Radcom January 2017 article by Ofcom on page 44 Ofcom's approach to VDSL

Discussion in 'EMC Matters' started by M0JAV, Dec 7, 2016.

  1. M0JAV

    M0JAV Moderator

    It would be helpful if you could post comments in this thread rather then starting several new ones
  2. M0JAV

    M0JAV Moderator

    The article in question from Ofcom is repeated below
    Ofcom’s Approach to VDSL

    As Director of Spectrum Technology, Engineering and Enforcement at Ofcom, I enjoy the opportunity to meet with representatives of the RSGB. Radio amateurs are an important stakeholder group for Ofcom and, as a licence holder myself, I have a personal interest in the hobby. It is clear from my discussions that there is some concern within the radio amateur community about the impact of VDSL (Very High Speed Digital Subscriber Line) and other new technologies. I’d like to address that concern, and also explain a little about Ofcom’s role.

    Since Ofcom was created thirteen years ago, there have been considerable technological, social and economic changes. Our predecessor, the Radiocommunications Agency (RA), had around one hundred field engineers operating from a number of regional centres. In recent years, given the more challenging economic climate, public bodies like Ofcom have had to ensure we use our resources as efficiently as possible. This has allowed us to reduce our like-for-like real-terms budget for 11 years in a row.

    This means our Spectrum Engineering Officers must prioritise and address a wide range of services. They are responsible for investigating interference affecting everything from emergency services to business radio, mobile phone networks, fixed links and satellites. They are also engaged in proactive work to identify unlicensed use of spectrum, and they assist with scientific research and measurements aimed at protecting and managing the airwaves.

    Many RSGB members may have fond memories of the days of the Radio Interference Service or the RA. Of course, times must change, and today our thirty engineers must cover the entire UK. As you would expect, their time is in great demand. So it’s vital that we prioritise and target the work we do in the field.

    In recent meetings with the RSGB we have discussed the issue of interference, including interference caused by the deployment of VDSL by Openreach. We at Ofcom appreciate that many radio amateurs invest a lot of time and resources in their hobby. We also appreciate how frustrating it can be when reception is affected by external sources such as VDSL. This type of issue is more problematic when working on HF bands, particularly when on the fringes of what is feasible.

    The RSGB is having ongoing discussions with Openreach and Ofcom on the effects of VDSL. Openreach has been receptive, and has sought to resolve faults on its network that have created some individual issues. But those efforts may not solve every problem experienced by individual radio amateurs. So we have worked with the RSGB and Openreach to better understand the issues. One outcome has been to conduct a joint research project looking at a small sample of VDSL cases. From Ofcom’s perspective, we know there are over six million VDSL installations throughout the UK. These installations provide high-speed internet connections to millions more businesses and consumers.

    By comparison, the number of unconfirmed reports of interference to radio reception received by the RSGB is just over 100. This represents a very small proportion, given the millions of VDSL lines in use, but I understand that is probably of little comfort if you’re one of those affected.

    Our work indicates that under certain conditions the emissions from overhead cables carrying VDSL services can raise the local noise floor and this may affect a receiving station in certain bands if the antenna is located close to overhead cables. This may limit the capability to receive weaker transmissions. Faults in the Openreach plant may cause the noise floor to be higher than normal and Openreach endeavour to get such issues fixed whenever they are identified.

    Such problems may be challenging to resolve, and may persist even when Openreach has rectified any network issues, although careful design and location of a receive station including the aerial systems also plays a significant part in preventing or rectifying problems.

    We understand how frustrating such cases can be, though it is hard for Ofcom to intervene. We are required to act reasonably, responsibly and to make efficient use of our resources. We must be proportionate, accountable, transparent and consistent. Given the scale of VDSL interference, attempting to fix individual cases may not be proportionate and in the wider public interest. Nor might we have the legal powers to intervene in all cases.

    Although we are sympathetic to radio amateurs experiencing issues with interference, the hobby, by its very nature, often relies on receiving signals far weaker than would normally be used in commercial radio use. Of course, that can sometimes lead to unavoidable interference. Unfortunately, operators who are seeking to receive a weak signal from a distant source can’t be guaranteed access to interference-free use of the radio spectrum in all circumstances. Indeed, Ofcom can’t guarantee interference-free spectrum to any stakeholder.

    So we will continue to judge each case on its merits and exercise discretion on what further action is appropriate in individual cases.

    Ofcom will always be on hand to offer advice and assistance in response to reports of interference to radio communications.

    We also welcome the RSGB’s EMC Help page http://rsgb.org/main/technical/emc/ which assists not only members, but anyone who may be affected by VDSL or other interference problems.
    Mark Walls Ofcom director of Spectrum, Technology, Engineering and Enforcement
  3. M0JAV

    M0JAV Moderator

    The RSGB EMCC have also received the following answer to this question which gives more detail about what Ofcom say they can do to combat RFI

    Ofcom published a statement on 24 March 2016 ‘Decision to make the Wireless Telegraphy (Control of Interference from Apparatus) Regulations 2016’ in which we address this issue at section 3 ‘The legislative setting’.

    For your convenience I have copied the following extract:

    Ofcom has enforcement powers in relation to undue interference. These are set out in primary legislation. In particular, section 55 of the Act provides for the giving of notices by Ofcom prohibiting the use of apparatus (“enforcement notice”). However in order to avail of this existing power to serve these notices, regulations must first be made under section 54 setting requirements to be complied with.
    3.2 Enforcement notices may be given in the limited circumstances set out in the Act. These circumstances are where, in the opinion of Ofcom: 3.2.1 apparatus does not comply with the requirements applicable to it under regulations made under section 54(1); and

    3.2.2 either the first or the second condition below is satisfied.

    3.3 The first condition is that the use of the apparatus is likely to cause undue interference with wireless telegraphy used – 3.3.1 for the purposes of a safety of life service; or

    3.3.2 for a purpose on which the safety of a person, or of a ship, aircraft or vehicle may depend.

    3.4 The second condition is that- 3.4.1 the use of the apparatus is likely to cause undue interference with wireless telegraphy other than wireless telegraphy falling within the first condition;

    3.4.2 the use of the apparatus in fact has caused, or is causing, such interference;

    3.4.3 the case is one where Ofcom consider that all reasonable steps to minimise interference have been taken in relation to the wireless telegraphy station or wireless telegraphy apparatus receiving the interference.

    The principles of enforcement
    Ofcom strives to ensure our interventions will be evidence-based, proportionate, consistent, accountable and transparent in both deliberation and outcome. These principles apply both to enforcement cases and to how we manage enforcement activities as a whole.


    Targeting involves relating enforcement action to the risks. Our resources are not infinite, and we are therefore more likely to focus on more serious circumstances. It is neither possible, nor necessary for the purposes of the protecting and managing the radio spectrum, to investigate all issues of interference or non-compliance.

    In selecting which complaints, or reports of, to investigate and in deciding the level of resources to be used, Ofcom will take into account the following:

    • The severity and scale of any potential or actual harm;

    • The seriousness of any potential breach of the law;

    • The practicality of achieving results;

    • The wider implications of the event, including whether there is serious public concern.


    Consistency of approach does not mean uniformity. It means taking a similar approach in similar circumstances to achieve similar ends.


    Transparency includes helping stakeholders to understand what is expected of them and what they should expect from Ofcom.


    Ofcom is accountable for our actions. We report annually to Parliament and we publish information about our enforcement activities.
    Ofcom will exercise discretion in deciding whether incidents or complaints should be investigated.

    Duties and functions

    The Communications Act 2003 requires that Ofcom secures the optimal use for wireless telegraphy of the electro-magnetic spectrum. In performing its duties, Ofcom must have regard to the different needs and interests of all persons who may wish to make use of the electro-magnetic spectrum. Ofcom must also have regard in performing its duties to the desirability of preventing crime and disorder.

    The Wireless Telegraphy Act 2006 makes it a general function of Ofcom to give advice, provide services and maintain records as we consider appropriate for facilitating or managing the use of the spectrum. Ofcom may also carry out research. Ofcom has a function of providing advice and assistance to persons complaining of interference.
    In summary - Our duty is to provide advice and assistance. We do not have a duty to enforce and we do not guarantee that interference will not occur. When deciding whether to investigate or to take enforcement action we are required act reasonably and responsibly and maximise the use of resources and do so in a proportionate, accountable, transparent and consistent way. We treat each case on its merits.
    Clive Corrie Head of Enforcement.
  4. M0JAV

    M0JAV Moderator

    A reply from Terry sent to emc.chairman@rsgb.org.uk reposted with his permission

    Well ... if anyone was in any doubt of Ofcom`s approach before, there is
    none now. A disinterested unhelpful moan laid bare for all to see.
    I should say that, although unable to help, the Ofcom officer who
    visited me on two occasions was very pleasant and amiable.

    The simple fact here is that BT or Openreach, whichever you like, has
    decided to adopt a system operating at HF and distribute it overhead on
    a copper pair array stretching many miles in all directions ... surprise
    surprise it radiates !

    Some of us have spent the best part of a lifetime experimenting and
    trialling systems to get the best extreme low level signal reception at
    our unique locations - only to see it wiped out overnight by this scourge.

    Ofcom cannot duck the issue - BT are transmitting RF over a wide HF
    frequency range most effectively from what must be the largest antenna
    anywhere .. bigger than Droitwich !

    The cure, apparently, is fibre to the premises for all installations in
    each affected area. Come on RSGB we need you to fight for us please.

    Terry George G4AMT
  5. G4LNA

    G4LNA Member

    Firstly, I'm not interested in how many engineers OFCOM got, so what? They are there to investigate interference matters. Just because we are amateurs and don't pay for our bit of spectrum doesn't mean we don't matter, by the way, who's idea was it for us not to pay for our license? Your's OFCOM! I was quite happy to keep paying for my license, in fact I would be quite prepared to pay more if that meant that you were able to employ more staff to look after our spectrum.

    The article seems very contradictory, on one hand it is saying "By comparison, the number of unconfirmed reports of interference to radio reception received by the RSGB is just over 100. This represents a very small proportion, given the millions of VDSL lines in use" then further down it says "Given the scale of VDSL interference, attempting to fix individual cases may not be proportionate" but hang on, didn't you just say earlier on that there was very small proportion of complaints, is there something you are not telling us? Or have I missed something?

    It goes onto say "not be proportionate and in the wider public interest"

    1. 1.
      of or concerning the people as a whole.
    So, amateurs are not the public then? What are we then? I see this buzz phrase used a lot by government departments as a get out phrase for something they don't want to do. If the boot was on the other foot and amateur transmission were blotting out large portions of the internet through no fault of their own, they would soon get closed down because it was "wider public interest" not to have us blotting out Facebook, Twitter or whatever.

    The trouble is, big money is involved in the internet, they could have quite easily notched out the amateur bands, but no, that would have cost too much money and besides, there aren't that many amateurs, so it won't matter if a few of them suffer, they'll have to live with it.

    I hope the reply to OFCOM will be a robust one, because as it stands at the moment they are definitely not fit for purpose, and I see Mark Walls says he is also a radio amateur and has a personal interest in the hobby, so he has to toe the party line, not having a go at him personally, but just saying...........
    Ken G3SDW likes this.
  6. M0JAV

    M0JAV Moderator

    A reply from Kevin sent to emc.chairman@rsgb.org.uk reposted with his permission

    Hello John,
    Very interesting to see that we have Mark Walls, OFCOM Director of Spectrum, Technology, Engineering and Enforcement referring to Amateur Radio as a hobby.Hobby radio as we know is Citizen's Band radio. Amateur Radio is a Service under the ITU Radio Regulations. If we have a person holding that position in OFCOM referring to us as 'hobby' radio enthusiasts it doesn't bode well. In fact it makes me wonder if he knows the differentiation between hobby radio and Amateur Radio.If OFCOM saw us as an ITU regulated Service then we may have a better standing in discussions with them. I see the new RSGB President referring to Amateur Radio as a Statutory Service, about time too. For, far too many years, the RSGB have and still does refer to it as a hobby in print/online etc. If the Governing body cannot get it right what hope is there.I'm still suffering the VDSL interference on 10 Mhz I reported quite some time ago and OFCOM have a duty to take ownership and sort out these problems, but as they see it as only 'hobby' radio they wash their hands of it. OFCOM should be under no illusion that they have a role to play under the ITU, as we are part of the 'Amateur Radio Service' and have protection from interference under enacted legislation. It's no wonder nothing is done as we do ourselves a dis-service by referring to it as a hobby. let's get it right or we will totally lose any standing we may have.
  7. GM0DEQ

    GM0DEQ New Member

    Without prejudice, the response from Mark Walls highlights a lot of apparent ignorance regarding amateur radio and indicates OFCOM's ZERO interest in interference that is VDSL sourced. OFCOM's xenophobia towards VDSL borne interference is now embarrassing citing all manners of reasons as to why they cannot enforce. OFCOM would also appear to wish to transfer it's legal status from enforcer to arbitrator. This is absolution to the extreme and not tenable.

    Fact: OFCOM have acknowledged that they are aware of VDSL interference to amateur radio users.
    Fact: OFCOM will NOT enforce VDSL interference.

    Please ignore all the dry ice and smoke and focus on this sentence ONLY: "Given the scale of VDSL interference, attempting to fix individual cases may not be proportionate and in the wider public interest. Nor might we have the legal powers to intervene in all cases."

    1 ."may" not be proportionate?
    2. "might" not have the legal powers.

    Let's look at point 1: "proportionate".

    NOBODY has asked OFCOM to treat every interference case as a nail and use an enforcement "hammer" to rectify. How can fixing s small number of complaints be dis-proportionate - non nonsensical statement?

    Looking further at "proportionate", as an example, when does ONE admirer start to become dis-proportionate and ultimately a "harmful interference"?

    A single admirer may as a one off, send some unsolicited flowers. A very kind gesture perhaps but never the less unsolicited and perhaps unwanted. This act does however indicate to the recipient something has changed. Next a letter then a card. A visit by the recipient to the local enforcement agency results in a luke warm response and it is shrugged off as being dis-proportionate.

    Next the recipient gets a text and an email. Another visit to the local enforcement agency promotes a more serious and understanding approach and now starts to take the recipients complaint a little more serious.

    An escalation and more intrusive behaviour by the admirer over a period of time results in them causing sustained "harmful interference" to the recipient who has now NO rest bite from the unwanted affections of the sole admirer. Eventually the enforcement agency "recognise harmful interference" and ACT. The admirer has transgressed what is acceptable and become a potential stalker (subject to the judiciary). Perhaps a simple but serious analogy and in drawing this analogy I do not wish to condone, trivialise nor demean this type of behaviour.

    Turning to point 2. "OFCOM MIGHT not have the legal powers". This statement indicates to me that as an enforcement agency OFCOM believe that they simply cannot enforce. This is their sole raison d'etre. Needless to say this statement is simply NOT credible and is basically asking me to believe that OFCOM has in fact NO teeth and indeed doesn't even want to check if they have inserted that morning. This is simply not a professional nor credible response based on supposition and has NO case law to even suggest such nonsense.

    Finally, Mark Walls in order to attain any sense of credibility needs to avoid using statements based on "supposition" (OFCOM are as I am familiar, adept at this type of parlance) and indeed respond factually at all times.

    Read the statement again and count the suppositions.

    OFCOM, it's time to man up and accept that there is an elephant in the room and stop masquerading as donkeys.

    Bob Alexander
  8. M0JAV

    M0JAV Moderator

    A reply from Henry sent to emc.chairman@rsgb.org.uk reposted with his permission

    Dear chairman, after reading Mark Walls letter as Director of Spectrum I will try and keep this as succinct as possible.
    I quote from the article that "Given the scale of VDSL interference..." and his citing that are "over 6 million VDSL installations"
    when seen against 100 or so RSGB cases, this seems to miss the point.
    When "commercial" and "business" users use access technologies that cause radio interference problems in parts of the HF
    spectrum they are not licensed to use, then there is an issue.
    OFCOM have always stated that it is their birth right to police the spectrum on the basis that it is a "national" resource to the UK.
    They often state that they have sole responsibility for this national resource and they do very well when it comes to earning license
    revenue that flows straight into the treasurery coffers.
    Where VDSL results in problems in parts of spectrum that these "commercial interests" are not licensed to use, then OFCOM should
    exercise its responsibilities to protect it on a national basis as well as considering their neighbours due to the distances that unintentional
    HF spectrum noise can pollute.
    Ignoring HF noise pollution issues is wrong. I don't see the 30 odd OFCOM engineers
    being able to cope when 100 or so in days past seemed a more proportionate level of manning.
    HCTaylor / G8GAR
    Ex manager of Radio Investigation Services to the Home Office.
    Ken G3SDW likes this.
  9. G8EPA

    G8EPA New Member

    As an occasional amateur astronomer I am saddened by the very limited number of stars that I can see from my light-polluted urban garden. Having been fortunate enough to see the night sky from the Australian outback I know what I am missing. Of course, it is desirable that we all do everything we can to minimise unnecessary light pollution, if only because it is a waste of energy to illuminate the sky, nevertheless we have to accept that the benefits to society as a whole of artificial lights at night far outweigh the disadvantages of interference with optical astronomy.

    And so, in my view, it is with VDSL. From an amateur radio point of view, it would be so much better if it had never been invented. But unfortunately we can’t un-invent it, or turn back the clock to a time when it didn’t exist, and the benefits that VDSL provides of broadband internet access to millions of users are significant. Nevertheless, it is inevitable that the broadband HF spectrum of VDSL, transmitted over an unshielded twisted pair of wires, often strung up high in the air, is bound to radiate, and thus will inevitably increase the HF background noise level in the areas that it serves.

    Of course, we should press Ofcom hard to act wherever the emissions from VDSL connections exceed the appropriate specifications, and their recent hesitancy to act firmly is unacceptable. But our main hope is that VDSL turns out to be an interim technology, and that the demand for ever-increasing broadband speeds will eventually lead to VDSL being superseded by fibre to the home (FTTH) connections to every subscriber. And at that stage, were it not for the increasing proliferation of switched mode power supplies, LED lights, microwave ovens, solar power installations, and many other EMI radiating devices we could go back to the low background noise levels of the past. In the meantime, we either have to experiment with yet more sophisticated coding systems capable of operating with lower signal to noise ratios, or achieve a lower background noise by operating from the radio equivalent of the Australian outback. After all that’s where the square kilometre array radio telescope is being located precisely in order to minimise the effects of terrestrial interference.

    Steve G8EPA
    Ken G3SDW and M0JAV like this.
  10. Tony G2NF

    Tony G2NF New Member

    So there is only 100 issues in the UK (2 are mine) so if they are fixed the problems will all go away?

    Please explain why notching cannot be implemented, it is for COMTREND and I can certainly hear that out of band!
    My VDSL is delivered via over head cable/BT, even if notching was limited to all users of my Drop Pole (DP) alone it would help, or better still all users from my green box some 50mters away.
    OK in terms of % of carries lost its only those in our bands and hence a reduction in available user bandwith would hardly be noticed.

    It's clear to me OFFCOM dont want to rock the boat i'm sure they could, likewise RSGB needs to bang the table some what more on this issue and importantly be seen to do so.

    Tony G2NF
  11. M0JAV

    M0JAV Moderator

    Tony I have hidden your first post as it was merely a repeat of the article from Mark and clutters the thread. Thanks for your response.

    The 100 reports quoted are ones RSGB EMCC have collected after numerous requests to members to report them over the last two years. We believe there are many, many more not found or not reported. Yours was the 60th reported to us. Ofcom claim much lower numbers reported.

    PLT apparatus are now required to conform to EN50561pt1 which requires notching.
    VDSL devices are required to conform to EN55022 (or EN55032 from March 2017) neither of which has a limit for radiated emissions below 30MHz. They require conducted emissions on the telecoms port to be less than 20dBuA and BT report that all of their devices are compliant. Measurements we have taken of devices which meet this specification, still cause significant levels of RFI to amateur radio.

    However we know that all the devices in the green boxes for VDSL (DSLAMs) have provision for notching the amateur bands but apparently it has not been activated by Openreach.
    We have formally requested that this be introduced. Ofcom have not supported us because they say as a result of their measurements "There was no evidence of interference that would cause restricted use of the amateur radio frequencies tested at any of the locations visited. At one of the locations visited there was evidence of a slightly raised noise floor, on a band that was not in use by the amateur." Our own measurements at these sites show levels up to S9+20dB and we dispute their statement and readings.

    Fortunately Openreach have been helpful in other ways with Line balance checks for all lines around amateurs who we have confirmed are suffering from higher than normal VDSL interference.
    We have recently completed our investigations at 11 locations and presented the 170 page report to BT and Ofcom. In this we suggested a number of actions to BT/Openreach and await their response. I hope to publish a short summary of this report in the near future.
    I can assure you we have banged the table with Ofcom many times it just makes your hands sore.
    John Rogers M0JAV
    Chairman RSGB EMC Committee
  12. M0JAV

    M0JAV Moderator

    Quote from G8EPA

    Of course, we should press Ofcom hard to act wherever the emissions from VDSL connections exceed the appropriate specifications, and their recent hesitancy to act firmly is unacceptable. But our main hope is that VDSL turns out to be an interim technology, and that the demand for ever-increasing broadband speeds will eventually lead to VDSL being superseded by fibre to the home (FTTH) connections to every subscriber. And at that stage, were it not for the increasing proliferation of switched mode power supplies, LED lights, microwave ovens, solar power installations, and many other EMI radiating devices we could go back to the low background noise levels of the past. In the meantime, we either have to experiment with yet more sophisticated coding systems capable of operating with lower signal to noise ratios, or achieve a lower background noise by operating from the radio equivalent of the Australian outback. After all that’s where the square kilometre array radio telescope is being located precisely in order to minimise the effects of terrestrial interference.

    Steve G8EPA[/quote]

    I respect your logical and pragmatic approach to the inevitability of RFI. However I have concerns that modern digital RFI (which I prefer to refer to as electronic smog) is noise like. This means that combinations of noise add up and propagate long distances. This can raise the RF pollution levels (or background noise) to levels where commercial DAB radio fails let alone Amateur DX is impossible. Amateurs should be the early warning system for this problem. Your astronomy analogy is a good one and I am worried not only about the light pollution from nearby sources but the inherent smog level from the accumulation of all invasive devices like VDSL. I am worried that even the outback noise levels will rise.
    John Rogers M0JAV & VK2JAV
  13. M0JAV

    M0JAV Moderator

    We appreciate that you like us on the EMC Committee believe that this matter is critical to survival of Amateur Radio.
    We will collect your points and mould them into a report on responses received. I will attempt to answer specific questions but not comment on the very good points you raise until the summary report is completed.
    John Rogers M0JAV
  14. Tony G2NF

    Tony G2NF New Member

    Thanks for your reply John, I do appreciate what the EMC committe undertakes on our behalf (blood preassure returning to near normal levels) and look forward to seeing the summary report.

    I will forward you more ammo shortly (QRM @ +6dB to +10dB either side of the guard bands) using a wide band active RX some 25m from the nearest phone line. However I am sure the results would be much more dramatic if I moved it to be closer to the phone lines!
    That is once I have finished improving the shack earthing, added two additional 3M ground rods <2M from rig and a fair amount of 22mm pipework to the existing system with a lot of effort. Next, move the modem/router to be adjacent to Master Socket and lay in screened CAT5/6 from the PC.
    I doubt it will make much diffenece as it did not appear to improve when disconnected, but at least I will have done all I can on my property.

    Oh, also use a fully filtered (& grounded) AC mains feed as well as a fibre link from router to the shack pc via media converters to help reduce induced noise & earth currents etc. Now out of ideas.

    Tony G2NF
  15. Paul M0XDX

    Paul M0XDX New Member


    Could notching be implemented in exceptional cases such as mine?
    To quote you about my VDSL problem that has been ongoing since February 2015:
    "They show evidence of a possible self-install product, there is nothing we can do about these. There is one other line, on the DP the other side, and this looks ok so again there is nothing that can be done to this one."

    Does notching have to be implemented for each individual line or just for the green cabinet?

    Paul M0XDX
  16. M0JAV

    M0JAV Moderator

    Paul the quote you attribute to me was the result of openreach investigations of lines near you which I instigated and forwarded the response to you after we had your DP investigated.
    Openreach check remotely for line imbalance and will rectify problems in their network but not inside premises which requires payment by the subscriber who has a problem in their property. This is what the openreach response refers to.

    Notching ability is included in the VDSL DSLAM hardware fitted but to the best of my knowledge has not been used in the live BT network. The level of notching available depends on the infrastructure implemented by BT/ Openreach which is proprietary to BT.
    We have asked them to consider implementing notches everywhere to protect the upstream bands as this only removes 100kHz of bandwidth to be notched (10.1 to 10.15 MHz and 3.7 to 3.8MHz).
    We have also requested that they notch on an as needs be basis the downstream bands. We await their response.
    John M0JAV
  17. M0JAV

    M0JAV Moderator

    Reposted from an email to emc.chairman with Mikes permission

    Monday, December 12, 2016 11:00 AM
    Dear Chairman,
    Regarding Mark Walls’ RadCom article, I have had more than one run-in with Ofcom in recent years concerning radio interference and BT's monopoly of telecommunications infrastructure and its hugely increasing annual charge for its use, and each time I have been baulked by obfuscation and buck-passing.
    If I may say so, apart from illustrating well the tendency of quangocracies to use ten words when two will do, this article offers us absolutely nothing. Indeed, it offers us nothing in a patronising way, and as we can see, it's all about 'addressing issues' rather than proving that Ofcom has some teeth and can get something done.
    As usual, it's all about money, and we radio hobbyists are just that, hobbyists, so that is how we have to be treated. Making vast sums from line rentals to pay for televising premiership football, in the expectation of making even larger sums, is far more important than using the money for putting overhead cables underground. It may be guessed, of course, that I don't watch football.
    I rest my case.
    Very sincerely,
    Mike Hall, G3USC.
    PS: I don’t have the time to subscribe to forums but feel free to publish this in EMC Matters.
  18. M0JAV

    M0JAV Moderator

    A response from Martin G0HDB sent to emc.chairman@rsgb.org.uk and reposted with his permission

    Over the last few days I've pondered long and hard on how to respond to the article titled
    'Ofcom's approach to VDSL' by Mark Walls in the latest issue of RadCom and have prepared
    quite a lengthy response paper, which I attach for your information.

    I haven't sent the document to anyone else or submitted it directly to the RSGB EMC Matters
    Forum; please feel free to do whatever you believe is most appropriate with the document. If
    you want to publish it either in part or in full on the forum then that's fine by me! I hope you
    find the document useful and helpful in one way or another.

    Kind regards

    Martin Davies G0HDB

    The article by Mark Walls published in the January 2017 issue of RadCom and the responses by Clive Corrie to the RSGB’s question about what is needed to get Ofcom to enforce against serious interference to amateur radio both make for revealing but extremely frustrating and depressing reading for several reasons:

    1. The Mark Walls article seeks to use Ofcom's resource limitations - only 30 Field Engineers now versus approximately 100 in the past - as justification for not being able to devote sufficient time and effort to investigating and helping to resolve cases of interference, of whatever nature, reported by amateurs. Whilst I expect all amateurs will fully understand and accept the need for Ofcom to prioritise its efforts and resources onto cases where critical and safety-of-life services are affected by interference, this does not mean that Ofcom can simply abrogate its responsibility for ensuring that all licensed users, including the amateur service, are protected from undue interference as far as is practically possible. Nowadays, Ofcom blatantly regards and treats amateurs solely as hobbyists and therefore of no great importance, rather than as a fully-recognised radio-communications service as defined in the ITU's Radio Regulations that should be afforded exactly the same levels of protection against interference as all other similarly-recognised services.

    2. Ofcom’s casual dismissal of the 100 or so reports (why and by whom are they unconfirmed?) of interference from VDSL as an indication that the problem is of no great significance given the very large number of VDSL installations is arrogant and belittling – in almost any other field, for example vehicle or white-goods safety or reliability, that number of reports would give rise to a serious cause for concern and would in all probability result in immediate remedial enforcement action being initiated by the relevant regulator. Ofcom’s blatant refusal to acknowledge the scale of the problem reinforces how little it seems to care about protecting the amateur radiocommunications service from interference; it also makes one wonder whether Ofcom dismisses the concerns of the ‘professional’ users of the HF spectrum so readily. There is ample evidence that these users are also deeply worried about the degradation of their HF receiving capabilities caused by interference not only from VDSL but also from PLT equipment and other sources of RF pollution.

    3. The statement near the end of the article that: "Ofcom will always be on hand to offer advice and assistance in response to reports of interference to radio communications" is at best laughable and certainly not borne out in practice. The Ofcom position, as evidenced both by my own experiences earlier this year and by other amateurs' reports (for example see the letters from G4XMJ and GW3TMP in recent RadComs), seems to be that it (Ofcom) will as a matter of course try its utmost to refute and refuse to pursue interference reports from amateurs. When I submitted an interference report in June this year, the Ofcom Duty Engineering Officer who contacted me was adamant that my submission, which included detailed technical measurements that conclusively and irrefutably demonstrated the significant degradation of my receiving system's sensitivity caused by the presence of high levels of RFI emanating from (I strongly suspect) a nearby solar PV installation, did not constitute ample evidence of harmful or undue interference to my HF reception. The DEO seemed to be hell-bent on completely ignoring the clear and unambiguous definition of harmful interference that's given in the ITU Radio Regulations and also in the Wireless Telegraphy Act and was instead applying what seemed to be his own highly subjective test for what constituted harmful interference.

    Lest anyone be unaware of the definition, Section 1.169 of the ITU’s Article 1 - Terms and Definitions defines harmful interference as:

    Interference which endangers the functioning of a radionavigation service or of other safety services or seriously degrades, obstructs, or repeatedly interrupts a radiocommunication service operating in accordance with these Regulations.

    4. Even when amateurs' reports of interference are investigated by Ofcom, there appears to be a great reluctance on its part to take any enforcement action against the owners/users of apparatus that has been clearly shown to be the source(s) of significant, and harmful, levels of RF interference. This begs the question of when and in what circumstances Ofcom would make use of the additional powers it was given in the Wireless Telegraphy (Control of Interference from Apparatus) Regulations 2016 that came into force earlier this year. Ofcom's apparent extreme unwillingness to make use of these powers can't help but reinforce the impression that it is a toothless watchdog that has no interest in helping protect the amateur radiocommunications service from undue interference.

    5. In relation to this, the summary statement by Clive Corrie (Ofcom Head of Enforcement) that Ofcom's role is to provide advice and assistance and that Ofcom doesn't have a duty to enforce beggars belief - if it's not Ofcom's duty to enforce compliance with the regulations then whose duty is it? Furthermore, there are numerous references to Ofcom’s enforcement powers in the Wireless Telegraphy Act and also in the Wireless Telegraphy (Control of Interference from Apparatus) Regulations 2016, so Clive Corrie’s statement that Ofcom doesn’t have a duty to enforce is bizarre and incomprehensible – what on earth does he think Ofcom’s role is when cases of serious interference are reported? If it’s not Ofcom’s duty to enforce, why does it need the enhanced enforcement powers it has recently been given?

    6. The statement in the Mark Walls article that: "... careful design and location of a receive station including the aerial systems also plays a significant part in preventing or rectifying problems" is not only condescending and patronising but also insulting in that it seems to suggest that amateurs do not pay sufficient attention to these aspects of our station designs and implementations and that consequently we are at least partly to blame for any interference we suffer. This attitude is entirely unacceptable - it's a bit like suggesting that someone who suffers from noisy neighbours should either use earplugs or move house. I, and all the amateurs I know, have paid a great deal of attention not only to the types of antenna we use, especially those intended for reception only, but also to the siting of those antennas. However, in many situations the siting of an antenna, be it solely for receiving or for both transmitting and receiving, will be largely determined by what is physically possible and environmentally acceptable/permissible within the constraints of our properties, so Ofcom's apparent suggestion that we should relocate our antennas in order to reduce the levels of interference we suffer is completely nonsensical. The onus should be firmly on the people, organisations and authorities who install and use apparatus to ensure that neither the installed apparatus nor any related part of the total installation unintentionally emanates RF energy thereby causing undue interference, and it is (or should be) Ofcom's statutory duty to ensure that the Electromagnetic Compatibility Regulations and hence the EMC Directive's Essential Requirements are complied-with by any apparatus that is clearly and conclusively demonstrated to be the source of undue interference.
  19. M0JAV

    M0JAV Moderator

    Ofcom are certainly being consistent their 2017/18 annual plan https://www.ofcom.org.uk/__data/assets/pdf_file/0027/94743/Proposed-Annual-Plan-2017-18.pdf
    contains this section
    "Spectrum assurance and enforcement

    5.9 Ofcom advises and assists spectrum users to help resolve harmful interference. Our Spectrum Technology, Engineering and Enforcement Teams handle reports of interference and carry out activities to protect and manage the UK’s spectrum. These include reacting to interference to safety-of-life communications and proactively preventing unauthorised use of spectrum by identifying and addressing unlicensed use of spectrum and the sale or use on non-compliant equipment. Our enforcement is proportionate, in accordance with our statutory duties and regulatory principles."

    They are inviting responses from stakeholders by February 7th.

    Again no mention of enforcement against anything that is not safety of life communications.
    John Rogers M0JAV
  20. Martin G0HDB

    Martin G0HDB New Member

    John - thanks for the link to the Ofcom vision for the future...!

    Ofcom's reference in its Proposed Annual Plan to reacting to interference to safety-of-life comms is entirely in line with one section in the Communications Act 2003, which defines the functions of Ofcom, but it completely ignores another immediately-adjacent section in the Act. Specifically, section 183 in the Act, in Chapter 2 titled 'Spectrum Use', states:

    183 Modification of definition of “undue interference”
    For subsection (5) of section 19 of the Wireless Telegraphy Act 1949 (c. 54) (meaning of undue interference) there shall be substituted—
    “(5) Interference with any wireless telegraphy is not to be regarded as undue for the purposes of this Act unless it is also harmful.
    (5A) For the purposes of this Act interference is harmful if—
    (a) it creates dangers, or risks of danger, in relation to the functioning of any service provided by means of wireless telegraphy for the purposes of navigation or otherwise for safety purposes; or
    (b) it degrades, obstructs or repeatedly interrupts anything which is being broadcast or otherwise transmitted—

    (i) by means of wireless telegraphy; and
    (ii) in accordance with a licence under this Act, regulations under the proviso to section 1(1) of this Act or a grant of recognised spectrum access under Chapter 2 of Part 2 of the Communications Act 2003 or otherwise lawfully.”

    As is clear from the above, Ofcom has chosen to commit to dealing with harmful interference as defined in 5A(a) but has chosen to ignore completely the subsequent "or" definition in 5A(b). I wonder if this gives grounds for challenging Ofcom on the grounds that is not intending to fulfil all its statutory duties as defined in the Communications Act 2003...

    Furthermore, section 155 in the Act states:

    155 Advisory service in relation to interference
    (1) It shall be a function of OFCOM to provide a service consisting in the giving of advice and assistance to persons complaining of interference with wireless telegraphy.
    (2) In this section “interference”, in relation to wireless telegraphy, has the same meaning as in the Wireless Telegraphy Act 1949 (c. 54).

    There is a clear statement that Ofcom shall provide a service consisting of giving advice and assistance to persons complaining of interference; Ofcom's patent refusal to provide such assistance to many amateurs who have complained about interference, of many varieties, would again appear to be a failure to fulfill its statutory duties.

    That's enough time spent on wading through the morass of the Communications Act 2003; I'm off to see if I can hear and work any DX through the VDSL interference on 30m... :)

    Martin G0HDB

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