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Re: [RFI] DEFINITION OF "HARMFUL INTERFERENCE"

To: "RFI@contesting.com" <rfi@contesting.com>
Subject: Re: [RFI] DEFINITION OF "HARMFUL INTERFERENCE"
From: "Hare, Ed, W1RFI" <w1rfi@arrl.org>
Date: Fri, 20 Jan 2023 12:22:56 +0000
List-post: <mailto:rfi@contesting.com>
I am going to chime in here speaking generally.

The definition of harmful interference is vague, but we do not want the FCC to 
draw lines in the sand about what level of noise constitutes harmful 
interference because that line could then be used to determine whether the FCC 
will or will not act. If FCC WERE to draw a line, it would probably be at the 
median-values of human-made noise in residential environments, which on lower 
HF is typically around S6 to S8 or so.

Right now, it is determined on a case-by-case basis, and FCC has been pretty 
reasonable in its approach.  One ham that sent them a video showing S1 noise on 
his S meter was told that his noise was not harmful interference. (He reports 
that the noise does get higher, but that is one of the videos he sent to the 
FCC, which used that to make a determination that S1 noise is not actionable.  
We managed to keep the case open, but there is a lot to do now to try to bring 
better evidence to the table.)

But other than a case like that, the FCC has generally been willing to help 
even with noise lower than might be deemed to be harmful interference if there 
is a clearly identified and correctable source.  We really want to keep that 
door open, rather than a decision that for noise below a specific level, FCC 
will do nothing.

There is still work to be done to get the FCC to take some actions that seem to 
be needed in some cases, but what we do have a process is clearly making an 
important difference and our approach to getting improvements is to build on 
what we have and to maximize its effectiveness.

Ed, W1RFI


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