OFCOM Consultation January 2015

Discussion in 'EMC Matters' started by G3RIR, Jan 7, 2015.

  1. G3RIR

    G3RIR New Member

    Does the RSGB EMC Committee have any advice as to how we should respond to the latest OFCOM Consultation. It would be useful if a summary of the main changes proposed is given. My understanding is that it gives OFCOM the power to stop interfering apparatus which has a lready been installed.

    Neil G3RIR
  2. Ken G3SDW

    Ken G3SDW Moderator

    It is being discussed as we speak Neil, it will be announced asap.
    73
    Ken
    G3SDW
    EMCC
  3. Graham G3TCT

    Graham G3TCT New Member

    I have the following comments on the Ofcom undue interference consultation:-

    p7 para 3.3

    Note 4 says Ofcom does not consider it necessary for the Proposed Regulations to apply to fixed installations. The EMC Regulations 2006 define “fixed installations” as follows:-

    fixed installation” means a particular combination of several types of apparatus and, where
    applicable, other devices, which are assembled, installed and intended to be used permanently
    at a pre-defined location.


    This means that these regulations would not apply to anything installed permanently (for example a set of solar panels). The limitation is anyway partly contradicted by the definition of apparatus at 3.3.1 which includes a combination of appliances. And again in 4.18 “the Proposed Regulations are not confined to single types of apparatus”.

    Note 4 needs to be removed.


    P14 para 4.15 sets a limit on what Ofcom can/will do:-

    In particular, the requirement will regulate the intensity of the electromagnetic energy at which apparatus operates, so that it is consistent with the maximum intensity of electromagnetic energy which was permissible at the time the apparatus was put into service or made available on the market . In doing so, it will fulfil the purpose of ensuring that it does not cause undue interference with wireless telegraphy.

    Limiting the intensity to that which was permissible originally does not necessarily prevent undue interference. Apparatus that causes undue interference but meets the above cannot be dealt with.

    In particular, it may be the system configuration (cabling, earthing, shielding etc) that will result in interference rather than the parameters of the apparatus itself.

    Therefore the last sentence is incorrect, and para 4.15 should be amended to say:-

    In particular, the requirement will regulate the intensity of the electromagnetic energy at which apparatus operates or the configuration of the installation, so that it does not cause undue interference with wireless telegraphy.

    73
    Graham
  4. G3YRZ

    G3YRZ Member

    I've read through the consultation documents, the very helpful RSGB commentary, and the draft Regulations. A few points:

    1. The very important issue arises, as pointed out by the RSGB, of the distinction between laboratory tests and what actually
    happens in real life.
  5. G3YRZ

    G3YRZ Member

    Apologies, my TAB key caused the incomplete post to be posted. Mods and IT people - is there any way to delete/edit a
    post after posting?

    Back to my few comments:

    I've read through the consultation documents, the very helpful RSGB commentary, and the draft Regulations. A few points:

    1. The very important issue arises, as pointed out by the RSGB, of the distinction between laboratory tests and what actually
    happens in real life. It would be a good thing if the Regulations could cater for the real world scenario. Perhaps by extending
    the definition of "apparatus" to include connecting leads as installed. (Particularly if those leads reach a 1/4 wavelength etc!).

    2. I am concerned that the Regulations should be accessible to those to be protected by them. Not many amateurs/SWLs
    have equipment available to take field strength measurements of anything (I certainly have nothing to take quantitative
    measurements) and the Regulations will also protect members of the public and scientific communities who have nothing
    to do with radio/electronics. So are they/we to be limited to existing arrangements for reporting interference?

    3. Generally, the Regulations can only add to existing protections so well done to those responsible.

    73
    John
    G3YRZ
  6. G3YRZ

    G3YRZ Member

    Having looked a little more widely, I find another source of concern. On their website, OFCOM highlight
    their support of the "Internet of Things". Read about it here:

    http://consumers.ofcom.org.uk/news/ofcom-sets-out-Iot-plans/

    The article includes this interesting statement:

    "The Internet of Things (IoT) is an emerging sector which is likely to see billions of smart gadgets and devices wirelessly connected to the internet and each other. The IoT's services span industries from agriculture and energy to transport, healthcare and much more, with the potential for significant benefits to citizens and consumers.

    Applications range from wirelessly connected sensors used for , where fertilizer and water are automatically distributed across a farm to increase efficiency, to systems and , which match power generated to consumers' electricity needs.There are already over 40 million devices connected via the IoT in the UK alone. This is forecast to grow more than eight-fold by 2022, with hundreds of millions of devices carrying out more than a billion daily data transactions.

    Working with industry and Government, Ofcom wants to create a regulatory environment which fosters investment and innovation in the IoT."

    and

    "It is expected that globally up to 50 billion 'smart' devices, ranging from cars and parking meters to coffee machines and combine harvesters could be connected to the internet by 2020, each using tiny slivers of spectrum to get online.

    Ofcom's plan is to ensure the UK has the tools and infrastructure to allow the IoT to develop unhindered. To support this, Ofcom has already for machine to machine uses making the UK among the first countries in Europe to do so."

    These are selective quotes, but you can see the potential for huge numbers of QRM generating power supplies and other devices increasing
    exponentially under our noses. Worth considering, having regard to the proposed clause in Schedule 2 of the new licence conditions:

    Schedule 2 (i) (f) (iii) The Station must not cause interference to and may not claim protection from other
    wireless telegraphy and electronic equipment"

    Okay, that relates only to the 472 kHz band AT PRESENT but even there we must ask how the new interference regulations are to provide
    any protection, and what guarantee there is that the "accept inteference" clause will not extend to other bands and nullify any possible
    benefit from the interference regulations.

    73
    John
    G3YRZ
  7. G3YRZ

    G3YRZ Member

    Is anyone else having problems submitting their consultation response? I keep getting

    "Please check the following and re-submit your details:
    Please check the spam prevention text and try again."

    I have tried the Captcha 8 times and am confident I was correct on almost all of them! I didn't
    have this problem with submitting the licence conditions consultation response.
  8. Martin G0HDB

    Martin G0HDB New Member

    Hello all, does anyone (especially Ken G3SDW) have any up-to-date information about the progress or otherwise of the proposed Regulations that were the subject of the Ofcom consultation back in Jan/Feb?

    The consultation paper stated that the aim was to bring the new Regulations into force in May (this year!) but I can't find anything anywhere to indicate whether or not that happened.

    I had (and still have) a problem with a high level of RFI from a nearby solar PV installation. In early 2013 I raised the issue with Ofcom; their field engineer was very helpful and sympathetic and was able to identify with a high degree of certainty the house on which the offending PV array is installed but the householder was extremely unco-operative and wouldn't let the Ofcom engineer have access to the premises so, to my dissatisfaction, my case was closed by Ofcom with the problem unresolved. Since then, several more solar PV installations have appeared in my neighbourhood and the QRM level has increased even more so I could really do with Ofcom having the powers assigned to them by the proposed new Regulations.

    Thanks in advance for any information you can provide,

    73
    --
    Martin G0HDB
  9. Ken G3SDW

    Ken G3SDW Moderator

    Martin thanks for the question, i am going to ask John Rogers M0JAV to contact you regrading the details of your question
    73
    Ken G3SDW
  10. Martin G0HDB

    Martin G0HDB New Member

    Many thanks for the very speedy reply, Ken - I'll look forward to hearing from John in due course.

    FYI, a few days ago I emailed David Lauder G0SNO, with a copy to Don Beattie G3BJ, asking the same question but thus far I haven't heard back from either of them. I've only just discovered this Forum so thought it might be worth asking the same question here!
  11. M0JAV

    M0JAV Moderator

    Thanks Martin
    I asked the same question at the latest RSGB Ofcom liaison meeting on June 23rd their answer is recorded in the minutes as "It was noted that the proposed Wireless Telegraphy (Control of Interference from Apparatus) regulations that would change Ofcom’s enforcement powers were expected to be enacted before the end of the year." The minutes of the meeting can be found at http://rsgb.org/main/blog/news/rsgb-notices/2015/06/29/ofcom-rsgb-forum-23-june-2015/

    At the same meeting we again offered to work with Ofcom to resolve some of the outstanding Solar PV cases. We will continue to pursue the outstanding cases.
    Ofcom were represented at the 6th EMC Market Surveillance Campaign on Grid Connected PV inverters and optimisers in November 2014. This made recommendations on additional standards for these devices. RSGB is represented on some of the european committees and has contributed to a paper on PV converter measurements.

    Thanks for your interest we will keep pursuing Solar PV it is one of our focus topics in EMC at the moment.
    John Rogers M0JAV
    Chairman EMCC
  12. Colin Richards

    Colin Richards New Member

    Just to add to that, we haven't been given any good reason why the May implementation date hasn't been met. As you know, the Society submitted a response to the consultation. In that we generally supported the introduction of new Regulations - we have pressing for this for years - but we also raised a number of issues that we felt needed to be addressed to make the proposed legislation work better. Other members responded direct to Ofcom too.

    However, as you first raised a case with Ofcom in 2013, this should have been dealt with under the existing EMC Regulations, as should the subsequent installations you mention. We have had difficulty getting Ofcom to act in similar cases and it would be very helpful if we knew more details about your case(s). When David Lauder returns from holiday we'll follow up your e-mail to him off-forum.

    73
    Colin G3YCR
    EMC Committee member
  13. Martin G0HDB

    Martin G0HDB New Member

    Hello Colin and John, many thanks for your extremely helpful replies - it's good to know that there's at least a fighting chance that the new Regulations will come into force later this year. My guess is that the main reason why the date of May wasn't met might have been the General Election in early May, with Parliament having been dissolved in the run-up to it - there probably wasn't much Parliamentary business being done not only for several weeks before but also for several weeks after the Election.

    I was one of the numerous people who submitted a response to the Ofcom consultation, back in Jan/Feb this year, and I saw and agreed with the RSGB's comprehensive and very well-thought-through response.

    With regard to the Ofcom case I raised, in early 2013, the response I finally got from Ofcom on 21st May 2013 stated:

    "I am writing to advise you of the outcome of our investigation into your interference problem.

    We have been unable to gain access to the premises where we believe the source of your interference is located. This is due to a gap in our regulatory powers. This may change in future but is dependant on new legislation being enacted through Parliament..

    Our investigation is complete and case reference 1-228781052 is now closed.

    If you experience any further interference problems, you will need to request a new investigation.

    Yours sincerely,
    Duty Engineering Officer"


    As you might imagine, this outcome left me feeling rather dissatisfied and frustrated, to say the least. I haven't yet requested a new investigation into the new interference that I've recently begun to experience; it would be pretty disheartening to end up going through the same loop as before...!

    With regard to my email to David Lauder, with a copy to Don Beattie, I emailed David because in mid-2013 he and I had some lengthy email exchanges about my Ofcom case, with Don cc'ed on many of them, and David offered to visit me with his equipment to make some measurements of the field strength emanating from the offending solar PV installation but unfortunately we never managed to arrange such a visit. It would be extremely interesting to take a set of measurements now, when there is even more interference present!

    Thanks again for the interest you're showing in my case,
  14. Colin Richards

    Colin Richards New Member

    Martin
    I can understand your frustration. The reply you received is much the same as others we have seen. In fact there is no gap in the legislation and the EMC Regulations are applicable as they cover new apparatus and installations for several years after they are first taken into service. We feel frustrated too at not being able to get Ofcom to move their position. It would be useful to get measurements of your situation now that there are more solar PVs nearby and we'll see where this stands when David returns. It is always worth anyone putting a complaint in to Ofcom. They judge the size of the issue by the number of complaints - that's all they have to go on - and if they have no complaints they can say there is no problem.

    For the new Regulations, Ofcom could not rely on the election for the delay. These Regulations are made by Ofcom, not Government. The appropriate Minister does have to lay them in Parliament before they come into force but that is little more than a constitutional nicety. If they had been ready they would no doubt have been published and have been laid in the House before or since the election. Meanwhile the lack of modern legislation covering interference from apparatus in use (as opposed to the EMC Regulations, which cover apparatus when first placed on the market or taken into service) remains.
    73
    Colin G3YCR
  15. Martin G0HDB

    Martin G0HDB New Member

    Thanks again, Colin.

    I'm going to do a few more investigations of the source of the latest QRM, which is at S9 all the way up to about 21MHz and has 50Hz/100Hz lines in it when viewed on an audio waterfall. The RFI appears to be originating not from a solar PV installation but from something else in a nearby house (the QRM is present 24 x 7 so isn't daylight-related); I'll try talking to the neighbours first to see if they'll assist in tracking down the source but will follow up with Ofcom if that approach doesn't prove fruitful.

    All understood re: enacting the new Regulations; we'll have to wait and see when it does actually happen!
  16. Ken G3SDW

    Ken G3SDW Moderator

    Martin i do not want to appear to tell you how to suck eggs but when talking to your neighbors just keep it simple, no tech` stuff, lots of soft soap and if necessary flowers a chocolates as a last resort.
    73
    Ken
    G3SDW
  17. Martin G0HDB

    Martin G0HDB New Member

    Hello Ken, thanks for the advice which was appreciated but fortunately unnecessary... :)

    My first approach was to a neighbour who I knew was technically-minded - he works as a development engineer (although more on the s/ware side I think) for a nearby high-tech comms and electronic systems company so he knows about EMC and related matters. Today (Sun 2nd) we got round to doing some tests using an Icom R10 handheld Rx to try to locate the source of some of the RFI that I've been suffering for several weeks, the first test was to switch off the AC mains feed in the neighbour's house and see if the QRM disappeared, which it did. Then, after about 30mins detective work the cause of the RFI was identified as a small wall-wart PSU that was being used to power something (I can't recall what); when the PSU was unplugged from the neighbour's house and then plugged into one of my sockets and switched on the QRM immediately reappeared. The wall-wart PSU had presumably gone faulty and has now been consigned to the dustbin and I can hear signals on some of the bands again - yippee!

    However, I still have to trace another source of QRM that appears almost as 'white noise' across a large part of the HF spectrum up to about 20MHz. Rather puzzlingly the level of this interference is very much greater when I use my Wellbrook ALA-1530 active loop antenna for receiving. I haven't yet tried turning the loop to see if I can find a null in the noise; I'll hopefully get round to doing that in the next day or so. The QRM does occasionally disappear - it was absent for several hours during the evening of Sat 1st Aug - but seems to be pretty continuous for most of the time. It definitely doesn't seem to be daylight-related so probably isn't caused by a solar PV array.

    Thanks again for the assistance,
  18. Ken G3SDW

    Ken G3SDW Moderator

    Thanks for the update Martin, the route you have explained on getting your first problem sorted is the finest and only way accurate way of dealing with this sort of RFI problem, well done.

    The second problem you have must be treated in the same way and as long as you get enough time when the problem is on then i am sure you will find it OK.

    Let the forum know how things go.

    73
    Ken
    G3SDW
  19. Martin G0HDB

    Martin G0HDB New Member

    Hello again Ken (and all), herewith is an update on my latest RFI-chasing...

    It turns out that what I thought was wideband high-level noise across the lower reaches of the HF spectrum is (or was) self-generated...:oops:

    With the help of a friend today I tried rotating my Wellbrook ALA-1530 loop antenna to try to null out the interference; as soon as the loop was disturbed (it normally sits on a wooden base on my flat roof) the level of the wideband noise dropped dramatically. After a bit of prodding and poking at various connections it appeared that one of the connections between the high-gain pre-amp and the tubular aluminium loop wasn't achieving perfect continuity despite the relevant screw being fully-tightened (or so we thought). I've now *really* tightened the screw that traps the fork connector that's on the end of the flying lead that comes from the pre-amp, so there should now be good continuity between the loop and the pre-amp. The wideband noise has disappeared and I can hear signals on 30m and 40m again!

    I surmise that the poor continuity between the loop and the pre-amp was resulting in the entire system becoming well and truly unbalanced, with the result that the loop was acting more as an E-field antenna that was feeding only one side of the pre-amp which in turn was being overloaded and shoving out a high level of wideband mush to my Rx.

    All I need to do now, to avoid the 'QRM' returning, is ensure that the connection between the pre-amp and the loop remains sufficiently tight so that the active loop performs as it should, which is very well indeed. At last, after yesterday's and today's activities, I can hear things again on the bands!

    Put this one down to experience, I think... :)
    Kev likes this.
  20. Ken G3SDW

    Ken G3SDW Moderator

    Well Martin you would be surprised at how many cases i have dealt with that turn out to be home grown, its nice to learn a lesson and of course to resolve the problem. Well done that man.
    73
    Ken
    G3SDW
    Kev likes this.

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