[RFI] New ARRL Mission statement > Was solar fix
Mike Fatchett W0MU
w0mu at w0mu.com
Mon Jul 29 12:03:22 EDT 2024
Customs......What is that......The only time I hear about customs is
when my importer that brings in lamps from Turkey and the entire
shipment held up because they can and then charge the customer
outrageous fees to hold it. If it comes from China nope. I have never
had a single items held coming from China.
W0MU
On 7/27/2024 11:35 AM, David Eckhardt wrote:
> Pulling a single sentence from Ed Hare's "treatise": There are no
> radiated emissions limits below 30 MHz and no limits on the amount of
> noise that can be conducted onto other wiring, .......
>
> The reason for no radiated emissions below 30-MHz is often
> misunderstood by the average amateur. In putting only conducted
> emissions into the regulation for anything below 30 MHz, FCC realized
> that these devices would be connected to usually long conductors
> acting as radiators, a.k.a., antennas. These long conductors could
> not be accommodated in the standard OATS or semi-anechoic chambers -
> the standard for radiated emissions assessments. So, in limiting the
> conducted emissions only effectively limits the amount of energy
> coupled onto these long (and effective) radiators, even the power
> grid. The reasoning for not providing radiated emission limits below
> 30 MHz is technically sound.
>
> Now my, hopefully, short "editorial" to Ed's "treatise".
>
> My main gripe about ARRL doing this work is that the charter of FCC
> (CFR 47) was to do or contract to accredited labs what ARRL is doing -
> for a fee. The labs aren't cheap!! Believe me. I've used them for
> over 40 years. Not that ARRL isn't doing a yeoman's job at the task,
> but they are not being paid for the efforts as was the intention of
> the original tasks set out for the FCC. They are performing these
> "services" at the expense of us members of ARRL (yes, I'm a life
> member). That's you and me.
>
> In some ways, yes, the efforts of ARRL wrt EMC/RFI are directly
> serving amateur radio, but they should be paid for the efforts as FCC
> presently is pretty much lax with enforcement. This was not the
> intention of the FCC "charter" (CFR 47, and in particular, Part 15).
> At present, as far as the FCC enforcement is concerned (from
> experience as an EMC/RFI engineer for over 40-years) Part 15 may as
> well not exist.
>
> Wall warts and switch mode power conversion units sail through customs
> with no attention paid to EMC/RFI as they are considered
> "components''. Components are exempted by FCC rjules. FCC takes no
> enforcement efforts to sample final assemblies which contain these
> switchers. But, FCC rules specifically point out that the final
> assemblers of a product are responsible for the final EMC/RFI
> solution. AThe "solution" requires passing established radiated and
> conducted limits set by the FCC (and the EU). I've tested many of
> these and many do not pass the established FCC (or EU) radiated
> emission limits. The vast majority wall warts do not pass their
> conducted emission limits. Sampling and enforcement at the FCC is
> sorely lacking!!
>
> The reality of the situation is that China has "taught" the suppliers
> and assemblers to cheat,.....yes, cheat. I won't belabor this point,
> but anyone in my shoes as EMC/RFI engineers fully knows what I'm
> referring to in that statement.
>
> Well, this WAS going to be short.......
>
> Ed and all at ARRL, I would be glad to serve on a local representative
> to my area as an EMC/RFI trouble shooter if and when the ARRL
> establishes this function. Yes, as a volunteer with no pay. I have a
> relatively complete RF lab with some of the instruments (and antennae)
> quite portable.
>
> ONE FINAL NOTE: It's sad that ARRL is underfunded. Their EMC/RFI
> efforts are probably the most effective to us radio amateurs. But the
> whole organization is sorely underfunded. HELP........
>
> Enough.........
>
> Respectively Submitted:
>
> Dave - WØLEV
>
> <http://www.avg.com/email-signature?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=webmail>
> Virus-free.www.avg.com
> <http://www.avg.com/email-signature?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=webmail>
>
>
>
> On Fri, Jul 26, 2024 at 11:20 PM Hare, Ed, W1RFI via RFI
> <rfi at contesting.com> wrote:
>
> <Short rebuttal to long essay: the current rules aren't good enough.>
>
> In general, I agree, but changing FCC rules, especially to make
> unlicensed emissions limits more stringent, is not the best
> solution, because it can take an incredible amount of time and the
> outcome is not certain. I can say with certainty that the FCC will
> never set those limits low enough to prevent all interference to
> amateur radio. The political resistance would not be futile.
>
> I could have written a dozen more paragraphs, but one point worth
> mentioning is that we now have more interest by OET in these noisy
> devices. Now that we have an inroad to report devices that exceed
> the emissions limits, the Lab can and will do more testing, once
> they are identified. And even for otherwise legal devices, the
> FCC is taking some action wrt harmful interference. Both types of
> FCC contact and cooperation will continue and the Lab staff will
> continue to work with industry. ARRL is uniquely positioned to do
> both.
>
> ________________________________
> From: David E. Crawford <dcsubs at molniya1.com>
> Sent: Friday, July 26, 2024 6:56 PM
> To: Hare, Ed, W1RFI <w1rfi at arrl.org>; Mike Fatchett W0MU
> <w0mu at w0mu.com>; rfi at contesting.com <rfi at contesting.com>
> Subject: Re: [RFI] New ARRL Mission statement > Was solar fix
>
> [You don't often get email from dcsubs at molniya1.com. Learn why
> this is important at https://aka.ms/LearnAboutSenderIdentification ]
>
> Short rebuttal to long essay: the current rules aren't good enough.
>
> On 2024-07-26 09:06, Hare, Ed, W1RFI via RFI wrote:
> > First, with respect to noisy devices, there are FCC rules
> related to the amount of noise devices can make. The
> manufacturers of devices must meet these requirements and must use
> "good engineering practice" (for whatever that means.) There are
> also rules that state that if harmful interference occurs to
> licensed radio services (amateur, CB, broadcast, business, etc.)
> then the operator of the offending device needs to address the
> interference.
> >
> > These rules are not intended to prevent all interference, no
> more so than the amateur rules on harmonics emissions are intended
> to prevent all interference to neighboring equipment. To achieve
> that goal would require many tens of dB more suppression, adding
> considerably to the costs of equipment (amateur gear and consumer
> equipment.) The rules are intended to reduce the likelihood of
> interference to a small-enough incidence of occurrence that it is
> practical to deal with interference on a case-by-case basis.
> (Amateurs that caused interference to nearby over-the-air TV
> receivers, for example, had to add additional filtering to their
> transmitters, even though they met the emissions-limits rules.)
> The limits also ensure that if there is interference, it is local
> and thus easy to identify, rather than possibly coming from over a
> mile away.
> >
> > It would be wonderful for the rules to be changed, but that
> would be nearly impossible at worst, and take years of time (as do
> most FCC proceedings) at best. The inadequacy of the rules is
> most apparent in a few glaring areas. First, many devices are
> categorically exempt from specific emissions limits. Conventional
> electric motors, for example. More important to amateurs, devices
> classified as "appliances" are exempt from emissions limits. This
> would include devices used for cooking, heating, cooling and cleaning.
> >
> > Also, interference is controlled below 30 MHz by setting limits
> on the amount of noise conducted onto the AC mains. (The premise
> is that small devices are not good HF antennas, but wires
> connected to them are, and the AC mains are long wire antennas
> that can and do radiate. There are no radiated emissions limits
> below 30 MHz and no limits on the amount of noise that can be
> conducted onto other wiring, such as speaker leads,
> interconnection wires, etc. This worked, sorta', for most devices,
> but now that we are seeing more and more digital wiring in houses
> and solar systems that have lots of wires that are not AC mains,
> we are seeing the inadequacy of these rules.
> >
> > The ARRL Lab has done a lot of testing of devices and, based on
> its testing, most of the devices that it has tested have complied
> with the rules. (For reasons described above, interference still
> does occur.) There have been exceptions. When indoor gardening
> became more popular, some high-powered lighting was found to cause
> interference. The Lab obtained a number of grow lights and tested
> them. Some were found to be as much as 58 dB over the emissions
> limits. (To put that into lay terms, one device was making as much
> noise as 650,000 legal devices.) The Lab reported this to the FCC
> and simultaneously contacted the major importer. The importer
> ended up discontinuing the worst of the models and started adding
> filtering to its product line. This was not an ideal solution,
> but most of the interference problems did get resolved.
> >
> > The Lab have also worked out a semi-formal process with FCC to
> get interference to amateurs resolved. Although this has not been
> 100% successful, I would estimate the success rate at over 90%,
> albeit in some cases taking years to resolve. In this program,
> the FCC refers all cases it receives to the ARRL Lab. The Lab
> takes some important steps. It first determines that the problem
> would meet the FCC criteria for harmful interference.
> Interference that is very sporadic would probably not be acted on
> by the FCC, and a ham that goes from S1 to S2 noise is still well
> below the median values of human-made noise, so FCC is not going
> to see a rules violation. The Lab has worked successfully a few
> cases that do fall into both categories, although FCC action is
> not likely. (The position the Lab takes is that if a single source
> of interference can be reasonably corrected, it is reasonable to
> expect it will be. FCC has followed up on a few of those cases
> with some letters encouraging the parties to fix interference).
> >
> > The Lab also ensures that the correct source has been
> identified, following step-by-step procedures to ensure that a
> noisy device in the hams' own homes are not blamed on power-line
> noise, for example. The Lab has found that almost half of the
> reported cases turn out to be something different than the ham
> first thought. ARRL also determines that the involved parties
> have tried to resolve this directly. In some cases, they do. So
> the ham must talk to the involved neighbor, or to his or her power
> company or other identified utility.
> >
> > The result of the latter is sometimes effective, sometimes not.
> If not. ARRL contacts the involved parties, with a letter written
> under the wing of ARRL's staff-level agreements with the FCC. The
> letter explains the rules and what needs to be done to correct the
> problem. This is sometimes effective. If not, the Lab now has a
> well-documented case to turn over to the FCC. The FCC Enforcement
> Bureau evaluates the case and when it almost always agrees with
> ARRL's determination, it follows up with letters to the involved
> parties. So although this process is not 100% perfect, the League
> and FCC are both doing quite a bit to try to move RFI cases
> forward and resolving quite a number of them.
> >
> > The Lab is just now in the process of developing a similar
> process to be able to more systematically report noisy devices
> that appear to exceed the limits to the FCC Office of Engineering
> and Technology.
> >
> > In conjunction with this process, the Lab also maintains
> significant contact with industry. The recent case involving
> solar interference discussed extensively on this reflector is a
> good example. In this case, Solar Edge did make significant
> improvements to its product, resolving over 500 cases of
> interference known to date, this system continued to make noise.
> Tesla was also involved, with the battery chargers. At first,
> Tesla did not get involved, but, as a result of communications
> from ARRL, Solar Edge and FCC, it ultimately sent an EMC engineer
> to look at the system and an effective solution was put into place.
> >
> > As an aside to this, the League is also implementing local RFI
> teams of volunteers, and supporting teams that have sprung up
> spontaneously. This is being built into a national program and
> the Lab may ultimately recommend that this become an official ARRL
> function.
> >
> > No, it doesn't stop there. The League is also involved heavily
> with industry. It serves as a voting member on the US C63 EMC
> Committee that writes industry standards often incorporated into
> the FCC rules by reference. Lab staff are also involved heavily
> with the IEEE EMC Society, serving as a member of its standards
> board, overseeing the development of industry standards on EMC.
> These are not seats at the back of the room. In my time serving
> in that role, I was elected to the EMC Society Board of Directors
> and then elected by that Board to be its Vice President for
> Standards. On C63, I served as the Chair of Subcommittee 5 on
> Immunity. This work has been effective, because for a number of
> years, interference by amateur radio to other equipment has become
> more and more rare.
> >
> > The League also funded a consultant to help the IEEE write a
> standard on the procedures electric utilities should use to
> resolve power-line noise. This standard is the first of its kind
> and can serve as a model for similar standards involving
> solar-system noise, for example. Std. 1897-2024 is now available
> from the IEEE and my guess is that it will be widely adopted and
> used, especially if FCC letters to utilities point to it.
> >
> > So, the question was asked: When will we see the ARRL doing
> something to address noise. This has all been happening for over
> a decade, much of it reported in bits and pieces. So, yes, the
> question is correct. When will hams see what is being done and
> continue to support the continuation and expansion of these
> programs. Keep in mind that most of this has been done by one or
> two HQ staffers, who also have numerous other responsibilities, so
> I'd say that it's a mean and lean machine doing good for amateur
> radio.
> >
> > Ed Hare, W1RFI
> > ARRL Lab Manager 1987-2023
> > Current ARRL Lab Volunteer
> >
> > From: RFI <rfi-bounces+w1rfi=arrl.org at contesting.com> on behalf
> of Mike Fatchett W0MU <w0mu at w0mu.com>
> > Sent: Thursday, July 25, 2024 11:04 PM
> > To: rfi at contesting.com <rfi at contesting.com>
> > Subject: [RFI] New ARRL Mission statement > Was solar fix
> >
> > The ARRL today release a new Mission statement. 2nd on the list is
> > protection of Ham Radio. I am very curious to see what that
> plan is.
> > Does it include stopping/reduction RFI emission from devices that
> > continue to pollute the ham bands making harder and harder for
> people to
> > enjoy the hobby? Is that enough to get the FCC to start
> actually doing
> > their job?
> >
> > W0MU
> >
> >
> >
> >> 73, Pete N4ZR
> >>
> >> On 7/25/2024 3:42 PM, David Colburn wrote:
> >>> You made it 'political'.
> >>>
> >>> This has nothing to do with a constitutional-conservative
> preference for
> >>>
> >>> less government and more liberty.
> >>>
> >>> It has to do with corruption by monopolies and the relocation
> of funds
> >>>
> >>> from enforcement to enabling-profit of corporations that
> donate to the
> >>>
> >>> Party-in-power. (Consider who that was for the past 16 years -
> >>> there's been
> >>>
> >>> no push for "small government" for at least 12 of the 16, and
> >>> precious little
> >>>
> >>> the other 4.)
> >>>
> >>> If it were about "small government" the FCC would have a
> smaller budget
> >>>
> >>> and clearly-defined priorities - which would include keeping the
> >>> spectrum
> >>>
> >>> clean.
> >>>
> >>> IMHO, YMMV ... KD4E
> >>>
> >>>
> >>> On 7/25/24 14:22, David Eckhardt wrote:
> >>>> They're gone in the name of "small government".
> >>>>
> >>>> I do not consider this political, please, it's reality.
> >>>>
> >>>> I'll attempt to keep my fingers off the keyboard in the future
> >>>> addressing
> >>>> this issue.
> >>>>
> >>>> Dave - WØLEV
> >>>
> >>> _______________________________________________
> >>> RFI mailing list
> >>> RFI at contesting.com
> >>> http://lists.contesting.com/mailman/listinfo/rfi
> >> _______________________________________________
> >> RFI mailing list
> >> RFI at contesting.com
> >> http://lists.contesting.com/mailman/listinfo/rfi
> >
> > _______________________________________________
> > RFI mailing list
> > RFI at contesting.com
> > http://lists.contesting.com/mailman/listinfo/rfi
> > _______________________________________________
> > RFI mailing list
> > RFI at contesting.com
> > http://lists.contesting.com/mailman/listinfo/rfi
>
> --
> -----------------
> David E. Crawford
> Indian River City
> Florida Libre
> -----------------
>
> _______________________________________________
> RFI mailing list
> RFI at contesting.com
> http://lists.contesting.com/mailman/listinfo/rfi
>
>
>
> --
> *Dave - WØLEV
> *
>
>
More information about the RFI
mailing list