[RFI] Solar Panel RFI Awareness At Dayton

[Hare, Ed, W1RFI]

Actually, Jim, the language in the rules is critically different:

§ 15.5 General conditions of operation.<https://www.ecfr.gov/current/title-47/section-15.5>

(b) Operation of an intentional, unintentional, or incidental radiator is subject to the conditions that no harmful interference is caused and that interference must be accepted that may be caused by the operation of an authorized radio station, by another intentional or unintentional radiator, by industrial, scientific and medical (ISM) equipment, or by an incidental radiator.


(c) The operator of a radio frequency device shall be required to cease operating the device upon notification by a Commission representative that the device is causing harmful interference. Operation shall not resume until the condition causing the harmful interference has been corrected.

So, until the Commission determines that "harmful interference" is occurring, the operator does not have to stop using it.

I have had long talks with the Commission staff about "harmful interference," and they have been crystal clear that not all interference is going to deemed to be actionable.  The median values of man-made noise are typically S6 down to about S2 on HF, depending on frequency, so that moderate level of noise exists in lots of places.  Yes, a ham's location may have once been quiet, but noise comes; noise goes, and if the noise ls below that median value, the Commission has all but told me that it would not consider it actionable, and, as this post started, it would indeed say, "live with it. Hams across the country do."

Look also at the Part 15 definition of harmful interference:

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.

This says  nothing about interference to an individual licensee, but it describes interference that endangers the operating of a service.  I know from the BPL days that is the lawyers get involved, they will take the position that an individual case of RFI is not degrading the entire service, with lots of legal arguments.

The bottom line is that we don't want to force this issue, because it is a lose/lose for everyone.  I have avoided at all costs forcing the FCC to make a decision about harmful interference, because I know we will not like that decision. To keep them engaged, ARRL is working with these manufacturers, to get them to do more than the rules require, because they do not want new rules.  We don't either, because then, the first line of defense by manufacturers will be that they meet the rules.

The vast majority of cases have been resolved.  The manufacturers would like the FCC to get them off the hook on the remainder of cases, but I have persuaded the FCC not to make that determination yet, but to work to try to find better solutions for the remaining cases that seem to require more supression that has been successful for most cases.  I am about to put a few panels on my roof and see what solutions can be designed.

So, be careful what you ask for, because you might get it. The industry doesn't want more rules, but neither do we,, because any levels will be set so high that we will not like them.  The only radiated emissions limits that apply below 30 MHz are for carrier-current devices and intentional emitters, and those limits are a defacto S9.

Keep the cooperation going; it will bet us more than rules and force will ever get us, unless you want to see this all resolved by the lawyers.

Ed Hare, W1RFI


________________________________
From: RFI <rfi-bounces+w1rfi=arrl.org at contesting.com> on behalf of Jim Brown <jim at audiosystemsgroup.com>
Sent: Wednesday, May 25, 2022 2:26 PM
To: rfi at contesting.com <rfi at contesting.com>
Subject: Re: [RFI] Solar Panel RFI Awareness At Dayton

On 5/25/2022 1:38 AM, Dave (NK7Z) wrote:
> Respectfully I am saying that at some point there is a level at which
> the FCC will say too bad, live with it.  That level will be above what
> things were before the solar installation arrived.

FCC Rules say that if a product interferes with licensed radio operation
that use of it must be discontinued.

73, Jim K9YC
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