[RFI] Solar Panel RFI Video

Hare, Ed W1RFI w1rfi at arrl.org
Tue Aug 14 16:52:24 EDT 2018

I agree with Dave on this one; at least with respect to the solar systems being made by Solar Edge, a lawsuit is probably the last thing Amateur Radio wants to do.

First, there is clear and existing federal pre-emption of RFI matters, so state courts do not have jurisdiction.  A lawsuit, if one is even possible under these circumstances, can only be brought into federal courts.  

There is also the question of what is legal. Under Part 15 rules, the manufacturer must verify (and now declare) that its design meets conducted emissions limits below 30 MHz and radiated emissions limits above 30 MHz. Conducted emissions limits apply only to noise conducted onto the ac mains.  Under FCC rules for this type of device, there are no radiated emissions limits below 30 MHz. The manufacturer must also meet certain labeling requirements.  Testing is done under laboratory conditions, with the presumption that the emissions will be similar for systems as installed. This isn't always the case, but the burden of proof that systems are exceeding the limits, if they are, in the field, would be upon the person making the claim that limits are not being met.  To be credible, this would need to be done by a qualified lab, in the field, at a cost of several tens of thousands of dollars.

These are the only requirements a manufacturer needs to meet.  It is then the responsibility of the operator of noisy devices to resolve interference.  

Some manufacturers are willing to assume responsibility for that on behalf of their customers.  For the most part, Solar Edge is doing that. They have been in regular contact with Mike Gruber here in the ARRL Lab. They have developed solutions and have used them to fix a number of problems.  For the most part, that has worked, and right now, the door is open to try to find better ways to resolve the remaining problems. In one recent case, the factory engineers visited a site and determined that the attempts to fix it included an error of not applying the cures to all the optimizers. No court action would have prevented that mistake, but it would probably have prevented finding that mistake, as every single aspect of every case would not involve lawyers.

If every manufacturer of every product responded to RFI complaints, we would be delighted, so I want to see the present course run its course, and continue to be strengthened.  As we learned in the BPL days, this is best done through cooperation, as industry often rises to its highest ideals and resolves problems that some think are intractable.

Ed Hare, W1RFI

-----Original Message-----
From: RFI [mailto:rfi-bounces at contesting.com] On Behalf Of Dave Cole (NK7Z)
Sent: Monday, August 13, 2018 7:41 PM
To: Mike Kirkland
Cc: Rfi List
Subject: Re: [RFI] Solar Panel RFI Video

Mike (NS6Q),

I well understand your frustration with your RFI issues...  I am many months out in not being able to use HF at all due to RFI.  I am frustrated beyond belief.  Why?  My hobby of 50 years is now at an end until the FCC corrects the issue, I may not get Honor Roll as a result of this, I am 65, my time is running short.  The next sunspot peak may be my last...  You bet I am pissed, but I am also careful, and thoughtful, and I want a solution that sticks, and more importantly is good for the Amateur Community as a whole.

All of that said, I still believe we all need to take the slow careful, thoughtful, non contentious, (maybe a little contentious), path...

If we are not careful, we very easily could create an environment in which it takes a court order to get ANY assistance from ANY vendor for any RFI issues, by simply uttering the words "Class Action".

Imagine if you were a vendor and you were working with the Amateur Community and suddenly you get wind of a Class Action law suit.  Or you hear that a class action law suit is being discussed, and being suggested on a mail list.

What would you as a vendor do?  Why you would most likely instantly get your lawyers involved, if for no other reason than out of fear for the impending Class Action suit.

Once the lawyers are involved every single word a vendor utters, every single deed a vendor performs, every single piece of paper a vendor publishes would need vetting by those lawyers.

You would end up signing paperwork indicating that the RFI problem was fixed, only to find later that you missed that spur on your favorite 6 meter DX frequency, and you find you have no recourse because you signed that paper in order to get the free work done to suppress the RFI you complained about.  You get the picture...

You think it takes too long now, just wait until the vendors get jumpy and thinking they need lawyers to even speak to us.  That is not good for the Amateur Community, not good at all!

The reality of this is we are lucky the FCC helps us at all.  As I said upthread, I am told that the VE land version of the FCC does not do a thing for RFI, nothing, no enforcement of any kind when it comes to Amateur reported RFI.  Period.  Nothing...  Think about that-- you alone vs. whoever with zero help, and zero leverage.

We are the little guy here, we have no big stick, we have nothing to force our hand, the only ace we have is the ARRL, and they are not that big compared to the lobbying entities for say broadcast, cell, and Solar.

So the only outcome of "Class Action" talk for Amateur Community will be to muck up the entire process for every Amateur Operator out there, ending any ongoing efforts to quench ongoing RFI issues, making discussions not possible without the thought of legal action in the back of the vendors mind.  This is not the environment I want to live in RFI wise.

We need to work with the vendors, not threaten them!  If we don't we will loose, and we will lose big!

Some of us are going to get hammered in this process, I am one of those getting hammered and it seems you are as well.  I am still willing to take the slow course in this until it is fixed, I hope you will reconsider your position.

73s and thanks,
Dave (NK7Z/NNR0DC)
ARRL Technical Specialist
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RFI at contesting.com

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