[RFI] FCC Complaint Filing

[Eddie Edwards]

We just did a kitchen remodel here that replaced our ceiling lights with new Lithonia wafer-thin LED lighting with external SMPS boxes that created strong RF noise strongest on 30 meters.  I didn't like the way they were physically installed (made replacement messing and difficult) so rather than adding ferrites I had them removed and replaced with standard recessed cans for standard flood lights (LED or incan.) with plenty of room for adding ferrite filters latter myself if needed.  

I could not talk the contractor's electrician into installing or inserting my pre-wired ferrites while he was installing them because they were "not UL listed" devices but home-brewed instead.  Perhaps Brad's neighbor has run into the same problem if he tried hiring an electrician to add ferrites?  Perhaps the electrician told him they weren't safe to use?  It could be something like this that made the neighbor change his mind.  

I have one question related to Mike Martin's comment what is legal to manufacture and what is not.   My understanding is it's a Part 15 violation if it causes harmful interference, but not necessarily a violation if it has a poor design without what we consider proper filtering.  Am I incorrect?  

I know there are RF noise level limits that are set by the FCC (probably in Part 15 and other regs), but devices that are able to meet those levels can still cause harmful interference especially in the HF bands with higher allowed limits.  The reason for higher HF limits is probably similar to the old TVI problems back in the pre-cable TV era.  TV manufacturers were not required to added high pass filters to all TVs was because not every TV set would be located near a ham radio station.  

FCC didn't want to force TV makers to all spend possibly millions of dollars on millions of TV sets to resolve a small number of problems that are not happening in every TV set location.  However, if the ham did cause TVI back then, FCC forced quiet RF hours until the TVI was resolved by adding the high pass filters to TV set and low pass filter to the ham station.  

With TVI fading into history, now the RFI is in the other direction.  But the FCC lawyers probably see it the same way: why force the costs of additional RF filters on all lights that probably meet Part 15 limits without filters and when 99.999% of them are not located near a radio station receiver?  

In this case we need Part 15 enforcement today just like we had in the TVI days: RF quiet periods until filters are added!   Unfortunately, the FCC lawyers today don't respond the same for hams as it did for TV viewers probably because of the lower numbers of hams or the lower financial impact.  

73, de ed -K0iL


-----Original Message-----
From: RFI <rfi-bounces at contesting.com> On Behalf Of Michael Martin
Sent: Friday, November 22, 2019 07:59
To: n8gls at arrl.net
Cc: rfi at contesting.com
Subject: Re: [RFI] FCC Complaint Filing
Importance: High

Hello Brad,
Well it sounds like you've proven the cause. One of the things I like to do when approaching the owner of the offending source, is to have a radio in my hand that will display the noise. In your case I would approach the door with a clear radio station, maybe FM, and at a very low levels and as I'm talkin turn the volume up just slightly so they can hear the clear radio station. Then say this is a really clear station but let me show you this and hopefully through a memory channel in the radio or just tune to the am frequency where the noise is being displayed and say quote this is the noise I get on my equipment well your lights are on and then turn it up slightly so he can hear it so they get a better example as to what you're dealing with sometimes it's very convincing actually most of the time it's very convincing. Saying that all I'm interested in is being able to use my equipment without interference. It's unfortunate that he has the originator and source of the interference and you understand it isn't his fault that he has that but the manufacturer that built it build it without filtering and that is a violation of FCC rules and regulations and you're willing to help him install those filters to get rid of it that they should have installed.
I'd still like to know what area you are in?
Best wishes