[RFI] ARRL to FCC..

Ward Silver hwardsil at gmail.com
Wed Apr 2 10:10:24 EDT 2014


I think Kim has it right here, contrasting PROACTIVE with REACTIVE. When 
we identify screwed-up equipment like ballasts and wireless cameras and 
that sort of thing with a very specific problem and tied to specific 
models and manufacturers, it's straightforward for the FCC to deal with 
the problem in a limited and bounded way, and they usually do.  That's 
why documented evidence is so important in supporting any kind of 
regulatory action.  But just railing against classes of devices creating 
interference is going to go nowhere at the agency level, regardless of 
what the regulations may say or imply.

> You must clearly understand what Ward was told. It punts to "no additional funding for PROACTIVE RFI enforcement," NOT "no funds for RFI enforcement."  The > FCC has finding only for reactive RFI enforcement, not proactive RFI enforcement. Do the have authority? Yes. Do they have the ability to exercise it in
> proactive manner? No.

> What's the solution? Funding and spending authority. Kim N5OP

Exactly.  The FCC currently has no congressional mandate to go out and 
aggressively hassle importers about interference-related issues.  There 
is no reason or incentive for them to pick a fight with industry 
lobbyists over interference to us.  We will be far better off to 
continue to make well-documented cases contesting specific types and 
instances of interference in order to support the general case when an 
opportunity presents itself to do so.  That is why it's important to 
support spectrum defense efforts and why the ARRL Lab's traceable, 
calibrated work on RFI is so valuable.  A solid technical case was the 
foundation for the ARRL being able to prevail on the merits of the BPL 
case.

There will eventually be some recognition by both industry and 
regulators that the RF spectrum is not an infinite ocean into which 
electromagnetic pollution can be harmlessly dumped.  That day is not 
here yet - it usually takes some kind of spectacular incident to get and 
hold the necessary attention to achieve a response.  In the meantime, 
document problems and solutions, educate your representatives (and 
neighbors) about the technical issues and the need for regulatory 
oversight, and support organizations such as the ARRL in their efforts 
to develop and sustain the necessary body of technical work.

73, Ward N0AX


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