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Re: [RFI] New ARRL Mission statement > Was solar fix

To: Mike Fatchett W0MU <w0mu@w0mu.com>, "rfi@contesting.com" <rfi@contesting.com>
Subject: Re: [RFI] New ARRL Mission statement > Was solar fix
From: "Hare, Ed, W1RFI via RFI" <rfi@contesting.com>
Reply-to: "Hare, Ed, W1RFI" <w1rfi@arrl.org>
Date: Sun, 28 Jul 2024 11:57:32 +0000
List-post: <mailto:rfi@contesting.com>
<While getting the FCC to change may be hard, I think we need to try.
Just because it is hard does not mean we look away.  If we had that
attitude with the moon I guess we may never have gone there.>

I agree.  My comments were not intended to say that "we can't do it," but that 
changing the rules is probably the most difficult – and time consuming – 
solution to change.   As I said, resistance will not be futile.

Rules changes will not happen until FCC believes they are necessary.  The first 
step in moving FCC to that conclusion is to make them more and more aware of 
the impact of the present rules. With recent increased interest by OET and the 
FCC Regional Directors, that process is beginning to bear some fruit.  It will 
take more.

Ed

________________________________
From: RFI <rfi-bounces+w1rfi=arrl.org@contesting.com> on behalf of Mike 
Fatchett W0MU <w0mu@w0mu.com>
Sent: Saturday, July 27, 2024 12:52 PM
To: rfi@contesting.com <rfi@contesting.com>
Subject: Re: [RFI] New ARRL Mission statement > Was solar fix


The the lab is doing great for the resources it has.  No question.  No
complaints.  Thank you!

While getting the FCC to change may be hard, I think we need to try.
Just because it is hard does not mean we look away.  If we had that
attitude with the moon I guess we may never have gone there.

"We choose to go to the moon in this decade and do the other things, not
because they are easy, but because they are hard, because that goal will
serve to organize and measure the best of our energies and skills,
because that challenge is one that we are willing to accept, one we are
unwilling to postpone, and one which we intend to win, and the others,
too."  JFK 1962

This is the attitude that we must take.  We cannot hope that individuals
will be able to solve this issue.  It is getting to the point if one is
serious about noise that they locate a station where cities and towns
sit in areas where there is little activity.  If you want to move near
Denver you will want to keep Denver and the suburbs to the west and
south as you want to minimize noise toward EU, JA.

I have to beam right over the metro area to EU and JA to some extent.
It continues to get worse not better.  I am sure some fine OM will tell
me to move.  Easier said than done.

We need to shoot for the moon knowing we might settle for less but less
is better than doing nothing.

W0MU

On 7/26/2024 11:52 PM, Dave (NK7Z) wrote:
> I can attest to how useful the ARRL lab has bee n for me...  I had a
> long term issue with an indoor garden.  I carefully documented things
> to Steve Anderson's liking, provided both movies, and tapes of the
> issue, including how DFing was performed, and with what gear.  A
> letter soon followed to the home owner, (it was a rental), and the
> issue ended one day shortly after the letter was sent.  After five
> years of not being able to use 40 meter, I have now had five years of
> being able to use 40 again...  I can't thank the ARRL enough for
> this.  I was very reticent to contact the person living in the rental
> as the place looked very sketchy...
>
> 73, and thanks,
> Dave (NK7Z)
> https://www.nk7z.net
> ARRL Volunteer Examiner
> ARRL Technical Specialist, RFI
> ARRL Asst. Director, NW Division, Technical Resources
> I never learned from a man who agreed with me. (HeinLein)
>
> On 7/26/24 16:27, martin glazer via RFI wrote:
>> 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
>>
>> [You don't often get email from dcsubs@molniya1.com. Learn why this
>> is important at https://aka.ms/LearnAboutSenderIdentification ]
>>
>> 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
>>>>>
>>>>> _______________________________________________
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>>
>> --
>> -----------------
>> David E. Crawford
>> Indian River City
>> Florida Libre
>> -----------------
>>
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