[RFI] Tom King's comments on current noise floor inquiry and needed steps to lower it

[Don Kirk]

Hi Rob,

You wrote "We all know the noise floor has been steadily increasing but
getting the people who control our laws and enforcement to act, will
require proof."

I actually said a noise study was not needed (see below) when I made a
formal submission to ET Docket 16-191 last year, and I also said radiated
emissions standards should be implemented for all frequencies (see my
responses to the ET Docket 16-191 question 4 and 1c below):

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4. How should a noise study be performed?
The problem is well known and documented for numerous sources of incidental
radiators, so a noise study is not needed.  It does not matter if the
“overall” noise floor has increased, or if there are discrete frequencies
of interference causing interference on specific frequencies, the end
result is the same (reduced communications capability).

I also provided real life data regarding plasma TV interference from a
distance of 950 feet, variable speed drive data from 0.4 miles as well as
links to some of my web pages that document various forms of interference
that I've tracked down :

*Low Voltage Bookcase Lighting:*

http://sites.google.com/site/bookcaselightsrfi/



*Nintendo after market power supply:*

http://sites.google.com/site/3dspowersupplyrfi/


*HVAC Variable Speed Drive:*

http://sites.google.com/site/broadbandrfi/



*Injection Molding Machine Variable Speed Drive:*

http://sites.google.com/site/rfimetro/



*Power Line Noise:*

http://sites.google.com/site/powerlinenoisehistory/



*Treadmill RFI:*

http://sites.google.com/site/treadmillrfi/

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In my submission I said the following regarding question 1c as follows:

c. If incidental radiators are a concern, what sorts of government,
industry, and civil society efforts might be appropriate to ameliorate the
noise they produce?

·        Mandatory compliance testing, and prompt strict enforcement.

·        Radiated limits (not just conducted limits) for all frequencies.
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The problem is three fold in my opinion as follows: *lack of radiated
emission standards for all frequencies*, compliance testing of devices, and
strict enforcement.  I'm not confident that conducted emissions testing for
frequencies below 30 MHz is adequate as it uses very specific loads which
may or not reflect real life loads.  Also without radiated emission
standards below 30 MHz, how does one determine out in the field if a device
has indeed exceeded an emission level which would then qualify it for
enforcement (right now the allowable radiated limits below 30 MHz don't
exist, and therefore how can there be standardized enforcement out in the
field for frequencies below 30 MHz).

The term "harmful interference" is too vague from an enforcement standpoint
in my opinion but in some cases it might be more strict than the
establishment of a specific radiated emission level.  Nevertheless I feel a
radiated emission standard must be set so one can determine what is and
what is not acceptable when dealing with interference out in the field
(hard numbers to determine when enforcement/corrective action is
mandatory).

Just FYI (and just my opinion),
Don (wd8dsb)