[RFI] DEFINITION OF "HARMFUL INTERFERENCE"

[Hare, Ed, W1RFI]

This all actually started with Riley and a group of California hams. PG&E was stonewalling resolving power-line noise and Riley agreed to write PG&E a letter, telliing them that the FCC had received complaints, explaining the rules and the FCC expectations that it will be resolved.  Over time, in back and forth between Riley and ARRL's then RFI engineer, this built into an informal program that added a lot to Riley's ability to continue to help resolve RFI cases.

In that program, ARRL does do a lot of the ground work, but this allows the FCC to concentrate its time on what only the FCC can do.  The League staff makes a determination that the interference will meet the very loose FCC criteria for being harmful interference.  We work with the ham to ensure that the correct source has been identified and that reasonable efforts have been made to resolve it.  If that last step is unsuccessful. we write a letter to the operator of the noise source, under the wing of the agreement with the FCC.  All of this probably resolved about 50% of the cases.

Should all that fail, we then turn over a well-documented case to the FCC, which begins by writing a letter worded very similarly to the one we wrote.  This resolves a number of cases, too, often getting the operator of the noisy device to work with the ham.  The League then helps that ham work with them.

In an ideal world, the FCC would "do its job," but in practice, for the FCC to act, every case would require an investigation by a field agent, to make a finding of fact as to all of the things that ARRL helps determine.  With field offices closing, as they have, those resources will not be available and most investigations will not take place unless and until a field agent will be in the area for something else.  And even then, we have seen a WIDE range of results from investigations, so in reality, they are best avoided.

This process is the best way to manage limited FCC resources and ARRL has a full-time EMC engineer working all of these cases.  We are long overdue for an article; I agree, but finding the time to write the article and to then manage a large influx of new cases may prove to be quite the challenge.  ARRL is supporting the formation of RFI teams across the country.  These teams have arisen organically, and ARRL staff are participating, with the expectation that this ultimately could become a nationwide, organized process, but this needs to be done cautiously. One need look no further than some of the misinformation seen on this forum to know that, like FCC and utility investigations, there will be a range of accuracy and results.

This is a challenge and one that will take me the rest of my life to get where I'd like it to be, but that works out perfectly fine because that is exactly how much time I have!

Ed, W1RFI

From: Michael Martin <mike at rfiservices.com>
Sent: Thursday, January 19, 2023 5:26 PM
To: David Eckhardt <davearea51a at gmail.com>
Cc: Hare, Ed, W1RFI <w1rfi at arrl.org>; Rfi List <rfi at contesting.com>
Subject: Re: [RFI] DEFINITION OF "HARMFUL INTERFERENCE"

Dave that is an excellent idea and I hope they take that ball and run with it. You are absolutely correct. The ignorance concerning awrl is pretty wide. The comments I hear in the conversations I have concerning what they do to help amateur radio I agree with your point of view.

Michael Martin
RFI Services
51 W Bay Front Rd
Lothian, MD 20711

240-508-3760
mike at rfiservices.com<mailto:mike at rfiservices.com>
www.rfiservices.com<http://www.rfiservices.com>

On Thu, Jan 19, 2023, 2:23 PM David Eckhardt <davearea51a at gmail.com<mailto:davearea51a at gmail.com>> wrote:
Thanks, Ed.  I realize FCC keeps most of the airwaves civil as opposed to
11-Meters.  But I do feel they could be doing considerably more in
enforcing Part 15.  This, especially due to the digital revolution and
SMPSs from China which sail through Customs as a component with no
attention paid to RFI.  True, these are only the tip of the RFI iceberg.

Previous to all of this, I had no inkling that you, ARRL, were so involved
in RFI remediation when it comes to amateur radio.  I had always believed
that was the duty of the FCC and us EMC/RFI engineers.  I don't believe
most of the readers of QST and the other periodic publications by ARRL are
aware of your efforts.  Would it be possible to author an article for QST
on your efforts, methods, and connections with the FCC?  A few pictures in
the article of the ARRL lab might also "impress" the readers and other
licensed hams.

Yea, I know you're busy enough, but I truly believe most hams are ignorant
of your RFI efforts and the capability at ARRL.

Dave - WØLEV

On Thu, Jan 19, 2023 at 7:26 PM Hare, Ed, W1RFI <w1rfi at arrl.org<mailto:w1rfi at arrl.org>> wrote:

> Two of those FCC lawyers helped create and maintain the process that ARRL
> and FCC use to resolve harmful interference problems.
> ------------------------------
> *From:* RFI <rfi-bounces+w1rfi=arrl.org at contesting.com<mailto:arrl.org at contesting.com>> on behalf of
> David Eckhardt <davearea51a at gmail.com<mailto:davearea51a at gmail.com>>
> *Sent:* Wednesday, January 18, 2023 2:59 PM
> *To:* KD7JYK DM09 <kd7jyk at earthlink.net<mailto:kd7jyk at earthlink.net>>
> *Cc:* Rfi List <rfi at contesting.com<mailto:rfi at contesting.com>>
> *Subject:* Re: [RFI] DEFINITION OF "HARMFUL INTERFERENCE"
>
> Yes, in my opinion, FCC is just a collection of overpaid lawyers who
> wouldn't recognize RF if it bit them in the behind.  Further, OET has been
> gutted and Part 15, either subpart, is not enforced unless there is big $$
> in it for the CFR 47 bureaucracy.
>
> Just my opinion formed over the decades (six+ of those) as a licensed
> amateur radio operator and an EMC/RFI engineer.
>
> Dave - WØLEV
>
> On Wed, Jan 18, 2023 at 7:51 PM KD7JYK DM09 <kd7jyk at earthlink.net<mailto:kd7jyk at earthlink.net>> wrote:
>
> > > *Harmful interference.* Interference which endangers the functioning
> of a
> > > radionavigation service or of other safety services or seriously
> > degrades,
> > > obstructs or repeatedly interrupts a radiocommunication service
> operating
> > > in accordance with this chapter.
> > >
> > > This statement is reproduced in several places throughout CFR 47, but
> the
> > > wording is essentially identical.  Pretty general, but this is what FCC
> > > legally plays to.
> >
> > No doubt the FCC addresses such, within moments of being reported, as it
> > clearly violates their own rules, as defined by those experiencing it.
> >
> > Kurt
> >
> > _______________________________________________
> > RFI mailing list
> > RFI at contesting.com<mailto:RFI at contesting.com>
> > http://lists.contesting.com/mailman/listinfo/rfi
> >
>
>
> --
> *Dave - WØLEV*
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*Dave - WØLEV*
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