If I read between the lines and, in summary, the first contact should be
with the ARRL. They (still) have the capability of working on a technical
basis with the amateurs and, most importantly, still have the ear of the
FCC when required. We DO NOT,...N O T.... want to spoil that
relationship!!!
I've been at this (losing) battle as an EMC/RFI engineer professionally for
nearly 40-years. I've seen the changes and experienced the RF Fog caused
by the 'digital revolution'. No war stories here, but you might want to
read the last paragraph of my QRZ page, WØLEV.
FCC has set regulatory limits which should legally be honored. Yes, these
limits *do* precipitate problems for the typical amateur living in the
cities. Problem is, these days, China has shown by example that cheating
gains sales, legal or not (how many labels do you want?). Other upstanding
US suppliers have taken notice and are following suit. Per in-place FCC
rules, these offenders are not being pursued as they should. The burden of
proof falls on us EMC/RFI engineers. There aren't enough of us nor do we
have the clout with the FCC (and cheating lab tests- if any - from China)
that we should. FCC USED to do this function. No longer. All they're
left with is enforcement, which they do not accomplish in a responsible
manner (my editorial comment on the process).
But we amateurs need to recognize there are limits in place that should,
legally, be adhered to. The honor system (self declaration and Customs
inspections) is not working with the incursion of a multitude of electronic
'toys' and SMPS's from China and the precedents set by China (and others)
in ignoring the rules.
Dave - WØLEV
EMC Design & Test, LLC
On Tue, Sep 22, 2020 at 7:39 PM Hare, Ed W1RFI <w1rfi@arrl.org> wrote:
> Yes, we might all benefit from a “new agency,” but this is not going to
> happen, so we will continue to do the best we can.
>
> To really understand this problem, we need to look at Sec. 15.3 closely.
> Here is the definition of “harmful interference.” The emphasis is added.
>
> (m) Harmful interference. Any emission, radiation or induction that
> endangers the functioning of a *radio navigation service or of other safety
> services* -- or -- seriously degrades, obstructs or repeatedly interrupts a
> radiocommunications *service* operating in accordance with this chapter.}
>
> Note that the criteria for protecting a radio navigation services or
> safety service is different than for other services.
>
> Note also that the definition talks about degradation to a service, NOT to
> an individual communication within that service.
>
> Yes, S7 noise would be harmful interference if it were taking place over
> an S6 signal, although amateurs are quite capable of digging signals out of
> the noise. But S2 noise would be harmful to an S1 signal and there is
> simply no way that the FCC is going to deem S2 noise to be harmful
> interference and, depending on the person at the FCC asked to make the
> determination, S7 noise could be dismissed as being interference, but not
> harmful interference as defined in the rules because other operators in the
> *service* are able to carry out the desired communication. Even when
> applied down to the individual operator, as it usually is, the same “not
> harmful interference” conclusion can be reached. ARRL has seen an FCC field
> agent unable to find noise deem S9 noise to not be harmful interference
> because he couldn’t find the noise and the amateur could still hear some
> signals. We got that one sorted out, but this is the risk we run when we
> start demanding the FCC enforce rules. In this case, the amateur did an end
> run around our processes and ended up getting a local field agent out to do
> something about the case, when to that agent, the most expeditious thing to
> do is whatever could close the case.
>
> We do NOT want the FCC to draw a line in sand, because if it did, the FCC
> will draw a line that we don’t like. If anything, the FCC will draw a line
> that is based on the median values of man-made noise described in the ITU-R
> Recommendation P372.14, and that typically would be S5 to S7 on HF. We are
> much better off not drawing that line and allowing the FCC to tailor
> advisory letters and degree of response to the degree of interference.
> Yes, we can get the FCC to act when a power company creates S9 noise, but
> if that noise were S3 from a mile away, the FCC is not likely to act past
> that advisory letter, so in that case, the ham better find the pole that
> the utility will never find and the ham, ARRL and the FCC can usually
> convince the utility to fix it. The biggest problems we face wrt
> interference cases are the utilities and/or neighbors not knowing how to
> find noise sources, finding the wrong ones or, worse, a non-cooperating
> responsible party.
>
> In many cases, these are neighborhood disputes that have been made worse
> by the involved amateurs. Neighbors, most business operators and some
> utilities do not understand the complex issues we disagree over on this
> forum. Hams need to understand this lack of knowledge and not ride the
> high horse but walk the high road. For those “marginal” interference
> cases, although the FCC may write an advisory letter, if the neighbor or
> utility are given reasons not to cooperate, the problem won’t get fixed and
> the FCC will possibly not back the ham with a finding of harmful
> interference. In almost all cases, if actions can secure cooperation,
> cooperation and help from ARRL staff to the utility, neighbor or ham will
> be a more effective solution than taking a crap shoot with the FCC.
>
> Ed, W1RFI
>
>
>
>
>
> Sent from Mail<https://go.microsoft.com/fwlink/?LinkId=550986> for
> Windows 10
>
> From: Jim McCook<mailto:w6ya@cox.net>
> Sent: Wednesday, September 2, 2020 10:54 PM
> To: RFI List<mailto:rfi@contesting.com>
> Subject: [RFI] RFI - A Losing Battle
>
> There is a lot here that doesn’t make any sense to me.It appears to be a
> fantasy that there is a FCC regulation to prevent harmful interference
> to licensed radio communication.Interference is interference.S-7 noise
> is harmful when the signal interfered with is S-6.If the signal is S-3
> and the offending noise is S-4, it is exactly the same situation.All
> these special rules for different devices, incidental radiators,
> unintentional radiators, intentional radiators, ad nauseam, concern
> devices that need NOT cause interference above or below 30 MHz _if
> properly designed_.We all know “FCC Compliance” is a joke where lobbying
> and politics rule. It appears on a label that may have come from a
> roll of labels printed in China and slapped onto electronic garbage that
> indeed causes RFI.The switching power supply for my K3 sits inches from
> the radio._It creates NO RFI_.
>
> Government (FCC) is supposed to be working FOR US, but what really
> happens is that FCC obviously has abandoned Part 15.3 (n) when it comes
> to Amateur Radio.Ed and Paul at ARRL make a huge effort to help hams by
> picking up the void left by FCC that has placed ridiculous limits
> allowing interference to occur unless that interference reaches a
> certain arbitrarily determined signal level, never mind that it DOES
> cause interference to amateur radio. This responsibility should NOT be
> on the shoulders of ARRL. It is a HUGE burden.
>
> A different agency consisting of _engineers and enforcement_ is needed
> to replace FCC that can properly deal with amateur radio interference.It
> should be funded by our tax money that is being thrown away on many
> foolish, wasteful political agencies.Until this happens we will continue
> to slowly lose our HF spectrum due to rapidly increasing sources of
> devastating RFI.We are rapidly losing this battle.
>
> Jim W6YA
>
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--
*Dave - WØLEV*
*Just Let Darwin Work*
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