[RFI] ARRL to FCC..

[Paul Christensen]

Kim N5OP >

"What's the solution? Funding and spending authority."

I think a more accurate assessment is "funding and spending priority."  The
Commission has adequate funding, but that funding is not prioritized on the
instant issues.  If any of us analyzed the Commission's budget in detail --
and managed it in ways akin to that of private enterprise, I think we could
easily refute the "no funding" position.

Stating "no funding" is a red herring and an easy way out of dealing with
real issues.  All too often the public allows it instead of demanding better
efficiencies.  I work with federal agencies on a daily basis (primarily DHS
and U.S. DOL).  For nearly every solvable issue that gets in the way of case
adjudication, my lawyer counterparts are told the same story: inadequate
funding.  It's a great way to just "shut us up."

Ward, N0AX >

"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."

I agree with Ward on this although there was once a Commission that required
no Congressional mandate to aggressively regulate the production and
importation of unintential radiators.  It's been allowed to become such a
large issue in numbers that absent the complaint process, managing the
enforcement of existing devices is nearly impossible.  Ignoring a problem is
a whole lot easier than managing it -- until the day comes as Ward cites
when "...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, I'm afraid, will
not occur until there's some catastrophic event that is traced to a noisy
unintentional radiator.

Even if we applied stricter language to Part 15, how would the U.S.
Government enforce the standards of small imported, noisy consumer products
from Asia, many of which are purchased direct from a seller through on-line
channels like eBay?  We can punish those involved in the U.S. as well as
larger entities out of the U.S., but it's impossible to extend the reach to
the thousands of small companies and individuals involved out of the U.S.

Paul, W9AC