[ARRL-OK] Fw: [RFI] ARRL RFI News

[K2GKK D C_Mac_ Macdonald]

From: RFI <rfi-bounces+k2gkk=hotmail.com at contesting.com> on behalf of Hare, Ed, W1RFI via RFI <rfi at contesting.com>
Sent: Monday, July 29, 2024, 12:00
Subject: Re:RFI News

Things are happening, Mike.  For every solar system we fix, the manufacturers learn how to make better product. Solar Edge, for example, has been making incremental changes, to the point where the majority of their standalone systems installed do not make enough noise to be deemed “harmful interference.”   In Tony’s case, Solar Edge ultimately determined that the remaining problem was coming from the Tesla side of the equation and the FCC you deem to be asleep prodded them into looking into it.  The premise that manufacturers are going to fix a system or three and not make design changes to ensure that they do not have to fix a lot more of them is simply not true.

The League has very well publicized its RFI program,  so amateurs should be taking advantage of it.

Now, related to your other comment about the expense of testing, the costs to ARRL are not all that significant.  For the most part, the accurate measurements we make are for conducted noise below 30 MHz, and that test takes about an hour, including equipment set up.  The test fixture is in a room dedicated to that purpose, so it is plug and play.  For radiated above 30 MHz, we are somewhat less accurate, although the use of a commercial bicon antenna with known antenna factors and spectrum analyzers capable of making the same measurements as seen in the standards gets us pretty close if we measure in the open side lot next to HQ.  To be a lab that sells services intended to be used for certification purposes, the lab needs to go through quite an expensive certification process on its own. The ARRL Lab simply needs to be able to make measurements sufficiently accurate and credible enough to warrant a formal complaint to FCC.

We do NOT want to hang our hats only on measurements.  As said, most devices we have measured have met the FCC limits.  The issue is one of actual interference.  What the ARRL Lab does is to verify the credibility of reports, and try to use existing processes to see if the problem can be resolved without FCC help.  You can argue that this should be the job of the FCC, but that is simply not going to happen, nor do we want FCC staff to be taking reports that, by their very nature, turn out to be incorrect in the first place.  It would take only a handful of misidentified interference complaints to have the FCC start throwing them all into the circular file.  Once it has been determined that the interference is severe enough that the FCC would act on it (ie, not a 3 db increase in noise, because noises do come and go in the FCC’s mind – and in reality), the correct source has been identified and that the responsible parties will not be responsible, the FCC does take some action.  This was hard won, built bit by bit over many years of time.

As to actual enforcement, the FCC will not issue a Citation or a Notice of Apparent Liability without the approval of the full FCC Commissioners.  In the long run, bringing that level of the FCC amateur cases could very well backfire, in ways we don’t even want to imagine.  Over time, the FCC process is improving, and more of its staff are paying more attention, so letting that run its course is the best course of action with an agency known for its slowness.  If instant answers are demanded, the FCC may give them, and we almost certainly would not like their answer.

Ed, W1RFI


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