[RFI] ARRL to FCC..

[Hare, Ed W1RFI]

I can shed a bit more light on this, I think.

Many hams have an image of something that has never existed on a regular basis -- the thought that if they had interference, they could call the FCC, which would quickly send out a team to find the source of the noise.  This has never happened on any regular basis and is less likely to happen now.  

Under the FCC's rules, manufacturers of equipment are required to meet certain emissions-limit and labeling requirements. If the manufacturer does, it may market its products. Under these rules, most non-radio devices, other than personal computers, are "Verified" under Part 15 or Part 18 FCC rules, meaning that the manufacturer is required to test them, and to keep test results on file if ever asked for by the FCC.  There are generally higher limits for commercial products than consumer products, and all sellers and marketers of products are required to market them into appropriate environments.

If these rules are met, the operators of devices, ie your electric utility, your neighbor, or even you, are required to use them in a way that does not cause harmful interference to licensed radio users.

Hams can get some support from the FCC, but generally only if the ham is able to identify what the actual source of a product is and who is operating it.  The ARRL and FCC have, over years of time, developed a cooperative program where the FCC will generally ask the ARRL to help with a case, helping to determine what the source is, who is operating it and whether its noise is actually causing "harmful interference" as defined by the FCC's rules.  The FCC does expect that hams will make reasonable efforts to resolve problems with the operator of the device directly, before asking the FCC for help.  If these efforts are not successful, ARRL has been asked to help document the case history and gte the case to the FCC, which after its own review, usually sends an advisory letter to the operator of the device.  The ARRL "power line" program is also used by the FCC as the first steps of a case involving a neighbor.  See the various links under http://www.arrl.org/part-15-radio-frequency-devices for more information.

ARRL also does what it can to try to address problems directly with industry. It has contacts in the cable industry and with a number of major manufacturers, such as AT&T, to deal with UVerse problems, for example. ARRL also sits on a number of major industry committees, keeping a seat at these important tables for Amateur Radio, often serving at the head of the table in leadership roles. At this point, for example, I serve on the Board of Directors of the IEEE Electromagnetic Compatibility Society, as a current member of the EMC Society Standards Development and Education Committee, as past Secretary of that committee and as the current Vice Chair of the ANSI accredited C63 Committee's subcommittee on device immunty, for example. Although this work does not always result in Amateur Radio getting a pristine noise environment, it does ensure that industry is well aware of the needs of Amateur Radio, and that Amateur Radio is a part of the process.  This has often serves us all well, as seen in the recent study of arc-fault-current-inturrupter circuit breakers, where the manufacturer was very open ARRL in part because of the League's involvement with industry. The result was a site visit by the manufacturer, joint testing and a re-design of its products to no longer trip in the presence of typical Amateur signals.

ARRL has been buying and testing various products, finding significant violations of the FCC limits.  Unfortunately, the limits are rather high. This means that a "legal" device in the house next door, perhaps 100 feet away, could generate S7 to S9 noise on HF.  So, the large majority of devices the League has tested have actually met the emissions limits. The interference was then addressed on the basis of harmful interfence.

ARRL does have to make some judgment calls about what products to buy and test, because of limited resources, especially staff time.  So we look for the VERY loud noise, such as grow lights, some battery chargers and the like, then make purchases based on specific complaints in which the offending model numbers can be identified.  We are looking more to the items sold in the big box stores, instead of the occasional eBay seller.  To that end, we need good reports that are based on an actual complaint, with a model still in production and being sold. We can then do as we did with the grow lights and other products along the way and file formal complaints the FCC.  The interference from the eBay item or the 1950s lighting fixture can still be addressed as an individual complaint.

In other cases, ARRL does take a broader approach. When CFLs and LED bulbs came on the scene, the posts about the doom of Amateur Radio were rampant, and to assess the problem, ARRL purchased a large number of products and measured them. As predicted, most complied, although a few problems were identified.  

What the majority of the reports ARRL gets, however, involve an "unknown source." At that point for the most part, trying to identify WHAT is is becomes moot unless the ham can figure out where it is. Without an indentified device operator or model number, the only recourse is to find the actual source and work with a neighbor, then with the ARRL and FCC, to try to get it resolved.

I hope this is all helpful.

73, Ed Hare, W1RFI
ARRL Lab Manager




-----Original Message-----
From: RFI [mailto:rfi-bounces at contesting.com] On Behalf Of Silver, Ward, N0AX
Sent: Wednesday, April 02, 2014 10:10 AM
To: rfi at contesting.com
Subject: Re: [RFI] ARRL to FCC..

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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