[RFI] DEFINITION OF "HARMFUL INTERFERENCE"

Sat Jan 21 07:38:38 EST 2023

Now, when it comes to Part 15, I agree; much more is needed.  Hams are suffering interference from all sorts of devices regulated by Part 15.  ARRL wants reports -- specific reports -- ie, the Model XYZ sold by Wal-Get-Depot is causing S9 interference from my neighbor's house. IF we can get those kinds of quality reports, we can and do act.  With a report like that, we go to Wal-Get-Depot, or the on-line US-based entity selling them, obtain one and test it to the C63.4 standards that apply to conducted emissions.  We can also test radiated, but in an open field, not a calibrated site, but even that is good enough to know that a device is operating much above the limits.  We find a lot of devices exceeding the permitted noise levels, and this week, with the ARRL Board of Directors meeting here, I have had discussions with the Chair of the EMC Committee and our DC counsel, and we are discussing just how the reports and complaints we have can be brought into the "Part 15" arm of the FCC.

But, unfortunately, the reports we receive are sporadic, or similar to: "My neighbor had a noisy LED bulb, but we replaced it and threw the bad one away.  I don't know what the model number is or where it was purchased." ARRL doesn't have the financial resources or staff time to buy every possible device, and every switching power supply that is sold with everything is a potential source, so those specific reports really are a vital part of our work.  When we get those reports, we can and do purchase units and do quantified testing on them to see if they exceed the limits.

I am seeing a lot of pessimism on this list about FCC, but I am not going to get derailed by it.  Fifteen years ago, FCC WAS doing nada about interference to hams, but a "can do" mindset and ensuing actions built a program where harmful interference is being addressed, even through a few glitches along the way.

But now that we have that in place, it's time for the next step.  Laura addresses these issues on the basis of harmful interference. In that light, it is not necessary to demonstrate that a device exceeds the emissions limits, so no actual testing needs to be done.  This is a good thing, because the Enforcement Bureau can't do its own testing. Exceeding the limits is a matter for the FCC Office of Engineering Technology and the FCC Lab.

ARRL has been identifying a few noisy devices that exceed the limits. We have well-documented reports and I expect that we will be filing complaints soon. When I do, I want to see what opportunities we may have to streamline the process.

Ed

________________________________
From: David Eckhardt <davearea51a at gmail.com>
Sent: Thursday, January 19, 2023 5:23 PM
To: Hare, Ed, W1RFI <w1rfi at arrl.org>
Cc: KD7JYK DM09 <kd7jyk at earthlink.net>; Rfi List <rfi at contesting.com>
Subject: Re: [RFI] DEFINITION OF "HARMFUL INTERFERENCE"

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
>

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