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Re: [RFI] Solar Panel RFI Awareness At Dayton

To: Pete Smith N4ZR <pete.n4zr@gmail.com>, "rfi@contesting.com" <rfi@contesting.com>
Subject: Re: [RFI] Solar Panel RFI Awareness At Dayton
From: "Hare, Ed, W1RFI" <w1rfi@arrl.org>
Date: Fri, 27 May 2022 14:49:11 +0000
List-post: <mailto:rfi@contesting.com>
I, for one, very much appreciate that the FCC doesn't have the resources to 
deal with every RFI problem. To me, it's ironic, and telling of how well ARRL 
designed its programs related to RFI, that 1.5 people in the ARRL Lab do what 
FCC cannot, but no matter what, I want ARRL to be involved.  Because FCC knows 
that it really benefits from our involvement, we are involved more than we 
otherwise would be, and that is a good thing.  If FCC did have more resources, 
it would probably begin every case with a form letter that started:  "Under FCC 
rules, power line noise sources are incidental emitters, which have no FCC 
limits on conducted or radiated immunity...."  It might go downhill from there.

ARRL provides the FCC with the most accurate and honest information it can, and 
the resultant reputation serves us all well.  FCC knows of ARRL's successes 
with industry, and how it has spent decades building relationships and 
participating in major industry processes, and that, too, opens doors of 
communication and trust that would probably otherwise be closed, and that would 
probably not be opened for anyone else.

This process is not perfect, and we are always  looking for ways to improve it, 
but it has been built piece by piece, literally over decades of time.  The only 
part of this that existed in 1986 when I was hired by ARRL is our participation 
in the C63 US national EMC-standards committee, helping to write standards 
often incorporated by the FCC by reference in its rules. (I have a funny BPL 
story related to that which I will tell here one day, but not today.)

One day, the Lab phone rang with a TVI case. I told the ham to use a low-pass 
filter. He had done so. I told him to use a high-pass filter on the TV. He had 
done so. I realized I had no more to offer and came to the conclusion that ARRL 
needed to improve its RFI program.  I put together a proposal that included 
improving ARRL's book on RFI, creating information packages, establishing 
contact with industry and helping to develop industry standards.   That was in 
1988, IIRC and here were are, 34 years later and it's all happening.

I didn't envision ARRL staff holding leadership positions, though I now know 
that this can be done simply by being willing to take on the work.  I didn't 
envision our program the FCC, although when the opportunity came up when Riley 
wrote letters to a few California utilities, I took the opportunity and now we 
have something pretty solid.

Okay, soapbox off. I am home today with a mild case of COVID picked up at 
Hamvention or travel to and fro, so ready to take another nap and get ready for 
my return to to the office next week.

Ed, W1RFI
ARRL Lab Dad


________________________________
From: RFI <rfi-bounces+w1rfi=arrl.org@contesting.com> on behalf of Pete Smith 
N4ZR <pete.n4zr@gmail.com>
Sent: Friday, May 27, 2022 10:33 AM
To: rfi@contesting.com <rfi@contesting.com>
Subject: Re: [RFI] Solar Panel RFI Awareness At Dayton

I'll second that from a layman's perspective.  During the long COVID
experience, I had some pretty bad powerline interference develop.  BGE's
noise guy for my area identified several sources, and when they finally
got the trucks back out on something like a normal schedule, my sources
dropped one by one, and I now have a pretty clean environment.

73, Pete N4ZR
Check out the new Reverse Beacon Network
web server at<http://beta.reversebeacon.net>.
For spots, please use your favorite
"retail" DX cluster.

On 5/27/2022 9:32 AM, Hare, Ed, W1RFI wrote:
> And we send that message to utilities, too.  And yes, those 50+ sources were 
> a real experience, showing an investigator who made a decision that the 
> utility should think is as unfair as the ham thought the first decision was.
>
> It's interesting, Mike, to see how those who have been in this game for 
> decades like you and me know exactly why we do things the ways we do. Our 
> credibility with the FCC and most of the utility industry is high, because we 
> support what is true and right. We will back a utility that legitimately 
> finds a non-utility device generating noise; we at least accept that a 
> utility only needs to fix noise sources that cause actual interference, 
> although correcting some of the others is good maintenance practice.
>
> I also know from experience, as do you, that a formal FCC complaint changes 
> things, but, like field investigations, it can change things for the better  
> or for the worse.  In many cases, when the FCC letter shows up, the lawyers 
> take over. For that reason, if the utility is responsive at all and willing 
> to try to fix it, we will help them in any way we can.
> If things are still at the staff level, we are all better off keeping it 
> there, and use the FCC only as a last resort.
> ________________________________
> From: Michael Martin<mike@rfiservices.com>
> Sent: Friday, May 27, 2022 8:40 AM
> To: Hare, Ed, W1RFI<w1rfi@arrl.org>
> Cc: David Eckhardt<davearea51a@gmail.com>; Dave (NK7Z)<dave@nk7z.net>; Rfi 
> List<rfi@contesting.com>
> Subject: Re: [RFI] Solar Panel RFI Awareness At Dayton
>
> Watch what you wish for, agreed!
> Those scenarios are very familiar to me. And there are many additional 
> stories to support what it is saying.
>
> Imagine being diagnosed with 50 interference sources in the FCC demanding 
> they be fixed. Only to discover that not one of those 50 sources were a 
> contributor to the noise level the ham was experiencing.
>
> Sometimes the paper tiger is best left undisturbed!
>
> Michael Martin
> RFI Services
> 240-508-3760
> <http://www.rfiservices.com>www.rfiservices.com<http://www.rfiservices.com>  
> is under construction and will be up and running soon.
>
> Get BlueMail for Android<https://bluemail.me>
> On May 27, 2022, at 7:10 AM, "Hare, Ed, W1RFI" 
> <w1rfi@arrl.org<mailto:w1rfi@arrl.org>> wrote:
>
> As amateurs, we should very much prefer it the way it is rather than having 
> the FCC be 100% responsible for "enforcing its own rules."  We can be assured 
> that if FCC were to 100% take on that task, the first thing it do is to make 
> a clear definition of harmful interference that I can assure you we would not 
> like.
>
> Be careful what you ask for because you just might get it and then have to 
> live with the aftermath.  The League staff are very much aware of what they 
> are choosing to do and why they undertake what the FCC will not.  We, in 
> fact, work at not demanding the FCC field investigations that some hams think 
> will make their case. It probably will not.
>
> Let me tell you a Tale of Two RFI Cases.
>
> In one case, a ham had S9 interference.  The utility screwed around endlessly 
> and the FCC finally was able to have a team going there for other reasons 
> look at the noise. It could not determine the source, so it told the amateur 
> that because he could hear some signals on the band, it was not harmful 
> interference, so the FCC was going to close the case and take no action.  You 
> would not believe the difficulty in getting that decision overturned.
>
> In another instance involving S9 noise, and FCC field investigation 
> identified over 50 noise sources and told the utility to fix them all.
>
> It's a crap shoot, then, right?  No, it's worse!  Both of those were the same 
> case in Texas, with two different FCC investigators.  Do you REALLY want to 
> see the FCC enforcing the RFI rules? If so, without ARRL's staff getting and 
> staying involved, it would have been game over after the first investigation.
>
> If FCC enforces, this will ultimately be turned over to multiple field 
> offices, with investigators for which RFI is a sideline at best, and a 
> mystery at worst. We are MUCH better off having 1.5 staff in the ARRL Lab 
> with literally world-class expertise and experience managing these cases, 
> with help from local volunteers, doing all of the legwork and turning cases 
> over to the FCC when necessary.  What ARRL has put together here, in 
> collaboration with FCC and the involved industries, is as good as we are 
> going to get in principle, always improvable in the details.  IMHO, it is a 
> model of consumer/industry/regulator collaboration that will ultimately be 
> adopted in other ways.
>
> Ed Hare, W1RFI
> ARRL Lab
>
> ________________________________
>
> From: RFI <rfi-bounces+w1rfi=arrl.org<http://arrl.org>@contesting.com> on 
> behalf of David Eckhardt<davearea51a@gmail.com>
> Sent: Thursday, May 26, 2022 12:20 PM
> To: Dave (NK7Z)<dave@nk7z.net>
> Cc: Rfi List<rfi@contesting.com>
> Subject: Re: [RFI] Solar Panel RFI Awareness At Dayton
>
> Dave, NK7Z, you hit the nails squarely on the heads in your last email.
>
> Further, those of us who are members of ARRL are paying in our dues (or
> life memberships) what FCC was originally tasked to do, among other tasks
> within CFR47.  ARRL and the amateurs are now the RFI sleuths, especially
> when it comes to home solar power installations.  So, our dues and life
> memberships to ARRL should be tax deductible??
>
> All have read my past rants on FCC shirking the responsibilities spelled
> out in CFR47.  Now we amateurs and ARRL are tasked with some of those
> responsibilities originally defined in  CFR47.  And all for free.......
> Something is wrong with this picture!
>
> Sure, FCC is severely short of funds.  And.,...... maybe ARRL has been
> working with FCC for 20 years on.  But this is no excuse for handing their
> own responsibilities, at no cost, off to a volunteer paid organization of
> members.
>
> Dave - W0LEV
>
> On Wed, May 25, 2022 at 11:24 PM Dave (NK7Z)<dave@nk7z.net>  wrote:
>
>   If only the FCC enforced their own rules, I would agree with you...
>
>   There is very little proactive enforcement happening up in this area,
>   and I suspect elsewhere...
>
>   RFI is rampant, and getting worse, not better.  It is a mindlessly
>   simple task to locate a grow operations in most cases.  Yet the Amateur
>   is the person on the front lines in location, and in first contact with
>   the offender, exposing the Amateur to possible liability, and possible
>   assault.
>
>   The grow ops up here are far too big to be selling in state, which means
>   they are selling out of state, which means they are illegal.  So the FCC
>   is placing the Amateur in the position of possibly dealing with a drug
>   offender...  The real issue is the RFI, not what is being grown, or
>   warmed, or lit...  Just the RFI, but it is still the Amateur that has to
>   knock on the door, and explain what is happening to whoever answers...
>
>   The FCC is ham stringed by not enough funding, so we are the front
>   line...  RFI enforcement has switched from proactive to reactive as a
>   result of lack of funding-- unless you are a cell provider...  Then one
>   call gets instant action, and-- god forbid you even think about starting
>   a pirate FM station...
>
>   In a perfect world, I would report RFI to the FCC, and they would send
>   down a field engineer in a timely manner, locate the RFI, and fine, or
>   warn the perpetrator, then followup with the operator of the device a
>   few weeks later, to ascertain compliance levels.  This would force an
>   overall reduction in the amount RFI, over time as consumers went after
>   the installers, and the manufacturers.
>
>   That is just not happening.  Thus the problem gets worse, not better.
>
>   This is why I say, there is some reasonable level of RFI that the
>   amateur is going to have to accept.  Be it right or wrong, that is the
>   way it is working, and for the foreseeable future going to work.  This
>   is very unfortunate.
>
>   73,
>   Dave,
>   https://www.nk7z.net
>   On 5/25/22 11:26, Jim Brown wrote:
>   On 5/25/2022 1:38 AM, Dave (NK7Z) wrote:
>   Respectfully I am saying that at some point there is a level at which
>   the FCC will say too bad, live with it.  That level will be above what
>   things were before the solar installation arrived.
>
>   FCC Rules say that if a product interferes with licensed radio operation
>   that use of it must be discontinued.
>
>   73, Jim K9YC
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>
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>
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>
>
> --
> *Dave - WØLEV*
> *Just Let Darwin Work*
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