Rules & Regs

(This article ran in Worldradio, May 2001)

Every once in a while I get an e-mail from an amateur operator who wants some information on the rules and regs that apply when an irate neighbor calls and wants to know why there is Morse code emanating from the family stereo or why a gravelly voice is hollering "seek you" during their phone conversations. Occasionally the correspondent wants to know about the other kind of RFI - the kind generated free of charge by your local power company. Of course, utility services are not licensed to broadcast on Amateur Radio frequencies, but that is not really the issue. What comes across as a thick carpet adorning the "noise floor" is not the same kind of interference that you may be causing to your neighbor's phone and is not related to the moron who decides to call "CQ DX" a kilocycle up the band from your QSO with your amigo in Papa Yankee land.

The RF energy fuzzing up your reception courtesy of the utility power lines or other electrical equipment is coming from what Part 15 of the FCC regs refer to as an "incidental radiator." Even if the incidental radiator has no moving parts and is purely a passive conduit for electricity, such as the power lines that are strung throughout your neighborhood, the FCC calls it a "device." So the rules and regs we are concerned about are those that regulate "incidental radiators" or "incidental radiation devices."

There are two basic types of incidental radiation - coronal discharge and spark gap noise. The coronal discharge type (which, and this is an oversimplification, is generated by ionization of the air dielectric around high voltage wires) causes some, but relatively few RFI problems for Hams. Sometimes it is accompanied by a fuzzy blue light and an audible hum, but the radiation that causes the RFI rarely travels great distances. In fact, unless the humidity is relatively low (pun intended) and the frequency is also low, it is unlikely that the RFI will be noticeable more than about 300 meters from the radiating power line.

According to most RFI literature I have read and our local power company RFI sleuth (more about him in a bit), the major cause of unwanted and harmful interference to Amateur Radio operations from utility power poles, lines, and equipment is spark gap radiation. This is caused by the same basic process of dielectric breakdown and ionization, but in this type of RFI the current (spark) actually flows in the gap between conductors (rather than in the "halo" or corona around a single conductor). Most of the time, the voltage that jumps the gap and ionizes the air (and generates the RFI) is induced in the conductors from the powerful electric field surrounding the high voltage feeder lines. One thing is common to both types of utility company RFI - it's usually possible to track down the interference to its source (not always easy, but possible) and, once the source is found, to fix the problem.

K3RFI - the RFI detective

We are really fortunate here in Washington, DC because the local electric utility, the Potomac Electric Power Company (PEPCO), has an expert RFI technician who is an absolute genius about RFI causes and cures. Mike Marti is also a licensed Ham (appropriately licensed as K3RFI). Mike spends a lot of his own time attending Amateur Radio club meetings in the Washington area and has a truck loaded with sophisticated RFI hunting gear. He is also involved in training RFI investigators for other power utilities. If we could clone Mike and spread his wisdom and knowledge across the country to all of the power companies, there would be a lot more solutions and a lot less griping.

The ARRL is also a great source of good information on RFI, including power company noise. No self-respecting Ham (except maybe for a few who live so far away from civilization that RFI is less of a problem than wolves), should be without a copy of the ARRL RFI Book. Even if you don't have an RFI problem (now!), the ARRL RFI manual is well-written and is a great source of interesting information. The ARRL Technical Information Service offers even more solid information on the ARRL web site. If you think that buzz in your ear is something other than tinnitus and that the source might be your local power plant or transmission grid, you should contact ARRL Lab Supervisor Ed Hare, W1RFI. His phone number is 860/594-0318 and his e-mail address is rfi@arrl.org.

In fact, ever since the first time I heard Mike Marti give his RFI spiel at a suburban Maryland Amateur Radio club meeting, I have thought that it would be a great idea for the ARRL to sponsor (or collaborate with PEPCO to sponsor) the making of a videotape on detecting and curing the causes of utility company RFI. Mike, of course, would be the narrator and star of the show, and the use of video would mean that graphics and diagrams could be used as well as photos and videotape of actual noise sources. In addition to being available to Hams and Ham clubs as an educational tool, it could also be used to inform utility companies about RFI problems and solutions.

In many cases, if local power companies get defensive or are uncooperative when confronted with an RFI problem by Amateur Radio operators, the reason is simply that they don't know what to do. We may assume that all power companies know (or should know) how to eliminate RFI, but that is no more realistic or fair than our neighbors assuming that we can fix the RFI from our Ham gear that leaks into their phones and TVs. One of the major differences in these two situations is that RFI from Ham gear that is caused by improperly designed or cheaply constructed telephone or unshielded stereos that act as a short wave receiver is not unlawful. On the other hand, harmful interference from the power company's incidental radiators or radiation devices is unlawful.

The utility RFI regs

Unlawful interference is regulated under Title 47, Part 15 of the Code of Federal Regulations (the "CFR"). Section 15.5 (General Conditions of Operation) includes two key provisions:

15.5(b) Operation of an intentional, unintentional, or incidental radiator is subject to the conditions that no harmful interference is caused and that interference must be accepted that may be caused by the operation of an authorized radio station, by another intentional or unintentional radiator, by industrial, scientific and medical (ISM) equipment, or by an incidental radiator.

15.5(c) The operator of the radio frequency device shall be required to cease operating the device upon notification by a Commission representative that the device is causing harmful interference. Operation shall not resume until the condition causing the harmful interference has been corrected.

The FCC has a lot of clout under Section 15.5(c), and although it is unlikely that the FCC will tell your power utility to shut off the juice to your neighborhood, the agency can levy fines and mete out other sanctions. Another important regulation that applies to incidental radiators is Title 47, CFR, Section 15.13:

Manufacturers of these devices [incidental radiators] shall employ good engineering practices to minimize the risk of harmful interference.

What is "harmful interference"? The FCC regs codified at Title 47, Section 15.3(m), are quite clear:

15.3(m) Harmful Interference. Any emission, radiation or induction that endangers the functioning of a radio navigation service or other safety services or seriously degrades, obstructs or repeatedly interrupts a radio communications service operating in accordance with this chapter.

This, of course, includes a properly licensed and operated Amateur Radio station.

In addition, Title 47, CFR, Section 15.15(c) (General Technical Requirements), "Parties responsible for equipment compliance should note that the limits specified in this part will not prevent harmful interference under all circumstances. Since the operators of Part 15 devices are required to cease operation should harmful interference occur to authorized users of the radio frequency spectrum, the parties responsible for equipment compliance are encouraged to employ the minimum field strength necessary for communications, to provide greater attenuation of unwanted emissions than required by these regulations, and to advise the user as to how to resolve harmful interference problems."

RFI help from the FCC

Last year, the FCC intervened to try to resolve several RFI complaints filed by amateurs. After a long struggle to get satisfactory results from Pacific Gas and Electric, some West Coast amateurs who were convinced that the source of harmful interference to their operations was incidental radiations from power lines or equipment, called on the FCC for help and got it. Last October, the FCC intervened in a Midwest power line complaint case by informing a Wisconsin electric utility (Alliant Energy of Madison) that it needed to do more to address suspected power line interference with the lawful operations of two Iowa amateurs. Alliant had told the Hams that it had complied with all applicable state and federal laws. The FCC explained the utility's obligations under its Part 15 rules and gave the company 30 days to look into the situation and report back to the complainants. Some of the FCC letter reads like this:

The FCC has the responsibility to require that utility companies rectify such problems within a reasonable time if the interference is caused by faulty power utility equipment. Under FCC rules, most power-line and related equipment is classified as an "incidental radiator." This term is used to describe equipment that does not intentionally generate any radio-frequency energy, but that may create such energy as an incidental part of its intended operation."

The FCC letter explained the applicable FCC rules (including the one that says the FCC can order the utility to cease interfering operations), and added a gentle nudge:

"The complainant has attempted unsuccessfully to work through your usual complaint resolution process and as a result the matter has been referred to our office. The FCC prefers that those responsible for the proper operation of power lines assume their responsibilities fairly. This means that your utility company should locate the source of interference caused by its equipment and make necessary corrections within a reasonable time. While the FCC has confidence that most utility companies are able to resolve these issues voluntarily, the FCC wants to make your office aware that this unresolved problem may be a violation of FCC rules and could result in a monetary forfeiture for each occurrence. At this stage, the FCC encourages the parties to resolve this problem without FCC intervention; but if necessary to facilitate resolution, the FCC may investigate possible rules violations and address appropriate remedies."

Usually, where an Amateur Radio complaint is the genesis of the FCC intervention, the Feds will try to get the allegedly offending utility to use the services of the ARRL to assist in mediating or solving the problem. Often the FCC will tell the utility to "contact the ARRL for additional guidance on dealing with RFI involving amateurs."

In the Wisconsin case, the FCC told Alliant Energy that the levels of interference reported by the Ham operators was "very clearly strong enough to be considered harmful interference to the Amateur Radio Service." Generally, the FCC bottom line is fairly straightforward. They tell the utility that it must not cause harmful interference to licensed services, and, if it does, it should "locate and correct problems within a reasonable time." In most cases, the Commission expects that interference problems can be resolved within 90 days of the time they are first reported. If amicable cooperative efforts are fruitless, the FCC can initiate its own investigation of possible rules violations and, if warranted "address appropriate remedies."

If you have power-line RFI problems, you can contact the FCC Call Center for help, but not until you have taken steps to resolve the problem locally. Unless you can demonstrate that you have made reasonable efforts to resolve power-line interference through your power-utility companyÕs normal customer service procedures, the FCC will probably not pay much attention. Also, the FCC seems to believe that it should defer to the ARRL in cases that involve the Amateur Radio Service, so the FCC often asks the ARRL to help resolve cases before they consider other steps. This being the case, you might want to try getting the ARRL together with your power company trouble shooters to work on solving the RFI problem. If you finally are convinced that you need to contact the FCC, be prepared to explain the steps you have taken to try to take care of the problem locally with the power utility company.

In any case, the more informed you are technically about RFI, the more chance you will have of being able to solve a utility-caused RFI problem. As a licensed amateur, you should at least be familiar with the material in the ARRL RFI Book. Get the book and study it so that you donÕt look like an incompetent doofus who only knows enough electronics theory to find the on-off switch on the 1.5 KW amp and replace the 40 watt light in the fridge where you keep the beer. If you have questions, this is an area where the ARRL really earns your dues, so use their talent and expertise, and call or e-mail the RFI desk. Of course, if you live around here where PEPCO pumps the juices, you just get in line for Mike MartiÕs RFI magic show. In any event, remember that RFI detection and suppression is as much an art as a science, so be patient! Get up-to-speed on the rules and the tech info, get all the help you can muster from the experts at ARRL HQ, then get involved in finding the solution! More power to you!

- David Splitt, KE3VV, the best darn Rules & Regs columnist in this magazine can be reached by mail to: 6111 Utah Avenue, N.W., Washington, DC 20015. He's also e-mail enhanced and you can contact him by e-mail to: davidsplitt@erols.com.