[RFI] A LOSING BATTLE

[Hare, Ed W1RFI]

Hi, Dave,

A few amateurs have directly engaged the FCC.  If they do so in a professional and respectful way, this really doesn't cause much harm, although over decades of time, ARRL staff have managed to have built a relationship with the right people that, for the most part, do make reasonable decisions.  To get there, though, ARRL did have to agree to undertake a lot of work, to work directly with the amateur, to ensure that the case really is interference, that the correct source has been identified and that reasonable efforts have been made to try to resolve the problem directly by the involved parties.

Unfortunately, by the time cases get to us, whether directly by the ham or through the FCC, relationships with neighbors and utilities have often been rather, well, tense and cooperation can sometimes be difficult.  The FCC has helped there quite a bit, but that, too, is a political tightrope, because the little old lady whose only joy is watching TV on a large-screen TV causing interference is going to get a lot more sympathy than a ham-radio operator that no one understands. FCC fears that the little old lady or someone on her behalf will go to their Congressperson or Senator and add a political layer to the whole case.  Keep it neighborly! We have had hams trespass with test equipment  into backyards when neighbors aren't home, caught on security cameras, which really and truly made our work with the FCC a lot harder.  Yes, the FCC staff we know understands that not all hams will be appropriate, so they keep the program going, but that really has to be the exception rather than the rule, because one word from the Commissioners or Bureau Chief could be disastrous.

When hams directly approach the FCC, they may get to the people in the FCC Call Center.  This results in stock answers, often the same ones that the FCC gives regular RFI complaints, because only Amateur Radio has an informal agreement with FCC staff to do more than simply provide information.  They may get to field offices, which we have seen make wildly inaccurate investigations and decide things like the inability to find the source proves that it is not harmful interference.  We need to get these cases to the people that know our process, know how to handle things in a way that does resolve a number of cases, although it can take an extraordinary long time.

The easy ones for us are S9 noise from power companies.  The ones from other businesses are a bit tougher.  Interference from neighbors is harder yet, and the really tough nut to crack is that interference that is very real to the ham, but below the unspoken threshold that we believe the FCC will deem to be harmful interference.  We, and the FCC staff we work with, try to avoid that decision, because they can and do send letters that encourage cooperation, even in cases where is it probable that FCC might decide to just close the case.

As I said, for these marginal cases, it may be needed for the ham to do a lot of legwork to identify the source.  If you have S4 noise that used to be S2 and the source is a power-line problem a mile away, honestly, the power company won't be able to find it.  They may not have it register on their instrumentation, designed to find serious problems. They may find a closer source that doesn't propagate down the line, maybe fix it, and then conclude that the ham will never be satisfied.  If, on the other hand, the ham correctly locates that pole, they usually will fix it, or respond to the FCC letter we can ask be sent if they don't respond initially.

This is not the case of ARRL being high and mighty thinking it knows best, because, after 20 years of fine tuning these processes, finding and keeping the right FCC staff to work on this, that experience really is going to be more effective than a ham that may or may not understand all the legal, social and political issues that make RFI to licensed users more than a technical problem.

Ed Hare, W1RFI
ARRL Lab Manager


________________________________
From: RFI <rfi-bounces+w1rfi=arrl.org at contesting.com> on behalf of David Eckhardt <davearea51a at gmail.com>
Sent: Tuesday, September 22, 2020 7:14 PM
To: Rfi List <rfi at contesting.com>; rfi-owner at contesting.com <rfi-owner at contesting.com>; rfi-request at contesting.com <rfi-request at contesting.com>
Subject: [RFI] A LOSING BATTLE

If I read between the lines and, in summary, the first contact should be
with the ARRL.  They (still) have the capability of working on a technical
basis with the amateurs and, most importantly, still have the ear of the
FCC when required.  We DO NOT,...N O T.... want to spoil that
relationship!!!

I've been at this (losing) battle as an EMC/RFI engineer professionally for
nearly 40-years.  I've seen the changes and experienced the RF Fog caused
by the 'digital revolution'.  No war stories here, but you might want to
read the last paragraph of my QRZ page, WØLEV.

FCC has set regulatory limits which should legally be honored.  Yes, these
limits *do* precipitate problems for the typical amateur living in the
cities.  Problem is, these days, China has shown by example that cheating
gains sales, legal or not (how many labels do you want?).  Other upstanding
US suppliers have taken notice and are following suit.  Per in-place FCC
rules, these offenders are not being pursued as they should.  The burden of
proof falls on us EMC/RFI engineers.  There aren't enough of us nor do we
have the clout with the FCC (and cheating lab tests- if any - from China)
that we should.  FCC USED to do this function.  No longer.  All they're
left with is enforcement, which they do not accomplish in a responsible
manner (my editorial comment on the process).

But we amateurs need to recognize there are limits in place that should,
legally, be adhered to.  The honor system (self declaration and Customs
inspections) is not working with the incursion of a multitude of electronic
'toys' and SMPS's from China and the precedents set by China (and others)
in ignoring the rules.

Dave - WØLEV
EMC Design & Test, LLC
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