The Electromagnetic Compatibility Committee of the Radio Society of Great Britain (RSGB) still has wide-ranging questions for UK telecommunications regulator Ofcom concerning new Wireless Telegraphy Act Section 54 regulations that address radio-frequency interference (RFI) from in-service equipment. RSGB said that while its latest response “largely reiterates” points it’s already made, it “still believes that a number of issues need resolution.” For starters, RSGB has asked the regulator to better define what the new regulations mean by “apparatus.”
Among other questions, RSGB wants to know “what is needed to get Ofcom to enforce against serious interference to Amateur Radio.” The Society pointed out that Ofcom has acknowledged its enforcement powers with respect to undue interference, but the agency has said that compliance regulations must be in place in Section 54.
RSGB allowed that there may be some cases where victims of interference may take “reasonable steps” to alleviate the problem; this may not always be possible when a radio amateur is the victim, and it asked Ofcom to clarify what is reasonable. “The re-siting of wire antennas in small gardens may be quite unrealistic, as may be the advice not to use a particular beam heading,” the RSGB said. “We should also like Ofcom to confirm that there is no obligation on amateurs to supply or pay for filtering or replacement of offending apparatus.”
RSGB also said it wants answers regarding in-service equipment excluded from the new regulations. For example, RSGB noted, cables used for such applications as DSL and power line telecommunications are not included, as they do not generate electromagnetic emissions. “However, when coupled to other apparatus and charged with signals at radio frequencies, unbalanced cables will generate emissions fortuitously,” RSGB said. “One of our members has posed the question that, if the cables increase the levels of emissions emanating from modems, then they must be at fault, so why have they been excluded? Emissions from VDSL at HF and at higher frequencies are becoming a major interference concern.”
RSGB also asked if Ofcom will use the new regulations to act against solar photovoltaic installations as being “improperly installed,” even when some of the apparatus is CE marked [i.e., European Union certified — Ed.] but the installation is causing severe or harmful interference nonetheless. “Even where [solar installations] are treated as collections of discrete ‘apparatus’ under [the Electromagnetic Compatibility Directive], Ofcom has simply walked away from cases saying they can do nothing as the ‘apparatus’ is CE marked,” The Society said.
For its part, Ofcom has said it does not have a duty to enforce and cannot guarantee that interference will not occur. “When deciding whether to investigate or to take enforcement action, we are required to act reasonably and responsibly and maximize the use of resources and do so in a proportionate, accountable, transparent, and consistent way. We treat each case on its merits.”