I believe that you are right, Jim, although the FCC regulates as much for the
consumer as it does for business. FCC does not want to impose any more
restrictions on business than is necessary to have a manageable RFI scenario
because more stringent regulations would add considerably to the cost of goods
across a wide range of technologies.
To have regulations that reduced noise levels to the point where an amateur
with a sensitive receiver, antenna and otherwise quiet location would hear no
emissions from a neighbor's equipment would probably require 30 to 40 dB lower
emissions. This would add very real costs and, with additional shielding
needed, add weight to most electronic devices. I think I can say with
certainty that no regulators globally would decrease the permitted emissions
labels by even 30 dB. The pushback from manufacturers, consumer groups,
economic entities and political pressures would be significant, and if 30 dB
more requirements were imposed by some miracle, the resultant cost inflation
would cause harm across a wide range of society. Regulators understand all
these factors, and it is all of the factors that are the impetus behind
regulations, so it is not just about manufacturers. Millions of dollars in
advocacy costs would not be enough to counter the billions of dollars of
opposition and all th
e technical justifications in the world would not be a match for the economic
and social factors involved.
Even if there were room for some improvement, 10 dB would be a lot, and not
enough, but that would almost certainly come with a cost of having that
improved level be the feared line in the sand below which no further mitigation
would be required by anyone. We do not want this. The present laws on
"harmful interference" offer unconditional protection against interference
which seriously degrades a licensed service, even if making more progress
towards that ideal is not always as fast as we all would like.
So going head to head with unstoppable forces for complete protection through
regulations changes is not the answer because it will not work. Working with
the FCC to get it to act in well-documented cases of harmful interference is
one important step that has had significant results, even though there is more
that can be done. Working with cooperative manufacturers to get them to see
the reasons that they should improve their products and should develop
solutions to remaining problems is another objective that can actually and
practically be accomplished and in the case of the solar industry, progress is
being made.
Developing industry standards that can address interference at the initial
stages is another effective way we can get a good end result to resolve what
regulations cannot. I just finished my third term as the IEEE EMC Society Vice
President for Standards. I am now "term limited," but helped to groom a
successor who will also work towards helping industry develop good EMC
standards. (The new VP for Standards is Karen Burnham, KE8GVH.) I am poised
next year to take on a leadership role in the EMC Society Standards Development
and Education Committee, basical the EMC-Society standards board. I also serve
as the primary representative on the US C63 EMC committee, that writes
standards that are often adopted by the FCC by reference. I chair its
subcommittee on immunity. All of this work has resulted in some important
industry standards. I wrote a section in on a C63 standard incorporated into
the rules on distance extrapolation for measurements of field strength and the
IEEE is just
now balloting a standard for power companies to use to respond to RFI
complaints. This will also serve as a model for other similar standards, such
as solar power, which is work I will continue to do going forward.
Each of these steps builds on previous steps, not only solving some of the
problems that amateurs are facing, but bring amateur radio into modern
technology as a significant contributor. I learned decades ago to build on
every opportunity, build bridges instead of opposition and even the infamous
BPL wars were won by working cooperatively with industry, to the point where
cooperation resulted in international ITU regulations that avoided the use of
amateur spectrum for BPL.
This is how it is done and it is why I keep those doors of communication open
with Solar Edge, the FCC and the major industry contacts that have built from
earlier succcesses.
Ed Hare, W1RFI
ARRL Lab Manager
________________________________
From: RFI <rfi-bounces+w1rfi=arrl.org@contesting.com> on behalf of Jim Brown
<jim@audiosystemsgroup.com>
Sent: Friday, December 23, 2022 3:04 PM
To: rfi@contesting.com <rfi@contesting.com>
Subject: Re: [RFI] Another Solar Panel RFI System
On 12/23/2022 8:59 AM, David Eckhardt wrote:
> I still believe the standards should be revisited wrt radiated emission
> levels and measurement philosophies.
Hi Dave,
Like you, I'm well into my 6th decade as a ham, and in those years, I've
paid as much attention to politics as to ham radio. The likelihood of
FCC Regs being re-written to make them harder on business is ZERO.
73, Jim K9YC
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