>> the errant product, not on the end user or me.
>>
>> Dale, k9vuj
>
>>
>> I had a neighbor who installed two of those xenon lamps using Chinese
>> switchers, 40 watters... Wiped out my radio totally, and three other
>> hams radios as well around the area.. He decided he did not need to do
>> anything about it, and it was just too bad for us... I tried to be
>> nice, I tried to be sweet, I even offered to buy new lights, he just
>> decided that he was not going to do anything about them... A note from
>> that FCC ended that instantly...
>>
>> Turns out he had enclosed two wall warts in sheet rock cavities, and did
>> not want to spend the money to dig them out of some enclosed space he
>> had built them into... Don't ask me how or why he did that, but that
>> was the reason given... In any case within 30 days my radio was back to
>> working again...
>>
>> If we are to keep our bands clean, we all must start reporting this sort
>> of thing to the FCC and the ARRL every time...
>>
>> Look at the results, some folks reported Grow lights as an issue to the
>> ARRL, and the ARRL did testing, and then damned near demanded that the
>> FCC get this item removed...
>>
>> As of this morning, neither Sears, or whoever the distributer was in CA
>> has them on their websites, I know the fellow in CA did, and now it is
>> gone... THIS IS POSITIVE ACTION, and it helps every one of us.
>>
>> So... If you have an RFI problem, report it, use your rights to enjoy
>> your radio-- clear of RFI...
>>
>> Report RFI when it is a problem for you. Don't report RFI if it is not
>> an issue, but if it is bothering you, report it!
>>
>> Please... You are not only helping yourself, you are helping every ham
>> in your general area.
>>
>>
>> --
>> Thanks and 73's,
>> For equipment, and software setups and reviews see:
>> www.nk7z.net
>> for MixW support see;
>> http://groups.yahoo.com/neo/groups/mixw/info
>> for Dopplergram information see:
>> http://groups.yahoo.com/neo/groups/dopplergram/info
>> for MM-SSTV see:
>> http://groups.yahoo.com/neo/groups/MM-SSTV/info
>>
>> Message: 8
>> Date: Fri, 21 Mar 2014 08:38:36 -0700
>> From: "Kenneth G. Gordon" <kgordon2006@frontier.com>
>> To: David Cole <dave@nk7z.net>
>> Cc: rfi@contesting.com
>> Subject: Re: [RFI] ARRL to FCC...
>> Message-ID: <532C5CFC.143.3CA4BD6F@kgordon2006.frontier.com>
>> Content-Type: text/plain; charset=US-ASCII
>>
>> On 21 Mar 2014 at 7:52, David Cole wrote:
>>
>> > decided that he was not going to do anything about them... A note from
>> > that FCC ended that instantly...
>>
>> What, exactly, did you have to tell the FCC to get them to notifiy this
>> ass?
>> Did you have to DF the problem yourself, or did you simply have to tell the
>> FCC that "someone" was seriously interfering with your operation?
>>
>> What?
>>
>> I need to know.
>>
>> SOMEONE, or SOMEthing, in my neighborhood is doing SOMEthing that
>> results in a 20db over S-9 constant noise level on (at least) 80 meters.
>>
>> I am also confirming that every damned piece of Chinese-made or
>> Chinese-designed electronic whatever is so damned "noisy" RF-wise that it
>> shouldn't be allowed out of China.
>>
>> Ken Gordon W7EKB
>
_______________________________________________
RFI mailing list
RFI@contesting.com
http://lists.contesting.com/mailman/listinfo/rfi
|