[RFI] Solar Panel RFI Awareness At Dayton

Sat May 28 04:54:45 EDT 2022

For FCC Part 15, CE limits for unintentional emitters apply from 150 kHz to 30 MHz.  They apply only to the AC mains, not the interconnecting wiring.

RE limits apply above 30 MHz, but if the free-running inverter/optimizer frequencies are below 1.705 MHz and there is no digital circuitry clocked above that frequency, it is not necessary to measure those emissions. (See CFR 47 Sec. 15.33(b)(1).

Solar systems are not certificated, but authorized under a Suppliers Declaration of Conformity. As such, the manufacturer is required to perform all of the testing required by Part 15 regulations and to keep the test data on file, providing it to the FCC on request. So they already must test it.  These manufacturers WILL give pushback if the FCC were to seek to lower the emissions limits and/or require additional testing such as a requirement to measure radiated emissions below 30 MHz, or to have to measure conducted noise on other wiring such as the wires connecting inverters to solar panels, etc.

Having said that, though, so far, most manufacturers ARE offering considerable cooperation to try to resolve harmful interference. Solar Edge has replaced over 500 systems in the field, completely removing panels, wiring, optimizers and inverters in houses and replacing them with improved models.  Generac has done the same on a much smaller scale and has indicated to ARRL that it wants to have its products operate way below the FCC emissions limits.

>From ARRL's experience in this, having investigated a solar system installed at W1VLF, the devices meet the current rules.  The noise coming from Paul's system was being radiated from the wiring running to the roof, not the AC mains.  Having said that, if a device that just meets the FCC conducted emissions limits below 30 MHz is installed in a neighbor's home, it is probable that about S7 noise to a nearby amateur will result.   To have emissions limits lower than the current rules would require about 40 dB of reduction, adding considerable costs to the filtering needed to manufacturer every unit sold.  This would apply to solar system and the $10 wall-wart charger people use to charge telephones, making that $10 charger into a $110 charger instantly.  The pushback to try to get limits that virtually prevent interference would be severe, and the lawyers involved would put an end to all cooperation, out of fear that demonstrating that systems can be fixed might strengthen a case that those fixes should be required to be installed in every system, irrespective of interference.

The premise of the rules is one of balance.  The FCC and manufacturers does not believe it to be appropriate to have limits low enough to prevent all interference.  Under the existing rules, the vast majority of devices manufactured are not involved in a harmful interference complaint if those devices meet the current rules.  The intent of the rules is to set limits that reduce the likelihood of interference to a small-enough number of cases that it is practical to resolve them on a case-by-case basis.  This also localizes interference, so if there is interference, is coming from a nearby premise, not coming from a mile away.

So, in my personal opinion, we should not seek try to change the rules.  The FCC is not likely to carve out separate rules for solar systems as opposed to all other unintentional emitters.  So any rules change would apply to the $10 power supply as well as to solar systems.  Attempts to change the limits would, IMHO, result in more pushback than could ever allow those rules to be changed.  An open rulemaking would also put an end to cooperation from at least some manufacturers, as we saw in the BPL days, where the pushback from industry was relentless.

Is this hopeless?  Not really. In the long run, getting some of what we want incorporated into industry standards may be the door opener needed.  As various standards are put into place that may begin to address things we would like to see in the rules, rules are more easily changed if standards support those changes than if one stakeholder that needs more protection than most stakeholders seeks to lower the limits.  This will take years, and the first of those standards is nearly ready for ballot -- the IEEE EMC Society sponsored a standard that covers the wide scope of describing how electric utilities should respond when they receive complaints of harmful interference to radio and television use near their systems.

The process of my idea to do this Recommended Practice to having an end standard took 5 years and ARRL intends to build on that, looking to have similar standards for other industries, such as solar.  Our work with at least three solar manufacturers at this point makes a good start at another Recommended Practice and two of the companies have expressed back general interest to my feelers.

Ed Hare, W1RFI

________________________________
From: Dale <svetanoff at earthlink.net>
Sent: Saturday, May 28, 2022 1:44 AM
To: Hare, Ed, W1RFI <w1rfi at arrl.org>; KD7JYK DM09 <kd7jyk at earthlink.net>; RFI Mail list at contesting.com <rfi at contesting.com>
Subject: Re: [RFI] Solar Panel RFI Awareness At Dayton

Ed and All on this list:

I have been following the various RFI threads over the past week or two as regards solar panel RFI and LED lamp RFI.  Let me state up front that I do not have a solar panel system at my house nor do any of my neighbors.  I avoid the LED problem by not having any in the house - incandescent, halogen, fluorescent tubes and CFL bulbs only.  Yes, old school but effective.

My main reason for posting this message is because I worked the "other side" of the RFI issue while at Rockwell Collins - military specs, specifically MIL-STD-461(x).  Test requirements that are generally applicable to land based, fixed applications (what most ham installations are) would be RE102 ("Radiated Emissions") and CE102 (:Conducted Emissions").  The specified frequency range for CE102 is 10 kHz to 100 MHz and for RE102 it is 100 kHz to 18 GHz!  Note: the CE102 specs are for emissions FROM the power leads of the device under test, and for RE102, they apply to both power leads and any interconnecting leads.

As others have mentioned, the costs to perform these tests and pass them are not trivial.  Thus, reality says that we hams should not expect any regulatory or voluntary relief from these interfering sources anytime soon (can you hear the screams of agony from the manufacturers?).  The good news is that if the ham is also the owner of the solar panel system, he or she does have some leverage in working with the installation contractor and/or the system manufacturer when it comes to resolving an RFI issue.  I also realize that some hams may attempt to perform some sort of filtering on power leads on their own.  Please do keep in mind that filters work on one or both of the following two principles: absorption and reflection.  Absorption occurs when elements of the filter absorb the undesired emissions and convert them to heat.  Reflection is when the filter returns the undesired emission energy back to its source.  In some cases, the reflected energy exceeds the capability of the device to handle the excess voltage and/or power, resulting in device failure.

One of the members of my local radio club is getting set to operate HF for the first time.  (All prior operations were as a Technician licensee - he has his General Class ticket now and is assembling a station.)  His house does have a solar panel installation.  He has had no problems with interference to his VHF operations, but he will soon learn about any HF RFI.  I'll pass along any issues that might be discovered.

73, Dale Svetanoff
WA9ENA
IEEE Life Member

-----Original Message-----
From: Hare, Ed, W1RFI
Sent: May 26, 2022 7:33 AM
To: KD7JYK DM09 , RFI Mail list at contesting.com
Subject: Re: [RFI] Solar Panel RFI Awareness At Dayton

>> But, please......PLEASE, if you are experiencing problems with a solar
>> power home installation, document it carefully and take it to the ARRL, NOT
>> FCC. FCC will ignore your problem submission. They listen, so far, to
>> ARRL.

If a complaint clearly involves amateur radio, the FCC won't ignore it; it will send the complaint to Laura Smith, who will, after a brief review to see that it involves amateur radio and appears to be an actual complaint, will send it to ARRL to undertake the work of evaluating the case and trying to help the involved parties resolve it.

> One of hundreds, of not thousands, of radio clubs in the US, but not
> from an affected user licensed by them, in response to a violation of
> their own rules, that in theory, only they enforce? Sounds legit...

ARRL is far from just one of hundreds or thousands of radio clubs in the US and the FCC is well aware of that. Many clubs and organizations are doing some exceptionally good things in amateur radio, and in their areas of competence they do more than ARRL could do for their parts of of amateur radio, but none those organizations do the wide range of what ARRL is undertaking and none have the paid staff, industry connections and decades of RFI experience ARRL has on staff and has access to through its work with other organizations. Not even close and if ARRL has a world-class RFI/EMC program, it is by intent and the support of more members than any club or organization has.

> Anyone have the link that was going around a few years ago
> where RFI issues were filed directly with the FCC for investigation,
> and enforcement? The process worked like this, as discussed
> extensively in this forum:

To my knowledge, that system never worked to do more than to collect some data to tabulate the number of cases for FCC reports. ARRL started inputting cases into the system and none of the amateurs ever received any communication from FCC about the case. It may work better now, but if that system worked, Riley never would have had to get involved in RFI cases and the FCC would not be continuing what he started through Laura Smith.

It would be interesting to see what happens with a fresh complaint, though, although it is not specific to amateur radio, so I am not sure it will get routed to Smith in the normal fashion.

Ed Hare, W1RFI

________________________________
From: RFI on behalf of KD7JYK DM09
Sent: Thursday, May 26, 2022 2:38 AM
To: RFI Mail list at contesting.com
Subject: Re: [RFI] Solar Panel RFI Awareness At Dayton

> But, please......PLEASE, if you are experiencing problems with a solar
> power home installation, document it carefully and take it to the ARRL, NOT
> FCC. FCC will ignore your problem submission. They listen, so far, to
> ARRL.

One of hundreds, of not thousands, of radio clubs in the US, but not
from an affected user licensed by them, in response to a violation of
their own rules, that in theory, only they enforce?

Sounds legit...

Anyone have the link that was going around a few years ago where RFI
issues were filed directly with the FCC for investigation, and
enforcement? The process worked like this, as discussed extensively in
this forum:

"you fill out an online complaint form with the FCC, the offender is
"red-flagged" in the computers as being a violator, and sent a notice to
resolve the issue. They are sent another letter in a couple of weeks or
a month or so asking both you and them how it was resolved and if done
to your satisfaction. If not, they give them a set time to resolve it,
then ask again, if not, maybe a couple more, if not resolved then they
start to send the threatening letters, quoting all sorts of violations
of Federal law, fines per incident per day, et cetera and inform them to
resolve it again and so forth. Once they are flagged, it doesn't stop
until YOU inform the feds it's now fixed. Since it's computerized, it's
automated and perpetual and doesn't stop until resolved and the "red
flag" is removed from their name."

I don't imagine many people want to get caught up in a scenario like the
movie "Brazil", and may go out of their way to resolve the issue, on the
other hand, they can ignore the process, and see how it plays out.

This looks like the current link, has a drop-down for interference:

https://consumercomplaints.fcc.gov/hc/en-us/requests/new?ticket_form_id=38844

Kurt

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