SolarEdge optimizers can make RFI covering most of the 20 meter band even when
they are idling with the main inverter off, or before they are connected in a
new system. The voltage on the input side of the optimizers from the solar
panels activates them. This is the mess that showed up at my QTH on August 26,
2016 when a neighbor was having a SolarEdge system installed. I used a SDR
screen shot of this as Figure 3 in my May 2019 QST article
http://www.arrl.org/files/file/QST/This%20Month%20in%20QST/May2019/Standke2a.pdf
Note the "squiggles" all over the band. To get a little more information on
this issue, I picked up a used SolarEdge optimizer model P320 and simulated it
idling (without the main inverter) by replacing the solar panel with a power
supply. I saw the same RFI all over the band connecting the optimizer leads
through an attenuator to a SDR receiver that I saw over the air from this
neighbor. About one year later I had a similar problem on 15 meters from
another neighbor. So, SolarEdge optimizer RFI can't be turned off. It is gone
when it is dark outside. It is also still there when they come out and do the
twisted wire and ferrite fix and miss one of more optimizers. It took them
four visits to fix one of my neighbor's systems because they did not filter all
the optimizers on the previous three visits. At least the good news is the RFI
is almost completely gone when every single optimizer is filtered.
If I was you, I would call the repair people back and tell them they must have
missed one or more optimizers because that is what your symptoms seem to
indicate. Maybe first confirm with a portable radio that the RFI is strong in
front of that address.
Randy KQ6RS
-----Original Message-----
From: RFI <rfi-bounces@contesting.com> On Behalf Of Tony
Sent: Tuesday, December 17, 2019 6:48 PM
To: Tony Brock-Fisher <barockteer@aol.com>; Rfi List <rfi@contesting.com>;
Cianciolo, Paul, W1VLF <pcianciolo@arrl.org>
Subject: Re: [RFI] Update: Tesla's Response to Solar Panel RFI
Ed:
My case with SolarEgdge is the one that has not been resolved so I'd like to
ask you a few questions and respond to the confusion regarding the RFI from my
neighbors system continuing after it was disconnected.
I was at the site each time the crew attempted to fix the RFI issue and they
NEVER disconnected all of the solar panels from the system at one time. They
instead worked on one section at a time so the majority of panels and
optimizers remained in service, hence the noise.
The SolarEdge tech at the site said that the system continues to generate noise
as long as the optimizers are connected to the solar panels. I have the emails
from SolarEdge confirming this.
The only effect I noticed during the process was a fluctuation in the noise
when they handled the panels and cabling.
I've asked many times if they would disconnect / disassemble the entire system
as a process of elimination in order to isolate the noise, but they said it
wasn't necessary.
As far as the source of the noise, I was present the day they installed the
system in 2016 which is when the noise began. At S-9 plus, the source was
blatantly obvious then as it is now. Seeing the noise fluctuate as the crew
handled the panels also confirms the source.
Please correct me if I'm wrong, but after reading your post, there doesn't seem
to be anything in regulations that would force SolarEge through to fix the
problem as long as their devices meet FCC emissions standards.
So what recourse do amateurs have in a scenario like mine where the noise
renders HF unusable? I can't sue them on a retirees pension.
Thanks for your time.
Tony -K2MO
On 12/17/2019 1:55 PM, Hare, Ed W1RFI wrote:
> Let me see if I can put this into perspective.
>
> First, there are a number of factors here that are not usually made part of
> the discussions about solar arrays that are being installed. The first is
> the applicable FCC rules. These are regulated by Part 15 of the FCC's rules.
> Under the rules, they are "unintentional emitters," devices that
> intentionally internally generate RF signals (> 9kHz), but that do not
> intentionally radiate them. As unintentional emitters, the manufacturer is
> subject to the following regulations:
>
> 1, They must meet radiated emissions limits. These apply ONLY above 30 MHz.
> They are set at a level such that from a "legal" device next door, one might
> see about S7 noise on 6 or 2 meters.
> 2. There are NO radiation limits below 30 MHz.
> 3. Below 30 MHz, the FCC controls interference by limiting the amount of
> noise that can be placed on the AC mains through limits on conducted
> emissions. This includes ONLY the ac mains and there are no limits to the
> conducted noise that may be present on the wires leading from the
> solar-system electronics to the panels.
> 4. The system must use "good engineering practice,' whatever that means. This
> generally means that if they make any attempt at filtering, such as a few
> strategically located capacitors, they would probably be considered as having
> met this requirement. I have never seen FCC take any action related to "good
> engineering practice.
>
> Incidental emitters are not subject to certification by the FCC. Older
> designs were brought forward under the "Verification" authorization in the
> old rules, and today, more likely through a manufacturer's declaration of
> conformity. Both are, in essence, self-tested and self-policed.
>
> This is a key here, because from all indications, the devices meet the
> conducted emissions limits below 30 MHz, so any radiation from the system is
> not directly covered by FCC rules.
>
> We don't like the current limits, but they have been in place for decades,
> and it is highly unlikely that FCC will ever seek to change them. But in
> planning what to do, it is critical that Amateurs fully understand just what
> does and does not apply to the manufacturers. Any claims that these devices
> are in and of themselves illegal appears to be incorrect, because from all
> indications, they meet the requirements for radiated and conducted emissions.
>
> The rules then require that the operator of the device, ie the neighbor and
> possibly the solar provider, use them in a way that does not cause harmful
> interference. First, harmful interference is defined as the repeated
> degradation of a non-emergency service, or any degradation of emergency
> communications. It is often in the eye of the beholder. FCC, for example,
> has typically deemed that noise that is below the median values of man-made
> noise described in ITU-R P372.12 is not harmful interference; it is just
> noise. This is typically about S6 on 40 meters, so any "marginal" cases are
> apt to not pass through the FCC process much past advisory letters. Even
> more key, if the devices meet the radiated and ac-mains conducted limits,
> there is no enforcement even possible against the manufacturer. If there is
> harmful interference, as defined by the rules, then the operator of the
> device must correct it, as ordered by the FCC. So, in trying to address this,
> the manufacturer would be well within its rights to claim that it meets the
> rules and, from there, any action it took would be voluntary. The operator
> is still responsible.
>
> Tesla and the FCC are NOT saying that systems can be put in whether there is
> interference or not; they are saying that the POTENTIAL for interference is
> not a reason for people to not be permitted to install solar systems. This
> is correct. There has always been a potential for Amateurs to cause
> interference to over-the-air broadcast, even from transmitters that meet the
> rules, but that potential is not enough to preclude Amateurs from installing
> stations in residential environments. Tesla and FCC are saying the same
> thing.
>
> Solar Edge is essentially the manufacturer of these products. So far, they
> have truly stepped up to the plate in a way that I believe should be
> appreciated, not criticized. Yes, there systems are among the noisy ones,
> but they have been working with Amateurs, installing new panels, optimizers
> and filters, and virtually all of the cases that ARRL has heard about have
> been resolved correctly. Paul Cianciolo, W1VLF, has been involved with them
> for almost a year now, and they are continuing to resolve problems on a
> case-by-case basis. Now, the scheduling for doing that can sometimes be
> several weeks out, but they are not avoiding all responsibility and are, to
> the contrary, stepping up in a way that I think we wish all manufacturers
> would.
>
> We know of one case that remains unresolved. In this case, we are getting
> different stories from the amateur and from Solar Edge. Now, so far, the
> stories we get from both sides have been in very close agreement, but in this
> case, Solar Edge has visited the site at least three times, replaced panels
> and optimizers, as we have seen done in other cases that were 100%
> successful, including at W1VLF's own home. According to the Amateur, even
> when the system was disconnected, there was still noise, and this is
> dramatically different from what Paul experienced when they did these fixes
> to his own home installation. Anything is possible, including the
> possibility that something was left energized to the possibility that there
> is some other noise source other than the one being worked on. ARRL is
> continuing to work with Solar Edge and this complainant, because we want to
> get to the bottom of this.
>
> We do NOT want to lose the cooperation we have with Solar Edge. Every case
> that becomes an FCC matter, though, runs the likelihood that company lawyers,
> not engineers, will be asked to solve the problem. This case is one in point,
> because I can clearly see the hand of the legal department in writing that
> letter. It is correct; they have tried really hard to fix this, there is
> question and disagreement about the source of the interference and yes, the
> POTENTIAL for interference that exists with nearly any device is not a legal
> reason to stop homeowners from installing systems. ARRL is doing all it can
> to try to keep this on track, and will, as needed, be prepared to some field
> work to try to get to the bottom of differences of opinion. The more
> "official" this gets, the more the lawyers will be involved and we well may
> be one legal decision away from lawyers telling engineers to stop all the
> cooperation, or at least to run each and every step through the Legal
> Department. I have the results of that, and it ain't pretty. I want to keep
> this on the technical level, and we will all be better off if we do.
>
> Ed Hare, W1RFI
> ARRL Lab
>
>
>
> -----Original Message-----
> From: RFI <rfi-bounces@contesting.com> On Behalf Of Kim Elmore
> Sent: Monday, December 16, 2019 4:26 PM
> To: Tony <dxdx@optonline.net>
> Cc: Rfi List <rfi@contesting.com>
> Subject: Re: [RFI] Update: Tesla's Response to Solar Panel RFI
>
> She still doesn’t get it. It’s not a zoning issue. I think you should also
> contact the FCC agent and speak with him directly to make sure it’s
> understood that you’re a licensed amateur.
>
> Kim N5OP
>
> "People that make music together cannot be enemies, at least as long
> as the music lasts." -- Paul Hindemith
>
>> On Dec 16, 2019, at 3:20 PM, Tony <dxdx@optonline.net> wrote:
>>
>> All:
>>
>> I received the following updates from Tesla's Ms. Holmen regarding the RFI
>> being caused by their solar panel installation. The good news is that she
>> will be meeting with SolarEdge on Wednesday. The bad is that she continues
>> to deflect and place the blame elsewhere.
>>
>> See below.
>>
>> Tony -K2MO
>>
>> __________________________________________________
>>
>> Ms. Holmen:
>>
>> With the information supplied to me by you and your neighbor
>> it has been determined this is purely a civil dispute between
>> neighbors. Tesla and SolarEdge have done their due diligence
>> to assist in your interference concern.
>>
>>
>> I recommend that you speak with an FCC agent regarding this matter.
>> It has nothing to do with a dispute - it's a matter of federal
>> regulations. https://www.fcc.gov/about/contact
>> <https://urldefense.com/v3/__https:/www.fcc.gov/about/contact__;!!Oq3
>> sn3U_Ofw!OgagJz_-_eM1HnZ0bMZR153PFADFP7_TJqnYRA60c6EY2dchdtvKrYoiDamM
>> $>
>>
>> I've attached a letter that was sent to SolarEdge headquarters in February
>> of 2017. The document explains the issue of radio frequency interference
>> caused by solar panel installations and the FCC's role in such matters.
>>
>> Response:
>>
>> Hi Mr. Bombardiere,
>>
>> Thank you for your email. I did speak with the FCC on Thursday of last week.
>> They did advise that a homeowner has the right to install solar on their
>> home regardless of potential interference. I advised the agent on the line
>> about the amateur license being help by the neighbor, and they again
>> informed me that the homeowner wishing to have solar is still allowed to
>> install it on their home. Jonathan was the name of the agent I spoke to.
>>
>> I do have a meeting with SolarEdge scheduled on Wednesday, December 18, 2019
>> to discuss the troubleshooting options and what was installed on your
>> neighbors home.
>>
>> Both SolarEdge and Tesla did their due diligence on this matter attempting
>> to fix this issue. I can inform you of the information I receive in this
>> meeting if you would like me to.
>>
>> The only options I have at this time are removing the solar system and
>> cancelling your neighbors agreement or reducing his system size. Both of
>> these options will come at a cost.
>>
>> _____________________________________________________________________
>> ___
>>
>>
>> Ms. Holmen:
>>
>> Thank you for taking the time to investigate further. With all due respect
>> to the FCC agent, he should have informed you about the FCC regulations that
>> pertain to electronic devices that cause RF interference.
>>
>> If this same Tesla installation was causing interference with Fire or Police
>> communications, the FCC would shut the system down immediately until the
>> problem was fixed.
>>
>> While the customer has every right to have solar panels, I'm sure you
>> understand that licensed FCC operators like myself have rights as well.
>>
>> I want to thank you again for all you've done and continue to do to resolve
>> this issue. I'm confident that SolarEdge can come up with a solution.
>>
>>> I can inform you of the information I receive in this meeting if you would
>>> like me to.
>> Please do.
>>
>> Response:
>>
>> Hi Mr. Bombardiere,
>>
>> Thank you for your email. I did inform the FCC hotline specialist about
>> interference and about a neighbor with an amateur license.
>>
>> When it comes to commercial areas, the city has regulations that Tesla would
>> comply with. Your neighbor and you live in a residential area, therefore
>> residential solar is allowed to be installed.
>>
>> Fire stations, police stations and airports all have specific regulations
>> and are not in the heart of residential areas. Should these be within a
>> specific area, a city or township would block permitting and inspections for
>> these situations. I hope that I am explaining this information clearly.
>>
>> Please let me know if you have further questions. I will keep you informed
>> regarding the conversation I have with SolarEdge.
>>
>> Best Regards,
>>
>> *Ashley Holmen | Specialist, Executive Resolutions*
>>
>> 6611 Las Vegas Blvd S., Suite 200 , Las Vegas, NV 89119
>>
>> p. (650) 546-8110 | aholmen@tesla.com <mailto:aholmen@tesla.com>
>>
>>
>>
>>
>> _______________________________________________
>> RFI mailing list
>> RFI@contesting.com
>> http://lists.contesting.com/mailman/listinfo/rfi
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