ARRL EMC Committee Semi-Annual Report Doc. # 20 For The American Radio Relay League Board of Directors Meeting July 19-20, 2013 Submitted By Kermit Carlson, W9XA Chairman, ARRL EMC Committee Mission Statement: The EMC Committee monitors developments in the Electromagnetic Compatibility (EMC) field and assesses their impact on the Amateur Radio Service. The Committee informs the ARRL Board of Directors about these activities and makes policy recommendations for further action, if appropriate. The overall goals of the committee are: Advise the ARRL Board about issues related to radio-frequency interference Advise the ARRL HQ staff on the content of its publications Make recommendations to the ARRL Board and HQ staff Maintain contact with other organizations involved in EMC matters through established liaison individuals Members of the Committee: Mr. Kermit Carlson, W9XA, ARRL Central Division Vice Director, EMC Committee Chairman Mr. Phil Barsky, K3EW, Engineering/Management Consultant, retired Mr. Gordon Beattie, W2TTT, Principal Technical Architect, AT&T Enterprise IT Service Assurance Mr. Jody Boucher, WA1ZBL, RFI troubleshooter, Northeast Utilities Mr. Brian Cramer, PE, W9RFI, Electrical Interference Solutions, Inc. Mr. Mike Gruber, W1MG, ARRL Lab RFI Engineer, HQ Staff Liaison Mr. Ed Hare, W1RFI, ARRL Laboratory Manager Mr. Ron Hranac, N0IVN, Technical Leader, Cisco Systems; past member of the Board of Directors, Society of Cable Telecommunications Engineers Mr. Richard D. Illman, AH6EZ Senior Engineer, Motorola Solutions Mr. Steve Jackson, KZ1X, VDSL and wireless communications Mr. John M. Krumenacker, KB3PJO Design Engineer Dr. Ron McConnell, W2IOL, T1E1.4 VDSL Standards Committee Mr. Jerry Ramie, KI6LGY, ARC Technical Resources, Inc. Mr. Cortland Richmond, KA5S, EMC Engineer Mr. Mark Steffka, WW8MS, Automotive EMC engineer Dr. Steve Strauss, NY3B, Home Phone Networking Alliance Technical Committee Committee Membership On behalf of the EMC Committee and myself, I wish to extend a warm welcome to our newest member, Phil Barsky, K3EW. As a retired System/Project Engineering Management Consultant, Phil brings a wide range of professional experience to the EMC field with particular emphasis in Interference/ Spectrum Engineering and EMI EMC Engineering. Phil’s consulting career also includes power line noise and interference abatement at XM Satellite Radio. Welcome Phil. Recent EMC Committee Activity and Discussion: The EMC Committee held one Webinar and Telephone Conference during the first half of this year. Held on January 22, the topic of discussion was an analysis of the compatibility of 135.7-137.8 kHz Amateur Radio communications and power-line control systems. The resulting whitepaper concluded that there is a significant potential for compatible sharing of the same spectrum between the PLC, which communicates through signals conducted by power transmission lines, and licensed radio transmitters which use signals radiated over the air. This document was produced for the ARRL CEO, ARRL Board and ARRL General Counsel. It was used in their response to the twelve points in FCC's ET Docket 12-338. The complete whitepaper is included as Appendix A. HQ Staff: The role of the ARRL HQ staff consists of the following: Answer individual inquiries from hams (and sometimes their neighbors) about RFI problems Write and publish articles about RFI Write and publish the ARRL RFI Book Design and update ARRL's RFI web pages Maintain a database at ARRL to facilitate EMC case tracking and reporting Work with ARRL's D.C. office on various spectrum and RFI-related filings Maintain contact with industry Participate in standards and industry groups, as a voting member or as a liaison. This includes ANSI accredited C63®, Society of Automotive Engineers EMC and EMR committees, Home Phone Networking Alliance, VDSL, HomePlug, FCC and individual companies. Mr. Gruber handles the majority of the staff work on EMC matters. In the 1st half of 2013, he also continued with work in a number of key areas: Adding updates and revisions to the ARRL RFI Web pages. One addition of note is a new page on grow light RFI. Grow light interference reports are increasing, and as the page indicates, can be particularly difficult to resolve. Here is the URL to that page: www.arrl.org/grow-light-rfi Facilitating and providing assistance on resolving long standing power line noise cases with the FCC. - Of particular note is a case near Pittsburgh, PA. Although the original case was closed after some repairs were made to noises found during an FCC and ARRL Field Investigation, the noise remains ongoing. An extended period of time after the repairs created enough uncertainty in the remaining noise that it was decided to give the utility an opportunity to address what might be potentially new issues. At this point, the case remains ongoing. Testing the conducted emissions of suspect consumer electronic and electrical devices. Devices that exceed FCC specified absolute limits can be identified and reported to the FCC. Of particular concern are: - LED Part 15 Bulbs, which may meet Part 15 limits, but if at or near the limits, could present an RFI problem without a practical solution, especially if there are many bulbs that are contributing to the problem. As an example, a device at FCC limits could be in the range of several homes in a typical suburban environment. When considering bulbs, a conservative estimate might be 50 bulbs per household, thus putting 150 or more bulbs within range of an Amateur station with just two neighboring homes. - Non-consumer Part 18 electronic ballasts being marketed and sold for consumer and residential purposes. - Variable speed pulsed DC motors now appearing in such things as washing machines, HVAC systems and pool pumps. Furnaces and air conditioners seem to be particularly problematic. - Large grow lighting devices used for indoor gardening are particularly problematic in some parts of the country, especially California and Colorado. These devices can be heard at much greater distances than would normally be expected from a device that meets the FCC Part 15 or 18 limits. One light that we looked at, for example, was considerably over the limit. Working with AT&T engineering staff to help resolve RFI issues with U-Verse systems. Reviewing proposed EMC related material for ARRL publications, including the RFI Chapter in the 2014 ARRL Handbook. Summary of Recent and Ongoing Lab Activities Lighting Devices As previously reported, Mr. Gruber prepared and added a grow light RFI page to the ARRL Web site. Pertaining to energy saving Part 15 & Part 18 Lighting Devices, Mr. Gruber also reports that he completed of testing of one additional Part 15 bulb for conducted emissions. This raises the total number of bulbs tested to 40. The selection of bulbs now includes: 31 LED bulbs from a variety of retail outlets, Dayton and eBay sources. Note: One LED bulb marked Part 18. 2 red LED (used) traffic lights purchased at Dayton. 7 CFL bulbs in various configurations, including floodlights. These bulbs are similar in configuration to the Part 15 LED bulbs that were selected for this testing. Mr. Gruber adds that LED bulbs operate under are Part 15, while CFL’s and electronic fluorescent light ballasts typically Part 18. In this case, there is an important distinction between these two rules - Part 18 limits for consumer RF lighting device lower than applicable Part 15 limits. As a consequence, the ARRL Board has previously asked us to look at proposal to reduce Part 15 limits to Part 18 levels for lighting devices. The results and data from this testing help provide us with a better understanding of interference potential from LED and CFL bulbs as they currently exist. It was also used by Mr. Gruber to write an upcoming QST article. At the time of this report, it is scheduled for the September 2013 issue. The analysis suggests that they substantially meet the applicable Part 15 or Part 18 limits in the Amateur spectrum. Those that failed primarily did so below 500 kHz. The measured emissions in most cases, however, were within our measurement tolerance. Although this might suggest a greater potential for interference to the two new proposed Amateur bands below 500 kHz, it is important to note that in all cases the limits high enough to create interference issues. Mr. Gruber emphasizes that even if an LED bulb is near the Part 15 limit, it can still be legally be sold and marketed in the United States. If and when interference occurs, the burden then falls on operator to correct problem. While this rule may work on a case-by-case basis for a small or limited number of sources, it is not practical should many bulbs in several houses be contributing to a wide spread problem. In addition, according to the FINAL REPORT ON THE 4TH JOINT CROSS-BORDER EMC MARKET SURVEILLANCE CAMPAIGN (2011), a study that they did on LED Lighting products in Europe found that: There was rather low compliance with the emissions limits: 61.5% of the tested, one hundred and sixty-six (166) products were found to be compliant. An additional study on harmonic current emissions was carried out. When applying the same harmonic limits as those for compact fluorescent lamps, one out of two samples, 46% of the assessed LED lighting equipment failed. A complete copy of this report is included as Appendix B in the report, or on-line at: http://ec.europa.eu/enterprise/sectors/electrical/files/emc/ms-campaign-fourth_en.pdf Arc Fault Current Interrupter AFCI Breaker Immunity Issues Mr. Gruber report that several months ago, he started receiving a few reports of “tripping breakers” from hams. Specifically, these complaints concerned AFCI breakers, or Arc Fault Circuit Interrupter type breakers. These breakers are designed to trip if they sense an arc, and are now required by the electrical code in some specified rooms for residential wiring. In response to these complaints, Mr. Gruber with invaluable help from W1AW Station Manager Joe Carcia built a “universal” circuit breaker test fixture. Mr. Gruber purchased every AFCI breaker that he could find at local electrical supply centers and big box home supply stores. Most of the complaints that he received seem to have involved breakers made by Eaton, which is a Cutler Hammer company, a well known manufacturer of electrical equipment. As a result, he purchased both a 15 and 20 Amp Eaton AFCI breaker for these tests. The initial results of this testing indicated that the AFCI breakers were surprisingly robust. They were operated them in the basement of W1AW during code practice sessions. They were simply not tripping, even with multiple transmitters all operating simultaneously at 1,000+ watts. Even the suspect Eaton breakers, which he purchased at Home Depot, were not tripping. Puzzled, Mr. Gruber then asked a complainant if he could send a sample or two of the problematic breakers. Shortly thereafter, he received two samples and tested them at W1AW. The initial tests indicated that there was indeed a problem. At somewhere between 25 and 50 watts, they would trip. Interestingly enough, these breakers were smaller than the ones that he had purchased and had a yellow (as opposed to a white) reset button. The part numbers were also very similar and the breakers were clearly meant to be interchangeable. Mr. Gruber’s best understanding of the problem at this point is that Eaton has redesigned their AFCI breaker, possible adding some new microprocessing circuitry. The older breakers were still on the shelf at Home Depot, and the newer model was used at the complainant’s residence and neighborhood. Based on his testing so far, the AFCI problem is primarily linked to one manufacturer (Eaton), and more specifically, only the latest model of Eaton breaker. It is not quite the universal problem that some seem to fear. However, with today’s cookie-cutter sub developments, this could become particularly problematic for a ham. High density housing where every service entrance panel is filled with Eaton breakers is an obvious recipe for disaster. Mr. Gruber will continue working with Eaton to find a solution to this problem. Status on FCC Enforcement and Outstanding EMC Cases Mr. Gruber reports that the FCC has been sending letters to utilities (and consumers) with some regularity. Although meaningful enforcement beyond that has historically been very disappointing, a notable exception occurred on April 23rd of this year. The FCC’s Tampa Field Office issued a Citation and Order Ruben D. Lopez Jr of Pomona Park, Florida. This Citation was in response to interference complaints to Amateur Radio from an irrigation well pump at Lopez’s farm or residence. The complainant in this matter is Richard H Sanders, WA4DJS. Of particular significance is that the FCC required the Part 15 device operator to cease using the device until the interference was corrected. The complete Citation and Order is included as Appendix C in this document. Mr. Gruber reports that this level of enforcement in cases involving Part 15 interference to Amateur Radio is very rare. In fact, he thinks it might be a first. Here is a brief timeline in this case: 05-18-2010 FCC’s Laura Smith submits case to ARRL 05-21-2010 ARRL Letter 07-15-2010 1st FCC Letter. URL Below 08-11-2010 FCC’s Laura Smith reports no response to 1st FCC letter. 02-28-2011 2nd FCC Letter URL Below 04-23-2013 Citation and Order URL Below Here are some additional URL’s that pertain to this case: ARRL News Story: www.arrl.org/news/florida-man-cited-for-causing-harmful-interference-to-radio-amateurs Citation and Order: http://transition.fcc.gov/Daily_Releases/Daily_Business/2013/db0423/DA-13-805A1.pdf Second FCC Letter: http://transition.fcc.gov/eb/AmateurActions/files/Water11_03_15_5238.html First FCC Letter: www.fcc.gov/eb/AmateurActions/files/AM_In10_09_21_5187.html With regard to power line noise, no previously reported longstanding power line noise case has been resolved during the first half of 2013. While some cases have been closed, there were roughly five times more new cases during this same time period. Looking at total picture, less than 20% of the known FCC power line cases have been resolved since the beginning of 2009. Here are some updated but approximate statistics from the database after ten and a half years: 3,609 total RFI cases. 1,025 Power Line Noise cases. Note: There are likely to be more since approximately 1/3 unknown sources are power line noise. 186 cases involved one or more FCC letters. 53 cases involved 2 or more FCC letters. As previously reported, here are some FCC Statistics from January 2009 to December 2011: 73 letters sent involving Power Line Noise. 50 cases remain ongoing. Note: It is possible that some of these cases have been corrected but not reported as such to ARRL. 13 and possibly 14 cases known to be fixed. 2 complainants moved. 3 cases involve an unknown status. 1 case on hold. 3 cases disregarded. Note: Reasons might include inappropriate behavior or lack of complaint credibility. In summary, Mr. Gruber reports the following comments concerning FCC enforcement: Less than 20% of the PLN cases involving the FCC from 2009 to 2011 are now fixed. Some cases have lingered for many years without satisfactory resolution. Cases are often caught in an endless loop or letter writing campaign. Of the approximately 1,000 ARRL power line noise cases, the FCC o Has never issued even one NAL. o Issued only about 4 citations. Note: Remarkably, the same noise level that prompted the Lakeland citation was later deemed not to meet FCC’s criteria to be harmful interference. Present protracted power line noise case examples include cases in Pittsburgh, Illinois and Colorado. It is important to note that Mr. Gruber was personally able to find noise at each of these locations in less than one hour of looking. Bottom Line: The FCC is clearly not doing its job! First Half 2013 Year Total RFI-Case Statistics: New RFI Cases – 109 New electrical power-line cases – 25 ARRL Letters sent – 6 (Note: One letter involved four complainants.) FCC 1st Letters submitted – 5 (Note: Laura Smith may have issued FCC letters based on need and input from the ARRL. These letters were not formally submitted by ARRL and therefore not included in this total. Many of these letters were follow-up in nature and therefore required custom legal language. The effectiveness of these letters has yet to be determined.) FCC 2nd Letters submitted – 1 Electric Utilities: Power-line interference has continued to be the single number one known interference problem reported to ARRL HQ. It can also be one of the most difficult to solve. Fortunately, Laura Smith clearly remains interested in RFI matters and continuing with the Cooperative Agreement. In addition, the Committee is continuing in the process of forming a working group to address this issue of power line noise. The following power line noise cases are of particular interest. Some have been previously discussed in semi-annual reports. K3GT in Allison Park, Pennsylvania: As previously reported, this case had been ongoing for over a decade. The FCC had issued five letters in this matter between 2002 and 2011. Mr. Gruber, with the assistance of Mike Martin of RFI Services helped the FCC investigate this case in May of 2011. Matthew Urick of the FCC Field Office in Philadelphia officially conducted the investigation, which is located near Pittsburgh. Also present was the complainant, Bob Thacker, K3GT. Subsequently, Mr. Hare visited the complainant in 2012 for a meet and greet session. During this time, without any locating equipment, he assessed the situation. Given the length of time that had transpired since the FCC’s last letter, and uncertainty regarding some of the sources, the complainant has agreed to a start over. Mr. Thacker has done some noise locating and presently working with the utility to resolve the remaining interference. At present, this matter remains ongoing. AA9VI in Northbrook, Illinois: As previously reported, this case was investigated by EMC Committee member Brian Cramer, W9RFI. Also present was Committee Chairman Kermit Carlson. It had also been previously investigated by the FCC and first reported to the ARRL on December 10, 2007. At the time of Mr. Cramer’s investigation, the FCC field agents had been unable to locate the source of the problem. Mr Cramer has now taken employment with ComEd. As a result, Mr. Cramer can no longer represent ARRL interests in this case. Mr. Gruber reports that the case remains ongoing. W0ZK in Northglenn, Colorado: This is another case that seems to have been dropped by the FCC. The noise started in early 2007 and was investigated by ARRL personnel, including TC Bob Witte and EMC Committee member Ron Hranac, N0IVN in early 2008. Bob Witte subsequently provided a report on the RFI on March 26, 2008. It identified several sources, and as a result, the ARRL Letter is issued on March 27, 2008. In July of 2008, Bob Witte emailed Mike Gruber for update. Mr. Gruber reported that Riley had just retired on July 3rd and that he no longer has a contact at the FCC. Mr. Witte then emailed Jon Sprague of the FCC’s Denver office asking for options. Kathy Berthot issued the first FCC letter on August 7, 2008. Subsequently, Laura L. Smith issued a second FCC Letter on February 20, 2009. Approximately three months latter, Ms. Smith reported that Xcel Energy has retained outside counsel in this matter. During an ARRL Convention, Mr. Gruber visited the site on June 1, 2009. He conclusively locates two sources using signature analysis. In addition, he observed a third offending noise source that ceased before he could pinpoint it. Later that September, Ms. Smith asks complainant for an update. She also reported that that she had discussed this case with Xcel’s attorney. Two months later, Mr. Witte asks Ms. Smith for an update. He also reported that Xcel did not appear to have taken any new action on this case. In October of 2010, Ms. Smith reported that she was checking on case status with the Denver Field Office. In September 2011, however, the complainant reported that his case appeared to have been dropped. He was not able to get a response from either the FCC or utility. The last report from the complainant in the first half of 2013 indicated that the noise continues, although intermittently at times. This case remains ongoing and essentially unchanged from the last Semi-Annual EMC Committee report. W4FGC in Lakeland, Florida: Although this case is well over ten years old, it was never fixed. Mr. Gruber reports that he has spent probably more time on this case than any other. Despite his effort, little or no improvement occurred as a result of sources located by the utility. Unfortunately, this case is now closed. As previously reported, Mr. Flynn is now 91 years old and no longer able to continue the Power Line Noise battle. In January, Mr. Gruber sent the complainant an official ARRL Certificate of Appreciation for his effort. Here is the text from that Certificate: On behalf of the American Radio Relay League, the ARRL Laboratory and all concerned Amateurs, we wish to express our greatest appreciation to James Clinton Flynn, W4FGC, for his steadfast support and assistance in the establishment of a working cooperative agreement between the ARRL and the Federal Communications Commission. His tireless persistence was essential toward one of the first FCC field investigations involving harmful interference to Amateur Radio caused by a public utility. Furthermore, be it known that his help established an important precedent toward the handling and resolution of all future such cases. We salute Mr. Flynn for this effort. Broadband over Power Line (BPL): Broadband over power line (BPL) is the use of electrical wiring or power-distribution lines to carry high-speed digital signals. There are two types of BPL of concern to amateurs. Both in- building and access BPL have signals that occupy most or all of the HF range, extending into VHF. The power-line or electrical wiring can act as an antenna and radiate these signals. In- building BPL can be used to network computers within a building. It uses the building wiring to carry digital signals from one computer to another. Access BPL provides broadband Internet access to homes and businesses, using a combination of techniques and wiring. As of July 2013, there are only a handful of BPL systems still in operation in the US and none are being expanded in any way as the major US BPL manufacturers have all shut down any production of access BPL equipment. In-premise BPL is continuing to be sold, but at this point, none of the several industry standards on BPL protocols permit the use of the Amateur bands. BPL is also one of several options for the developing smart-grid technologies, although it is far from being the front runner in current smart-grid deployments. The reliability of using BPL on overhead and underground distribution lines is not sufficient to make BPL the first choice of smart-grid backbone technology. Smart-Grid and Related Standardization Mr. Ramie reports on an EMI Issues White Paper and Smart Grid Standardization Efforts as follows: The NIST-SGIP issued the EMI Issues white paper in December, 2012 The five “gap” immunity tests missing from utility equipment tested for the US (under IEEE-1613) vs. what is required in Europe (under IEC-61850-3) are shown in red below. See Table. The EMII Working Group asked the IEEE-PES Substations C2 subcommittee to include the five gaps in their upcoming extension of IEEE-1613, called IEEE-P1613.1 Immunity Tests for Utility Equipment Immunity Tests Conducted IEC 61000-4-6 IEC 61000-4-16 Radiated IEEE C37.90.2 Magnetic fields IEC 61000-4-8 IEC 61000-4-10 ESD IEEE C37.90.3 EFT IEEE C37.90.1 Surge IEC 61000-4-5 Surge Withstand IEEE C37.90.1