[RFI] RFI - A Losing Battle

Wed Sep 23 12:29:10 EDT 2020

The bets advice I've heard in this regard is the cautionary "Could be 
arcing or overheating," because it truly *could* be (you don't yet 
know).  Then, you're doing them a favor!

Kim N5OP

On 9/23/2020 10:54 AM, Richard F DiDonna NN3W wrote:
> One issue that pops up in terms of enforcement is the ability to even make
> a complaint - especially with respect to neighbors.  If you live in a HOA,
> your ability to demand changes to a neighbor's RF emitting devices gets
> kind of diminished given the fact that many amateurs aren't supposed to
> even have antennas with which they can hear the RFI in the first place.
>
> 73 Rich NN3W
>
> On Wed, Sep 23, 2020 at 11:08 AM Hare, Ed W1RFI <w1rfi at arrl.org> wrote:
>
>> Part of the problem is that "enforcement" of harmful interference is
>> handled by the Enforcement Bureau, which we have working somewhat well.
>> The emissions and marketing violations are enforced by the Office of
>> Engineering and Technology, which knows of us, holds ARRL in high esteem,
>> but we haven't worked out a process like we have with EB.  I think I can
>> get that to change.
>>
>> Ed
>>
>>
>>
>> -----Original Message-----
>> From: Dave Cole <dave at nk7z.net>
>> Sent: Wednesday, September 23, 2020 1:06 AM
>> To: Hare, Ed W1RFI <w1rfi at arrl.org>; rfi at contesting.com
>> Subject: Re: [RFI] RFI - A Losing Battle
>>
>> How can I help set this up Ed?  I 100% agree...  You all handed the FCC an
>> open and shut case with Home Depot, and as far as I know, nothing ever
>> happened...  That does not bode well for enforcement...
>>
>> 73, and thanks,
>> Dave (NK7Z)
>> https://www.nk7z.net
>> ARRL Volunteer Examiner
>> ARRL Technical Specialist, RFI
>> ARRL Asst. Director, NW Division, Technical Resources
>>
>> On 9/22/20 4:58 PM, Hare, Ed W1RFI wrote:
>>> Yeah, although we do get the FCC to do some enforcement anyway.
>>>
>>> What is needed is a campaign to identify aggregious devices and report
>>> them to the FCC.  ARRL has filed a few complaints about illegal
>>> devices, but until that turns into a number of cases, it is hard to
>>> get more than staff-level cases.  Just as we got that underway, W1MG
>>> retired and it took a while to get W1VLF into the role.  He hit the
>>> ground running, but actual cases keep him pretty busy. We did get
>>> started with testing devices for compliance, even without a fully
>>> certified lab to to do, although we do duplicate the ANSI C63 test
>>> methodology the FCC specifies in the rules. It certainly is good
>>> enough testing to justify a complaint, considering that we give a
>>> number of dB leeway. I want cases that will pass all muster when we can
>> go live with this.
>>> COVID-19 ground that to a halt, as ARRL staff had to work remotely
>>> only, then had to comply with only 50% occupancy and other requirements.
>>>
>>> Still, we are preparing to re-engage this at our earliest opportunity.
>>> We need to identify devices, though.  To file a complaint, we have to
>>> buy one on the open market, from a US seller, test it, document the
>>> tests and get a formal complaint filed.  W1VT identified over 10,000
>>> potential emitters on the walmart.com site alone, so there is simply
>>> no way to test them all.  The hard part of this is that the limits are
>>> too high to please any of us, so device causing S7 noise from the
>>> house next door may well be in compliance. It can still be harmful
>>> interference, but if we are talking filing complaints against illegal
>>> devices, we need, well... actual illegal devices.
>>>
>>> We did this with grow lights and found two models, similar, so
>>> probably the same PC board, 58 dB over the FCC limits.  Translation:
>>> One device was creating as much noise as 650,000 legal devices.  (That
>>> is not a typo -- QST figured it was and changed it to 650! lol!)  We
>>> tested LED bulbs from the big box stores and found them all in
>>> compliance, although the next batch may or may not be the same.
>>>
>>> Ed, W1RFI
>>>
>>>
>>> ----------------------------------------------------------------------
>>> --
>>> *From:* RFI <rfi-bounces+w1rfi=arrl.org at contesting.com> on behalf of
>>> Dave Cole <dave at nk7z.net>
>>> *Sent:* Tuesday, September 22, 2020 5:00 PM
>>> *To:* rfi at contesting.com <rfi at contesting.com>
>>> *Subject:* Re: [RFI] RFI - A Losing Battle Perhaps the FCC will use
>>> that $50.00 per renewal they are talking about to perform RFI
>>> enforcement?
>>>
>>> Sorry, I had too...  :)
>>>
>>> 73, and thanks,
>>> Dave (NK7Z)
>>> https://www.nk7z.net
>>>
>>>
>>> On 9/22/20 12:39 PM, Hare, Ed W1RFI wrote:
>>>> Yes, we might all benefit from a "new agency," but this is not going to
>> happen, so we will continue to do the best we can.
>>>> To really understand this problem, we need to look at Sec. 15.3
>> closely.  Here is the definition of "harmful interference."  The emphasis
>> is added.
>>>> (m) Harmful interference. Any emission, radiation or induction that
>>>> endangers the functioning of a *radio navigation service or of other
>>>> safety services* -- or -- seriously degrades, obstructs or repeatedly
>>>> interrupts a radiocommunications *service* operating  in accordance
>>>> with this chapter.}
>>>>
>>>> Note that the criteria for protecting a radio navigation services or
>> safety service is different than for other services.
>>>> Note also that the definition talks about degradation to a service, NOT
>> to an individual communication within that service.
>>>> Yes, S7 noise would be harmful interference if it were taking place
>>>> over an S6 signal, although amateurs are quite capable of digging
>>>> signals out of the noise.  But S2 noise would be harmful to an S1
>>>> signal and there is simply no way that the FCC is going  to deem S2
>>>> noise to be harmful interference and, depending on the
>>> person at the FCC asked to make the determination, S7 noise could be
>>> dismissed as being interference, but not harmful interference as
>>> defined in the rules because other operators in the *service* are able
>>> to carry out the desired communication.   Even when applied down to
>>> the individual operator, as it usually is, the same "not harmful
>>> interference" conclusion can be reached. ARRL has seen an FCC field
>>> agent unable to find noise deem S9 noise to not be harmful
>>> interference because he couldn't find the noise and the amateur could
>>> still hear some signals. We got that one sorted out, but this is the
>>> risk we run when we start demanding the FCC enforce rules. In this
>>> case, the amateur did an end run around our processes and ended up
>>> getting a local field agent out to do something about the case, when
>>> to that agent, the most expeditious thing to do is whatever could close
>> the case.
>>>> We do NOT want the FCC to draw a line in sand, because if it did, the
>>>> FCC will draw a line that we don't like. If anything, the FCC will
>>>> draw a line that is based on the median values of man-made noise
>>>> described in the ITU-R Recommendation P372.14, and that  typically
>>>> would be S5 to S7 on HF.  We are much better off not drawing
>>> that line and allowing the FCC to tailor advisory letters and degree
>>> of response to the degree of interference.  Yes, we can get the FCC to
>>> act when a power company creates S9 noise, but if that noise were S3
>>> from a mile away, the FCC is not likely to act past that advisory
>>> letter, so in that case, the ham better find the pole that the utility
>>> will never find and the ham, ARRL and the FCC can usually convince the
>>> utility to fix it. The biggest problems we face wrt interference cases
>>> are the utilities and/or neighbors not knowing how to find noise
>>> sources, finding the wrong ones or, worse, a non-cooperating responsible
>> party.
>>>> In many cases, these are neighborhood disputes that have been made
>>>> worse by the involved amateurs. Neighbors, most business operators
>>>> and some utilities do not understand the complex issues we disagree
>>>> over on this forum.  Hams need to understand this lack  of knowledge
>>>> and not ride the high horse but walk the high road.  For
>>> those "marginal" interference cases, although the FCC may write an
>>> advisory letter, if the neighbor or utility are given reasons not to
>>> cooperate, the problem won't get fixed and the FCC will possibly not
>>> back the ham with a finding of harmful interference.  In almost all
>>> cases, if actions can secure cooperation, cooperation and help from
>>> ARRL staff to the utility, neighbor or ham will be a more effective
>>> solution than taking a crap shoot with the FCC.
>>>> Ed, W1RFI
>>>>
>>>>
>>>>
>>>>
>>>>
>>>> Sent from Mail<https://go.microsoft.com/fwlink/?LinkId=550986> for
>>>> Windows 10
>>>>
>>>> From: Jim McCook<mailto:w6ya at cox.net>
>>>> Sent: Wednesday, September 2, 2020 10:54 PM
>>>> To: RFI List<mailto:rfi at contesting.com>
>>>> Subject: [RFI] RFI - A Losing Battle
>>>>
>>>> There is a lot here that doesn't make any sense to me.It appears to
>>>> be a fantasy that there is a FCC regulation to prevent harmful
>>>> interference to licensed radio communication.Interference is
>>>> interference.S-7 noise is harmful when the signal interfered with is
>>>> S-6.If the signal is S-3 and the offending noise is S-4, it is
>>>> exactly the same situation.All these special rules for different
>>>> devices, incidental radiators, unintentional radiators, intentional
>>>> radiators, ad nauseam, concern devices that need NOT cause
>>>> interference above or below 30 MHz _if properly designed_.We all know
>>>> "FCC Compliance" is a joke where lobbying and politics rule.   It
>>>> appears on a label that may have come from a roll of labels printed
>>>> in China and slapped onto electronic garbage that indeed causes
>>>> RFI.The switching power supply for my K3 sits inches from the radio._It
>> creates NO RFI_.
>>>> Government (FCC) is supposed to be working FOR US, but what really
>>>> happens is that FCC obviously has abandoned Part 15.3 (n) when it
>>>> comes to Amateur Radio.Ed and Paul at ARRL make a huge effort to help
>>>> hams by picking up the void left by FCC that has placed ridiculous
>>>> limits allowing interference to occur unless that interference
>>>> reaches a certain arbitrarily determined signal level, never mind
>>>> that it DOES cause interference to amateur radio. This responsibility
>>>> should NOT be on the shoulders of ARRL.  It is a HUGE burden.
>>>>
>>>> A different agency consisting of _engineers and enforcement_ is
>>>> needed to replace FCC that can properly deal with amateur radio
>>>> interference.It should be funded by our tax money that is being
>>>> thrown away on many foolish, wasteful political agencies.Until this
>>>> happens we will continue to slowly lose our HF spectrum due to
>>>> rapidly increasing sources of devastating RFI.We are rapidly losing
>> this battle.
>>>> Jim W6YA
>>>>
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-- 

Kim Elmore, Ph.D. (Adj. Assoc. Prof., OU School of Meteorology, CCM, PP 
SEL/MEL/Glider, N5OP, 2nd Class Radiotelegraph, GROL)

/"A great second violinist plays second fiddle to no one." //– Robert C. 
Marsh, Chicago Sun-Times./