[RFI] RFI - A Losing Battle

Dave Cole dave at nk7z.net
Wed Sep 23 14:14:05 EDT 2020


That is a choice the ham made by living in an HOA, and hence, not as 
much of a driver I would expect, as say a ham that does not live in an HOA.

We are in the process of looking for a new place, and there will be no 
HOA, or restrictive CC&Rs, period!

I will also run an RFI test overnight if possible, 
(https://www.nk7z.net/sdr-rfi-survey-p1/), or a full drive around if 
time is short...

73, and thanks,
Dave (NK7Z)
https://www.nk7z.net
ARRL Volunteer Examiner
ARRL Technical Specialist, RFI
ARRL Asst. Director, NW Division, Technical Resources

On 9/23/20 8:54 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 
> <mailto: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 <mailto:dave at nk7z.net>>
>     Sent: Wednesday, September 23, 2020 1:06 AM
>     To: Hare, Ed W1RFI <w1rfi at arrl.org <mailto:w1rfi at arrl.org>>;
>     rfi at contesting.com <mailto: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 <http://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
>     <mailto:arrl.org at contesting.com>> on behalf of
>      > Dave Cole <dave at nk7z.net <mailto:dave at nk7z.net>>
>      > *Sent:* Tuesday, September 22, 2020 5:00 PM
>      > *To:* rfi at contesting.com <mailto:rfi at contesting.com>
>     <rfi at contesting.com <mailto: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 <mailto:w6ya at cox.net>>
>      >> Sent: Wednesday, September 2, 2020 10:54 PM
>      >> To: RFI List<mailto:rfi at contesting.com <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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