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Re: [RFI] John Pink's Comments Regarding Solar Panel RFI

To: Tony <dxdx@optonline.net>
Subject: Re: [RFI] John Pink's Comments Regarding Solar Panel RFI
From: David Eckhardt <davearea51a@gmail.com>
Date: Tue, 10 Jul 2018 20:58:48 +0000
List-post: <mailto:rfi@contesting.com>
Tony, some very good points.  I've worked EMC/RFI regulatory for some 30
years addressing world wide markets.

The largest problem in the USA is enforcement.  As far as FCC is concerned,
components (mostly from China) pass through our Customs with no expectation
what-so-even in addressing EMC/RFI (the FCC mark for home and small office
modules, Class B).  FCC exempts components.  As components from China
which, someday, somewhere, will ultimately be incorporated into an assembly
which will eventually be marketed and sold for profit.  At that point, the
FCC expects the system integrator, the entity that assembles all the
components into a salable product, to own the EMC/RFI requirement for the
assembly/product he/she markets.  The problem is, the system integrator
(component integrator) knows this costs money and time to have the
assembly/product tested in an accredited lab, and, worse, it might fail,
adding more money and delays.  The end result is that there is no attention
paid to EMC/RFI for these solar installations.  The end result is that
there is no regulation of RFI from these solar installations.
Unfortunately, it takes an act of our Congress (figuratively speaking) to
investigate a complaint.  The rules, radiated emission limits, and
requirements are in place, but they are ignored and not enforced.
Unfortunately, this also applies to most digital hardware in the USA.

Dave - WØLEV

On Tue, Jul 10, 2018 at 7:20 PM, Tony <dxdx@optonline.net> wrote:

> All:
>
> Informative reply from John Pink on solar panel RFI. Please see below.
>
> Tony -K2MO
>
>
> *From:* john_pink
> *Sent:* Monday, May 07, 2018 12:02 PM
> *Subject:* RE: NEC 2017 codes of practice.
>
> Bob, I read with interest your comments on the implications of NEC 2017.
> You said 'I hope I am not being alarmist' - I don't think you are - however
> you are tackling the issue on the wrong front.
>
> The issue that you need to raise concerns the 'standards' that govern the
> interfaces between panels and optimisers - and any other ancillary
> equipment.   There are IEC and IEEE standards that state the permissible
> levels of emission from the ports of these equipment, and the frequencies
> they use The standards are for the most part derived from standard agreed
> by CISPR.
>
> As a contributor to CISPR through my work at British Standards Institute,
> and CENELEC in Brussels, I am aware of many licenced radio amateur from the
> USA who are involved in this work.  In fact the lead representative for the
> USA on the subject of harvesting of solar energy is an active licensee. He
> is also involved with all aspect of Near Field charging of vehicle -
> another topic which should cause radio amateurs great concern.
>
> I would recommend two things.  Firstly that you encourage ARRL to increase
> its support for this important and valuable work, this may means financial
> support for the representatives, since the meetings are held around the
> world. ARRL need to sponsor 'experts' to ensure that the cost of travel is
> reimbursed.  ( RSGB has been very generous in this respect). Secondly, find
> a way, if this does not already exist, to become involved in NEC affairs -
> it should be possible to have ARRL representation involved in their work.
> The objective is to ensure that 'best practice' is used on all and every
> installation of Solar harvesting schemes.
>
> To summarise, the steps should ensure that the items of equipment
> (apparatus) are compliant with international standards that are designed to
> protect radio services, and then ensure that the equipment are installed in
> such a way that they do not negate compliance with the standard.  For
> example, if the equipment is connected with twisted pairs in order the meet
> the compliance test - the installer must follow the same practice - and so
> NEC 2017 (or later versions), must make that clear.
>
> Since every authorised installer should carry and be checked against the
> NEC installation practice, things will get better. However, I acknowledge
> that best practice is followed when safety issues are concerned - but
> rarely are rarely understood when EMC matters are important, and that it
> what you have to get across with NEC - and we have to get across here in
> Europe, where we face exactly the same challenge.
>
> All of this is an international effort, because for the most part Solar
> harvesting equipment is manufacturer around the world. Here in Europe the
> systems come from China or Germany.  Which means that it may be compliant
> with CENELEC requirements to carry the ubiquitous CE mark. Note that little
> word 'may', by which I suggest that there are ways around the compliance
> system - just as there are ways around FCC marking.
>
> CISPR  - Special International Committee for Radio Interference, affiliated
> with International Electro-Technical Commission (IEC)
>
> CENELEC   European Committee for Electrical Standards
>
> I hope this helps - do let me know if I can provide any additional
> background.
>
> John - G8MM, F5VKU
>
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>



-- 

*Dave - WØLEV*
*Just Let Darwin Work*
*Just Think*
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