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 Previous: Youth@HamRadio.Fun: Field Day, Morse Code and More |  Next: The K7RA Solar Update |
NEWINGTON, CT, Jul 24, 2003--The ARRL has told the FCC that improved interference standards for consumer electronic devices is the most pressing need as the Commission considers the interference immunity performance of receivers. The League filed comments this week in response to an FCC Notice of Inquiry (NOI) Interference Immunity Performance Specifications for Radio Receivers (ET-03-65), released last March to gather input on the issue. While recommending "either mandatory receiver immunity standards or at least guidelines" in most other services, the ARRL said no receiver immunity standards are necessary or practical in the "essentially experimental" Amateur Service.
"The real need for receiver immunity specifications is in the area of consumer electronics," the ARRL said. "With the current explosion of consumer electronics and unlicensed devices, the Commission must--concurrently with consideration of receiver immunity standards in licensed radio services--establish interference rejection standards for unlicensed home electronic equipment and systems as well."
At the same time, the ARRL said, development of any receiver immunity standards or guidelines "should not be used as a means of justifying the overlay of otherwise fundamentally incompatible spectrum sharing partners."
The League said the FCC has had the authority to require improved RF interference immunity of consumer electronics and systems for many years "and has failed repeatedly to exercise it." The result has been "many thousands of instances of complaints against Amateur Radio operators and, in some cases, civil and criminal actions being filed," the League said. In its 21-page reply to the NOI, the ARRL recited the recent history of legislative and regulatory efforts to come to grips with interference from RF sources, including amateur stations, to receivers used in other services, such as TV and radio broadcasting, and to consumer electronics.
"ARRL continues to believe that receiver immunity should be on the order of 3 V/m for receivers that might be in the near field of an Amateur Radio station," the League said. At that distance, a receiver would be immune to an approximately 100-W ham radio transmission into a 0 dBd antenna 100 feet away. The League conceded, however, that such a standard would not address the interference immunity of telephones, computers, alarm systems, audio systems and other consumer electronics that "constitute the bulk of the instances of interference involving Amateur Radio operators."
The ARRL suggested the FCC mandate a standard for all consumer electronics or adopt a labeling or grading system that allows consumers to make their own choices about the importance of interference immunity and its value in terms of increased product cost. The League also said software-defined radio (SDR) technology offered the best opportunity to deal with receiver immunity.
The ARRL advised the FCC against relying exclusively on manufacturers to agree on how to deal with interference immunity. "Looking at the history of voluntary standards for RF interference rejection," the League said, "the track record of manufacturers is not exemplary." The FCC should establish recommended guidelines for receiver immunity, the ARRL said, but added that these should not apply to unlicensed devices "which are entitled to no interference protection in the first place."
In its NOI, the FCC had said it had no plans to reverse its "longstanding practice of allowing the market to determine the performance of broadcast receivers, with the Commission stepping in only where obvious deficiencies appear" that could disrupt reception.
The FCC's Consumer and Governmental Affairs Bureau (CGB) Web site "consumer facts" page takes a somewhat different stance by stating that interference from transmitters to broadcast receivers "is normally caused by the actual design of the (interfered-with) equipment itself." The CGB says many manufacturers "do not protect internal wiring with adequate shielding or sufficient filtering," leaving the consumer equipment susceptible. There's a similar comment regarding RFI to telephone equipment. Such RFI "is not necessarily a sign that the interference is intentional or that the interfering radio transmitter is illegal but that your equipment has no, or inadequate, protection." the FCC says.
The ARRL also urged the FCC not to make interference susceptibility of unlicensed devices a determining factor in whether a licensed radio service should be given an allocation in bands in where unlicensed--and unprotected--devices are deployed. As an example, the League cited the FCC's recent refusal to allocate a sliver band in the vicinity of 136 kHz "because of the ill-conceived prior deployment of unlicensed power line carrier [PLC] systems."
The FCC, in effect, "refused to make an allocation based on interference susceptibility of unlicensed and unprotected RF devices and systems," the League said. "This is improper spectrum management and the policy should be revisited."
In March, the FCC ask how it could incorporate receiver interference immunity specifications within its overall spectrum policy and invited public comments on possible methods and means of improving receiver performance. The Commission suggested that these could include incentives, guidelines or regulatory requirements--or a combination--in particular bands and services or across bands and services.
The Commission said it believes incorporating receiver performance specifications could "promote more efficient utilization of the spectrum and create opportunities for new and additional use of radio communications by the American public." The NOI was a follow-up to the work of the FCC Spectrum Policy Task Force, which looked at ways to improve overall radio spectrum management.
The ARRL's comments on the NOI are available on the ARRL Web site. The March FCC Notice of Inquiry in ET Docket 03-65 is available on the FCC Web site.
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