re: "the FCC long ago decided not to address radiated emissions below 30 MHz "
I didn't say it had to be an FCC accepted rule. I gave an example of a
'service'
that has such specs.
I propose something more along the line of an industry guideline, like an ASTM
'spec'. (OR equally, EIA/TIA spec etc.) It would be handy just to establish some
baseline "performance" of an un-tamed Solar Edge system versus a "tamed" one.
Call it benchmarks that could be useful at their factory when they do system
testing.
We can either mug-wump all this, or, actually do something useful, one small
step at a time. The problem, like a friend ham once put it, is getting all the
guineas (a small ground-dwelling bird) to progress in the same direction.
A number of ppl on the list have professed some familiarity with EMI
measurement,
but it appears this only extends as far as FCC regulations.
de AA5CT
.
.
On Tuesday, December 17, 2019, 11:07:16 PM CST, Kim Elmore
<cw_de_n5op@sbcglobal.net> wrote:
I think Ed (W1RFI) has cautioned us that the FCC long ago decided not to
address radiated emissions below 30 MHz and that they are unlikely to do so in
the future. As far as they’re concerned, the HF issue has sailed.
Either because they have no enforcement capability or because HF has been
commercially relegated to the scrap heap, we’re unlikely to get any changes in
FCC regs concerning HF emissions. As we read from W1RFI, there’s nothing in the
regs to compel SolarEdge, or any other entity, to address it.
Apparently, SolarEdge is doing so solely for altruistic reasons and altruism is
thin ice. To maintain that, we need to avoid involving attorneys because their
job is to minimize if not eliminate liability risk to their clients. As such,
I’m a bit surprised theor attorneys allow SolarEdge to even work the problem
because in doing so, SolarEdge has implicitly admitted some kind of
responsibility for cleaning up their HF RFI. It may be that no one has
consulted their attorneys and, if so, we should work to keep it that way
Kim N5OP
"People that make music together cannot be enemies, at least as long as the
music lasts." -- Paul Hindemith
> On Dec 17, 2019, at 9:42 PM, AA5CT via RFI <rfi@contesting.com> wrote:
>
> There are specs and standards for radiated EMI as well as antenna equipment
> (eg
> as untuned pickup loops and active E-field probes) designed to develop
> standard
> 'gain' for HF measurement receivers used below 30 MHz - but for mil
> (military)
> applications.
>
> The old Stoddart Aircraft Radio Company model NM-22A received from 30 MHz on
> down and was used with a set of antennas to measured radiated fields. Impulse
> noise
> peaks were measured using Peak and QP modes. The manuals for these radios
> included 'cal' charts showing how measured FS values translated into V/m
> (Volts
> per meter) standardized values with each different receive antenna.
>
> Maybe we need to look at something like that, before propositions for proposed
> standards are made?
>
> de AA5CT
>
> .
> .
>
>
> On Tuesday, December 17, 2019, 9:18:50 PM CST, David Eckhardt
><davearea51a@gmail.com> wrote:
>
> 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
> installation.
>
>> 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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>>>> http://lists.contesting.com/mailman/listinfo/rfi
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>>
>>
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>
>
> --
>
> *Dave - WØLEV*
> *Just Let Darwin Work*
> *Just Think*
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