[RFI] Another Solar Panel RFI System

[Hare, Ed, W1RFI]

To my knowledge, the senior staff at FCC have pretty much let the Enforcement Bureau do its job.  Laura Smith has pretty much said, in one case from a ham who literally demanded an answer from her, that the FCC would not consider S3 noise to be harmful interference in a residential environment, but the HQ staff did manage to make it clear that this still needs to be evaluated on a case-by-case basis. If the Chair had dictated that S9 was not harmful interference, then Smith would be stuck with that, which she is not.

Now, hams would make the case that S3 noise can be interference, and it can be, but the ITU-R has done decades of studies that show that the median value of human-made noise is more typically S6 in residential environments, so FCC knows that if it were to take firm enforcement action, it would probably not prevail with the ITU-R document pretty much saying that a higher-level is typical.  The attorney for the defendant would bring that out quickly.

Having said that, I know that Solar Edge is pretty much down to that level with its current designs. We still see issues, with legacy systems out there and with new systems and poor installation practices by the many installers doing the work.  Solar Edge is again going to try a new design it believes will be even quieter, so "big business" is not the automatic enemy and when we get cooperation of any sort, we are better off working with it and building on it than we are trying to fight it.

FCC is also rather cooperative, taking ARRL's well-vetted reports and issuing advisory letters to operators of noisy devices.  Even in cases of "S3" interference, when we can identify a single source of noise and demonstrate that it can be fixed, FCC has asked operators of these devlces to work with the amateurs to try to resolve it. We are honest with the FCC about the level of interference, but its staff have been sympathetic so far to the concept that if interference can be reasonably fixed, it is reasonable to ask for manufacturer or operator help in doing so. That is far more advisory than the usual letter, by necessity, but the FCC has been very helpful to us in trying to get cases resolved.

The key to these "lower levels" of interference receiving FCC encouragement hinges on the premise that the source can be reasonably fixed even though it is weak. That has been decided on a case-by-case basis, sometimes unfavorably to amateur radio, when the possibility of a reasonable fix is not immediately clear, or in some cases, where an amateur has made loud and sometimes too forceful demands that the FCC do just what the ham tells them to do.

More than the technical solutions, what I call "personal diplomacy" is a key to solving any RFI problem.

Ed Hare, W1RFI
ARRL Lab


________________________________
From: RFI <rfi-bounces+w1rfi=arrl.org at contesting.com> on behalf of Steve Dyer W1SRD via RFI <rfi at contesting.com>
Sent: Sunday, December 18, 2022 3:09 PM
To: rfi at contesting.com <rfi at contesting.com>
Subject: Re: [RFI] Another Solar Panel RFI System

Randy,

What is the source of this statement?

I find it unlikely the FCC Chair is commenting so specifically on this
issue.

If she is so familiar with this issue as to comment at this level of
detail, then it presents an opportunity to engage directly.

73,
Steve
W1SRD

On 12/18/2022 11:56 AM, wx5l at charter.net wrote:
> Recently Jessica Rosenworcel , FCC chairwomen has made a statement about
> issues with Solar Edge RFI and said that S-6 to S-9 is NOT harmful
> interference.

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