Agree.
Sent from Yahoo Mail for iPhone
On Friday, July 26, 2024, 4:22 PM, Hare, Ed, W1RFI via RFI <rfi@contesting.com>
wrote:
<Short rebuttal to long essay: the current rules aren't good enough.>
In general, I agree, but changing FCC rules, especially to make unlicensed
emissions limits more stringent, is not the best solution, because it can take
an incredible amount of time and the outcome is not certain. I can say with
certainty that the FCC will never set those limits low enough to prevent all
interference to amateur radio. The political resistance would not be futile.
I could have written a dozen more paragraphs, but one point worth mentioning is
that we now have more interest by OET in these noisy devices. Now that we have
an inroad to report devices that exceed the emissions limits, the Lab can and
will do more testing, once they are identified. And even for otherwise legal
devices, the FCC is taking some action wrt harmful interference. Both types of
FCC contact and cooperation will continue and the Lab staff will continue to
work with industry. ARRL is uniquely positioned to do both.
________________________________
From: David E. Crawford <dcsubs@molniya1.com>
Sent: Friday, July 26, 2024 6:56 PM
To: Hare, Ed, W1RFI <w1rfi@arrl.org>; Mike Fatchett W0MU <w0mu@w0mu.com>;
rfi@contesting.com <rfi@contesting.com>
Subject: Re: [RFI] New ARRL Mission statement > Was solar fix
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Short rebuttal to long essay: the current rules aren't good enough.
On 2024-07-26 09:06, Hare, Ed, W1RFI via RFI wrote:
> First, with respect to noisy devices, there are FCC rules related to the
> amount of noise devices can make. The manufacturers of devices must meet
> these requirements and must use "good engineering practice" (for whatever
> that means.) There are also rules that state that if harmful interference
> occurs to licensed radio services (amateur, CB, broadcast, business, etc.)
> then the operator of the offending device needs to address the interference.
>
> These rules are not intended to prevent all interference, no more so than the
> amateur rules on harmonics emissions are intended to prevent all interference
> to neighboring equipment. To achieve that goal would require many tens of dB
> more suppression, adding considerably to the costs of equipment (amateur gear
> and consumer equipment.) The rules are intended to reduce the likelihood of
> interference to a small-enough incidence of occurrence that it is practical
> to deal with interference on a case-by-case basis. (Amateurs that caused
> interference to nearby over-the-air TV receivers, for example, had to add
> additional filtering to their transmitters, even though they met the
> emissions-limits rules.) The limits also ensure that if there is
> interference, it is local and thus easy to identify, rather than possibly
> coming from over a mile away.
>
> It would be wonderful for the rules to be changed, but that would be nearly
> impossible at worst, and take years of time (as do most FCC proceedings) at
> best. The inadequacy of the rules is most apparent in a few glaring areas.
> First, many devices are categorically exempt from specific emissions limits.
> Conventional electric motors, for example. More important to amateurs,
> devices classified as "appliances" are exempt from emissions limits. This
> would include devices used for cooking, heating, cooling and cleaning.
>
> Also, interference is controlled below 30 MHz by setting limits on the amount
> of noise conducted onto the AC mains. (The premise is that small devices are
> not good HF antennas, but wires connected to them are, and the AC mains are
> long wire antennas that can and do radiate. There are no radiated emissions
> limits below 30 MHz and no limits on the amount of noise that can be
> conducted onto other wiring, such as speaker leads, interconnection wires,
> etc. This worked, sorta', for most devices, but now that we are seeing more
> and more digital wiring in houses and solar systems that have lots of wires
> that are not AC mains, we are seeing the inadequacy of these rules.
>
> The ARRL Lab has done a lot of testing of devices and, based on its testing,
> most of the devices that it has tested have complied with the rules. (For
> reasons described above, interference still does occur.) There have been
> exceptions. When indoor gardening became more popular, some high-powered
> lighting was found to cause interference. The Lab obtained a number of grow
> lights and tested them. Some were found to be as much as 58 dB over the
> emissions limits. (To put that into lay terms, one device was making as much
> noise as 650,000 legal devices.) The Lab reported this to the FCC and
> simultaneously contacted the major importer. The importer ended up
> discontinuing the worst of the models and started adding filtering to its
> product line. This was not an ideal solution, but most of the interference
> problems did get resolved.
>
> The Lab have also worked out a semi-formal process with FCC to get
> interference to amateurs resolved. Although this has not been 100%
> successful, I would estimate the success rate at over 90%, albeit in some
> cases taking years to resolve. In this program, the FCC refers all cases it
> receives to the ARRL Lab. The Lab takes some important steps. It first
> determines that the problem would meet the FCC criteria for harmful
> interference. Interference that is very sporadic would probably not be acted
> on by the FCC, and a ham that goes from S1 to S2 noise is still well below
> the median values of human-made noise, so FCC is not going to see a rules
> violation. The Lab has worked successfully a few cases that do fall into
> both categories, although FCC action is not likely. (The position the Lab
> takes is that if a single source of interference can be reasonably corrected,
> it is reasonable to expect it will be. FCC has followed up on a few of those
> cases with some letters encouraging the parties to fix interference).
>
> The Lab also ensures that the correct source has been identified, following
> step-by-step procedures to ensure that a noisy device in the hams' own homes
> are not blamed on power-line noise, for example. The Lab has found that
> almost half of the reported cases turn out to be something different than the
> ham first thought. ARRL also determines that the involved parties have tried
> to resolve this directly. In some cases, they do. So the ham must talk to the
> involved neighbor, or to his or her power company or other identified utility.
>
> The result of the latter is sometimes effective, sometimes not. If not. ARRL
> contacts the involved parties, with a letter written under the wing of ARRL's
> staff-level agreements with the FCC. The letter explains the rules and what
> needs to be done to correct the problem. This is sometimes effective. If
> not, the Lab now has a well-documented case to turn over to the FCC. The FCC
> Enforcement Bureau evaluates the case and when it almost always agrees with
> ARRL's determination, it follows up with letters to the involved parties. So
> although this process is not 100% perfect, the League and FCC are both doing
> quite a bit to try to move RFI cases forward and resolving quite a number of
> them.
>
> The Lab is just now in the process of developing a similar process to be able
> to more systematically report noisy devices that appear to exceed the limits
> to the FCC Office of Engineering and Technology.
>
> In conjunction with this process, the Lab also maintains significant contact
> with industry. The recent case involving solar interference discussed
> extensively on this reflector is a good example. In this case, Solar Edge did
> make significant improvements to its product, resolving over 500 cases of
> interference known to date, this system continued to make noise. Tesla was
> also involved, with the battery chargers. At first, Tesla did not get
> involved, but, as a result of communications from ARRL, Solar Edge and FCC,
> it ultimately sent an EMC engineer to look at the system and an effective
> solution was put into place.
>
> As an aside to this, the League is also implementing local RFI teams of
> volunteers, and supporting teams that have sprung up spontaneously. This is
> being built into a national program and the Lab may ultimately recommend that
> this become an official ARRL function.
>
> No, it doesn't stop there. The League is also involved heavily with industry.
> It serves as a voting member on the US C63 EMC Committee that writes industry
> standards often incorporated into the FCC rules by reference. Lab staff are
> also involved heavily with the IEEE EMC Society, serving as a member of its
> standards board, overseeing the development of industry standards on EMC.
> These are not seats at the back of the room. In my time serving in that
> role, I was elected to the EMC Society Board of Directors and then elected by
> that Board to be its Vice President for Standards. On C63, I served as the
> Chair of Subcommittee 5 on Immunity. This work has been effective, because
> for a number of years, interference by amateur radio to other equipment has
> become more and more rare.
>
> The League also funded a consultant to help the IEEE write a standard on the
> procedures electric utilities should use to resolve power-line noise. This
> standard is the first of its kind and can serve as a model for similar
> standards involving solar-system noise, for example. Std. 1897-2024 is now
> available from the IEEE and my guess is that it will be widely adopted and
> used, especially if FCC letters to utilities point to it.
>
> So, the question was asked: When will we see the ARRL doing something to
> address noise. This has all been happening for over a decade, much of it
> reported in bits and pieces. So, yes, the question is correct. When will
> hams see what is being done and continue to support the continuation and
> expansion of these programs. Keep in mind that most of this has been done by
> one or two HQ staffers, who also have numerous other responsibilities, so I'd
> say that it's a mean and lean machine doing good for amateur radio.
>
> Ed Hare, W1RFI
> ARRL Lab Manager 1987-2023
> Current ARRL Lab Volunteer
>
> From: RFI <rfi-bounces+w1rfi=arrl.org@contesting.com> on behalf of Mike
> Fatchett W0MU <w0mu@w0mu.com>
> Sent: Thursday, July 25, 2024 11:04 PM
> To: rfi@contesting.com <rfi@contesting.com>
> Subject: [RFI] New ARRL Mission statement > Was solar fix
>
> The ARRL today release a new Mission statement. 2nd on the list is
> protection of Ham Radio. I am very curious to see what that plan is.
> Does it include stopping/reduction RFI emission from devices that
> continue to pollute the ham bands making harder and harder for people to
> enjoy the hobby? Is that enough to get the FCC to start actually doing
> their job?
>
> W0MU
>
>
>
>> 73, Pete N4ZR
>>
>> On 7/25/2024 3:42 PM, David Colburn wrote:
>>> You made it 'political'.
>>>
>>> This has nothing to do with a constitutional-conservative preference for
>>>
>>> less government and more liberty.
>>>
>>> It has to do with corruption by monopolies and the relocation of funds
>>>
>>> from enforcement to enabling-profit of corporations that donate to the
>>>
>>> Party-in-power. (Consider who that was for the past 16 years -
>>> there's been
>>>
>>> no push for "small government" for at least 12 of the 16, and
>>> precious little
>>>
>>> the other 4.)
>>>
>>> If it were about "small government" the FCC would have a smaller budget
>>>
>>> and clearly-defined priorities - which would include keeping the
>>> spectrum
>>>
>>> clean.
>>>
>>> IMHO, YMMV ... KD4E
>>>
>>>
>>> On 7/25/24 14:22, David Eckhardt wrote:
>>>> They're gone in the name of "small government".
>>>>
>>>> I do not consider this political, please, it's reality.
>>>>
>>>> I'll attempt to keep my fingers off the keyboard in the future
>>>> addressing
>>>> this issue.
>>>>
>>>> Dave - WØLEV
>>>
>>> _______________________________________________
>>> RFI mailing list
>>> RFI@contesting.com
>>> http://lists.contesting.com/mailman/listinfo/rfi
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--
-----------------
David E. Crawford
Indian River City
Florida Libre
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