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

To: Tony <dxdx@optonline.net>
Subject: Re: [RFI] Update: Tesla's Response to Solar Panel RFI
From: David Eckhardt <davearea51a@gmail.com>
Date: Wed, 18 Dec 2019 03:18:30 +0000
List-post: <mailto:rfi@contesting.com>
FCC needs to face this square in the face.  *For HF*, nothing in the FCC
rules, Part 15 included, presently applies to a typical solar

On Wed, Dec 18, 2019 at 2:48 AM Tony <dxdx@optonline.net> wrote:

> 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__;!!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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*Dave - WØLEV*
*Just Let Darwin Work*
*Just Think*
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