[RFI] DEFINITION OF "HARMFUL INTERFERENCE"

[Jim McDonald]

You're insulting all FCC lawyers, current and retired, some of whom are very active hams.

Jim N7US


-----Original Message-----
From: RFI <rfi-bounces+jim=n7us.net at contesting.com> On Behalf Of David Eckhardt
Sent: Friday, January 20, 2023 16:12
To: EDWARDS, EDDIE J <eedwards at oppd.com>
Cc: RFI Reflector <rfi at contesting.com>
Subject: Re: [RFI] DEFINITION OF "HARMFUL INTERFERENCE"

All good points and I do understand.  Money talks.  As I've commented before several times, the overpaid FCC lawyers wouldn't know RF if it bit them in the behind.  And not much is left of OET.

Another thought:  Ham radio will become dead if the "digital revolution"
continues on its present relatively unregulated path.  Cities are already almost useless for HF comms due to all the RFI.  FCC should consult Homeland Security, FAA, and emergency comm. organizations including DoD on their outlook on ham radio.  For a full week after the huge deluge we received in 2013 (20+ inches of rain in 5 days), ham radio was the ONLY communications from Estes Park, Colorado to the flatlands where all the emergency equipment was located.  Cell service and EM Comms were totally wiped out.  During the High Park Fire in 2012, amateur radio was required to supply comms to ANYONE, including EM services who entered the fire area.  I'm sure FCC is aware of these instances and many others of similar nature.  Knowingly throwing that capability away would put FCC between a rock and a hard place if and when Congress learned of their "mistake".

Dave - WØLEV



On Fri, Jan 20, 2023 at 8:54 PM EDWARDS, EDDIE J via RFI <rfi at contesting.com>
wrote:

> Dave,
>
> After everything posted so far, I think you probably already know the 
> answer to your question.  It's pretty simple.  Today the FCC is run by 
> political lawyers as you know.  They're main concern today is to 
> protect internet and cellular systems for the consumers because they 
> are the biggest elephants in the room.  It used to be Television and 
> Telephone systems many years ago; however, both are losing customers 
> every day to internet and cellular systems.  It's the most ubiquitous 
> method of all communications today.
>
> Just as most technical IT types think wireless paging systems are 
> obsolete today, and for the most part they almost are, the same folks 
> and many more think the same thing of ham radio.  So then what do you 
> think is the perception of ham radio amongst the non-technical, 
> political-lawyer class of people at today's FCC?  The same or worse.  
> You want them to enforce Part 15 to protect an obsolete hobby in their 
> perception?  Sorry, there's no budget for that because they're too 
> busy with high-tech stuff like FirstNet, 6G cellular, and things that 
> impact tens and hundreds of millions of citizens daily.
>
> The ARRL is currently the only voice to continually update and change 
> the perception of ham radio within the FCC.  There is no other even 
> close to being cable of doing that.
>
> 73, de ed -K0iL
>
>
> -----Original Message-----
> From: RFI On Behalf Of David Eckhardt
> Sent: Friday, January 20, 2023 12:08 PM
>
> Ed, as I mentioned yesterday, previous to my joining this RFI group 
> online, I had absolutely no idea how involved ARRL was w.r.t. (with 
> respect
> to) RFI/EMC.  I had a rather tainted outlook when it came to ARRL.  I 
> usually stated that ARRL simply served as a lobby group to maintain 
> our slice of the RF frequencies.
>
> Boy, that has changed since joining this group.  I haven't always been 
> too "kind" to FCC based on my experiences over the years and to see 
> them gutted, especially OET.  I'm technical and put food on our table 
> and a roof over our heads for some 35+ years as an EMC/RFI engineer at 
> various companies, including HP (before the reign of "the witch of the 
> West").  In the past, I had wished I could cancel my life membership.  
> No more.  Keep it up!  I just wish the ham community knew more 
> regarding the RFI/EMC efforts we all pay for as members.
>
> But, again, ARRL is now doing the job FCC was originally chartered to 
> conduct, paid for by our dues to ARRL, and free to the tax payer.  
> Everyone benefits, but why should we be paying for what the FCC should be doing?...
> ... ...  Your thoughts?  I realize it's a labor of love for the RF 
> spectrum and our hobby.
>
> Dave - WØLEV
>
> On Fri, Jan 20, 2023 at 3:25 PM Jim Morgan <jvmorg at comcast.net> wrote:
>
> > Had intended to post to the forum... sent directly to Ed by mistake!
> > Thank you Ed for the personal response.  Hope you don't mind my 
> > posting
> it.
> >
> >
> > 73, Jim W4QE
> >
> >
> >
> > -------- Forwarded Message --------
> > Subject:        Re: [RFI] DEFINITION OF "HARMFUL INTERFERENCE"
> > Date:   Fri, 20 Jan 2023 13:49:48 +0000
> > From:   Hare, Ed, W1RFI <w1rfi at arrl.org>
> > To:     W4QE at arrl.net <W4QE at arrl.net>
> >
> >
> >
> > That point is being recognized.  We are also increasing 
> > communication with the AM broadcast industry and ARRL helped fund a 
> > participant in the development of smart-grid immunity standards, 
> > benefitting the electric utility industry. Amateur radio also 
> > benefitted big time because we can only imagine what would happen if 
> > amateur radio transmissions repeatedly took down the electric power 
> > grid.  It was a 10-year effort, in collaboration with the IEEE EMC 
> > Society and Power and Energy Society, but the final standards 
> > included meaningful RF immunity standards for protective relays and 
> > other equipment used in the developing smart-grid technologies.  As 
> > intitially written, a rock placed in the test fixture would have 
> > passed. 🙂
> > --------------------------------------------------------------------
> > --
> > --
> > *From:* Jim Morgan <jvmorg at comcast.net>
> > *Sent:* Friday, January 20, 2023 8:09 AM
> > *To:* Hare, Ed, W1RFI <w1rfi at arrl.org>
> > *Subject:* Re: [RFI] DEFINITION OF "HARMFUL INTERFERENCE"
> > I have been following this thread with interest, and just wanted to 
> > express appreciation to all for the (generally) civil tone of the 
> > conversation.  Clearly interference can be a touchy issue. I'm glad 
> > that the ARRL is so involved both in the standards process and the 
> > enforcement process.  I agree with Ed that diplomacy is as important 
> > as technology when trying to get to resolution of an interference issue.
> >
> > Thank you Ed, and ARRL, for your involvement in this area.
> >
> > It occurs to me that the work of amateurs in this area provides 
> > benefits beyond the amateur community.  RF devices are everywhere, 
> > and every time we find and fix a source of interference on the ham 
> > bands, life also gets better for some machine in a hospital, some 
> > theater or church using wireless microphones, even the drive-through 
> > at your favorite fast-food restaurant, who may not even know why 
> > their equipment is sometimes "flaky" or has dropouts.
> >
> > 73 all,
> > Jim W4QE
> >
> >
> > On 1/20/2023 7:02 AM, Hare, Ed, W1RFI wrote:
> >  > This has been my life's work, for over 35 years, and all that I 
> > know has been built on the work of many people, not just my own. 
> > That is the strength of organization.
> >  >
> >  > But I do have to note that is is more than a club, and our 
> > standing with FCC and others is also built on decades of 
> > participation.  When we work with the FCC, we do so as authentically 
> > and productively as we can, with a loyalty to what we believe to be 
> > the truth.  We have this unique position with the FCC because 
> > although we do strongly represent amateur radio to their enforcement 
> > people, it is done in the light of creating a reasonable process to 
> > help resolve cases, then supporting the
> process.
> >  >
> >  > It is done in parallel with similar work with the standardization 
> > process, through entities like the IEEE, not only with seats at the 
> > table, but with seats at the head of the table.  I just completed an 
> > 10-year series of terms on the IEEE EMC Society Board of Directors, 
> > twice as a Director-at-Large and three times as their elected Vice 
> > President for Standards.  I term-limited, so had to step down, but I 
> > am continuing that work by supporting the new VP for Standards and 
> > by serving its two major EMC committees in whatever ways they need 
> > me to serve.  ARRL has been a member of the US EMC committee, 
> > C63.org, that writes standards often adopted by the FCC as 
> > regulation. I am the Chair of its Subcommittee 5 on immunity.  ARRL 
> > has had a representative on the FCC Technological Advisory Council, 
> > bringing amateur radio and his expertise on RF safety and RF in 
> > general to their work.  ARRL, and amateur radio, participated 
> > internationally as part of the ITU-R process of helping to create internat
> >  >   ional RF law.
> >  >
> >  > So, when this "club" approaches the FCC at the staff level with a 
> > request for help and an offer to help the help, it is now seen as a 
> > legitimate request and a legitimate offer for help that will be 
> > appropriate and reasonable in its expectations.  The ARRL 
> > individuals that have been elected by their peers to leadership 
> > positions have been given those positions because they are 
> > legitimately contributing to real industry processes, representing 
> > their stake and influencing the outcome, but again, in ways that are appropriate and reasonable.
> > It is work that carries the strength of 700,000 US amateurs, with 
> > the ability to take on some of the tasks and, when needed, to crowd 
> > source informatiton that can be and is important and valuable to the 
> > advancement of state of the art.
> >  >
> >  > So, when "the club" works with the FCC, all of that is known, all 
> > of that is part of the processes and the FCC and others are coming 
> > around to believe that what is being asked is for a greater good 
> > that ARRL has helped establish a track record of greater-good 
> > achievement that shows that amateur radio is still a valuable part 
> > of modern technological advancement.
> >  >
> >  > Ed Hare, W1RFI
> >  > ARRL Lab
> >  >