Sorry for the delay in getting back to this one. Hopefully, folks are checking
emails.
To really understand this issue, we need to understand what rules these systems
meet.
Solar inverters and optimizers are regulated by CFR 47 Part 15 as unintentional
emitters. They are classified as digital devices. As such, they must meet the
Part 15 rules for emissions below 30 MHz that are conducted onto the AC mains
and the radiated emissions limits above 30 MHz. There are no radiated
emissions limits for any unintentional emitter except for carrier current
devices such as BPL. It will be hard sell to get the FCC to carve out radiated
limits below 30 MHz for one type of emitter. It will be a tough sell in any
event, because only a small number of unintentional emitters that meet the
rules are involved in harmful interference complaints. Industry and the FCC
will insist that the existing rules work, and, to a great degree, they are not
wrong. Many manufacturers that meet the limit respond positively to harmful
interference complaints.
If the FCC were to adopt radiated limits below 30 MHz, it would almost hang its
hat on the limits for intentional emitters and carrier-current devices, which
essentially result in S9+10 dB interference levels, typically. We do NOT want
this, and if the FCC extended the carrier-current limits to solar systems, the
first line of defense from manufacturers would be, "We meet the new rules."
ARRL already has a case where a new solar manufacturer is taking that very
approach.
Do not ignore the monkey-wrench effect. If there were an open rulemaking, it
is a certainty that every solar company would hire a communications attorney,
who would then direct that every step in any interference case go through the
attorney. That would effectively end cooperation, and muddy the waters so
badly the end result could be rather unpredictable.
Right now, ARRL has 2-1/2 solar companies working on resolving cases and
looking to improve the product. The League is also looking to form an
industry standards working group to develop an IEEE recommended practice on
good design for EMC for solar systems and a reasonable program to respond
effectively to complaints. If there ever were to be a rules change, this is
essentially the only way I could see the rules getting changed, if they can be
changed to harmonize with an industry standard that has the support of a wide
range of stakeholders.
I will have to look in the program to see when this gathering is taking place
and attend if I can.
Ed Hare, W1RFI
ARRL Lab
IEEE EMC Society Vice President for Standards
________________________________
From: Hare, Ed, W1RFI <w1rfi@arrl.org>
Sent: Thursday, May 12, 2022 8:04 AM
To: Don Kirk <wd8dsb@gmail.com>; KD7JYK DM09 <kd7jyk@earthlink.net>
Cc: rfi@contesting.com <rfi@contesting.com>
Subject: Re: [RFI] Solar Panel RFI Awareness At Dayton
I will have a lot to say about all of this, but need to get a few other things
done first. These issues are NOT as simple as asking for a rules change and
getting it. If that were possible in any meaningful way, it would have been
done long ago. Even putting that on the regulatory table could monkey-wrench
the ongoing work with the industry to clean up its act over and above what the
existing rules require.
More shall be revealed. 🙂
________________________________
From: RFI <rfi-bounces+w1rfi=arrl.org@contesting.com> on behalf of Don Kirk
<wd8dsb@gmail.com>
Sent: Wednesday, May 11, 2022 8:21 PM
To: KD7JYK DM09 <kd7jyk@earthlink.net>
Cc: rfi@contesting.com <rfi@contesting.com>
Subject: Re: [RFI] Solar Panel RFI Awareness At Dayton
Hi Kurt,
You said "We already have specific emissions values, I just suggest
lower.", but I don't believe there are radiated emission limits below 30
MHz, just conducted emission limits below 30 MHz in the US. If you
introduce radiated emission limits in the FCC rules for frequencies below
30 MHz then you do in fact risk overriding the protection we have with the
current "harmful interference" stipulation.
On the other hand maybe you're talking about reducing the "conducted
emissions" limits for frequencies below 30 MHz which would not necessarily
put the "harmful interference" stipulation in jeopardy.
Hopefully someone better educated on the current FCC rules will step in and
correct me if I've misspoken.
Just FYI,
Don (wd8dsb)
On Wed, May 11, 2022 at 2:06 PM KD7JYK DM09 <kd7jyk@earthlink.net> wrote:
> "Adding a specific emissions value to the regulations, and a value that
> would be a compromise that most hams won't like at all..."
>
> We already have specific emissions values, I just suggest lower.
>
> "...doesn't require removal of the words "harmful interference"."
>
> Right, a different issue, not related to emissions values already in place.
>
> "In fact adding the specific emissions value to the regulations would
> redefine those words and lock them in to that specific emissions limit
> value."
>
> No change in current regulations with specific emissions values (other
> than lower potential RFI levels), and unrelated to harmful interference
> enforcement.
>
> "So having "Harmful Interference" vague enough to account for these
> differences works better for the most hams than does setting a specific
> emissions limit that will be a compromise between ARRL and the
> commercial industry."
>
> There was no suggestion to separate, or remove any of this, or even
> compromise, just lower the potential of one other thing, with the hope
> it would have a broader affect overall.
>
> Imagine, RFI, being 1/10th, or 1/100th of what it currently is, with no
> other changes, removals, or compromises. RFI, at a fraction of what it
> is, that might be a good start...
>
> "Why is it so hard to understand that the commercial industry will have
> equal or possibly more influence in new regulation creation than the
> smaller ARRL probably will?"
>
> I don't believe for a moment that just one radio club would have an
> adequate affect on the matter.
>
> If we compare the relative size of the ARRL to the FCC and the entire
> global industry, one which has few abilities, control, enforcement, or
> incentive, another which doesn't even care, the ARRL (more specifically,
> "1.5 staff in the ARRL Lab have managed to be the focal point and do all
> the legwork for the cases that FCC does handles" per Eds April 5th post)
> isn't a large influencing group, not even a few fussy individuals,
> relatively speaking, I dare say, more of a vague memory, if anything at
> all, that someone made a comment about something, before others do as
> they always have, hence, my support of the suggestion of everyone else
> with an interest or concern of the issue, being involved at some level
> that matters, note, however, not in any counterproductive manner at all,
> as suggested by Dave.
>
> Kurt
> _______________________________________________
> RFI mailing list
> RFI@contesting.com
> http://lists.contesting.com/mailman/listinfo/rfi
>
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