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Re: [RFI] Update: Tesla's Response to Solar Panel RFI

To: Kim Elmore <cw_de_n5op@sbcglobal.net>
Subject: Re: [RFI] Update: Tesla's Response to Solar Panel RFI
From: "Hare, Ed W1RFI" <w1rfi@arrl.org>
Date: Tue, 17 Dec 2019 18:55:54 +0000
List-post: <mailto:rfi@contesting.com>
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 
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 

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

-----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__;!!Oq3sn3U_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>
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