Sure, David, I will chime in.
You are wrong.
The exemptions in Sec 15.103 talk about utility equipment, but any device
installed in subscriber premises is not exempt.
Solar systems are Part 15 unintentional emitters because the switching
supplies, inverters, optimizers and the various digital control circuitry used
are all digital devices. They are being installed in residential environments
so they need to comply with Class B limits. See Sec. 15.101 to see how and why
the circuitry in a solar system is characterized as a unintentional emitter and
is therefore regulated by Part 15 emissions limits.
One might be able to characterize the large solar farms s being included in the
language of Sec. 15.103, but not residential solar systems. They are regulated,
plain and simple.
And even "exempt" devices must comply with the Part 15 rules about harmful
interference.
And, btw, although ARRL staff do read some of this traffic, there is no
guarantee that HQ staff will read every word of every thread, so communicating
with ARRL should be done directly, not by posting requests at the end of a
comment asking HQ staff to respond.
Ed, W1RFI
-----Original Message-----
From: RFI <rfi-bounces+w1rfi=arrl.org@contesting.com> On Behalf Of David
Eckhardt
Sent: Thursday, December 16, 2021 3:17 PM
To: Cianciolo, Paul, W1VLF <pcianciolo@arrl.org>
Cc: Rfi List <rfi@contesting.com>
Subject: Re: [RFI] Noise from Generac Solar controllers?
There are total exemptions for anything permanently connected to the power grid
(I'm not going to look that up yet again......). However, in a dedicated
single-family home which does not feed back to the power grid, there are no
rules. Even FCC Part 15 does not apply. If they are declared as "computing"
or "information technology equipment - ITE", then, yes, Part
15 home and small office (Part B) applies. But even as a home-dedicated
electronic device, it would be a stretch for Part 15 applicability. FCC has
yet to specifically address the solar power industry as a whole or formally
point out specifically where the existing rules apply to the whole segment.
ARRL: PLEASE chime in on this issue.......PLEASE? I know
you read these emails.
Dave - WØLEV
Dave - WØLEV
On Thu, Dec 16, 2021 at 7:14 PM Cianciolo, Paul, W1VLF <pcianciolo@arrl.org>
wrote:
> Dave,
>
> Actually this is not BS...however it is a little deceiving. Check out
> this PDF on a typical Generac inverter.
>
> https://a1solarstore.com/index.php?dispatch=attachments.getfile&attach
> ment_id=441
>
>
> Scroll down to the section that’s refers to standards compliance
> quoted
> here:
>
> "SAFETY: UL 1741 SA, CSA 22.2 #107.1, UL 1998 GRID CONNECTION
> STANDARDS: IEEE 1547, Rule 21, Rule 14H, CSIP, UL 1741 PCS CRD (Import
> Only, Export Only)
> EMISSIONS: FCC Part 15 Class B"
>
> Here in lies the rub. Yes they do pass FCC compliance emissions limits
> for 15 B but 15B does not cover radiated emissions, only conducted
> emission put onto the power lines.
> So yes they do pass. Does that mean they do not generate RFI,,,
> Absolutely not.
>
> There are 2 main noise generating components in a solar power system.
> Both are tasked with power conversion which for efficiencies sake is
> done with very fast rise times... and we know what that means. Harmonics.
> The 2 components are the "optimizers" and the line inverter.
>
> Solar Edge uses a different topology than Generac however both use
> "optimizers" Solar Edge uses 10 optimizer per panel usually at the
> 300 watt +/- level 20 panels = 20 optimizers. The classic 200 kHz
> problem
>
> Generac uses a similar but different topology. Several panels to a
> single optimizer. This means the optimizer is running at the kilowatt
> level or so.. say 20 panels and 4 optimizers.
>
> All this is happening on the DC side of the solar power system, not
> subject to the 15B conducted emissions requirements. When you are
> switching mult-kilowatt level power with fast rise times, there is
> going to be RFI.
> BTW Generac systems manifest themselves as having harmonic energy at
> 39 KHz intervals. This the switching frequency used in the optimizers.
>
> The line inverter in some topologies can and is another issue... But
> again, the line or AC side meets conducted emissions.
>
>
> 73,
>
> Paul Cianciolo, W1VLF
> ARRL Product Review Test Engineer
> Formerly RFI engineer, having dealt with both SE and Generac many
> times
>
>
>
> ARRL - The national association for Amateur Radio™
> 225 Main Street, Newington, CT 06111-1400 USA
> Telephone: (860) 594-0210
> FAX: (860) 594-0259
> Email: w1vlf@arrl.org
> World Wide Web: www.arrl.org
>
>
>
>
>
>
> -----Original Message-----
> From: RFI <rfi-bounces+pcianciolo=arrl.org@contesting.com> On Behalf
> Of David Eckhardt
> Sent: Thursday, December 16, 2021 1:46 PM
> To: Tony <73guddx@gmail.com>
> Cc: Rfi List <rfi@contesting.com>
> Subject: Re: [RFI] Noise from Generac Solar controllers?
>
> If someone on this lest knows of the FCC regulation(s) addressing the
> solar industry, please let us all know. To my knowledge, so far,
> there is nothing addressing the solar industry. ARRL, is there
> anything addressing this RFI source?
>
> Dave - WØLEV
>
> On Thu, Dec 16, 2021 at 6:44 PM David Eckhardt <davearea51a@gmail.com>
> wrote:
>
> > QUOTE: " For what it's worth, I contacted Generac on N1UK's behalf
> > and the gist of the conversation was that their equipment meets all
> > FCC requirements which is the standard answer you'll get from most
> > if not all solar equipment manufacturers. I'm sure you'll get the
> > same answer if you ask your Generac salesmen about RFI."
> >
> > This is BS as the FCC has no specific regulations for the whole
> > solar industry.
> >
> > Dave - WØLEV
> >
> > On Thu, Dec 16, 2021 at 6:31 AM Tony <73guddx@gmail.com> wrote:
> >
> >> Ken:
> >>
> >> I know of several hams who are experiencing RFI caused by Generac
> >> home solar. In each case, the interference turned out to be
> >> emanating from a neighbors installation. In one particular case,
> >> Mark N1UK, experienced RFI from a neighbors system located 400 feet
> >> from his home. His neighbor had the system installed mid-summer I
> >> believe and I don't know if the issue was resolved. You can find
> >> Mark's contact
> info on QRZ.
> >>
> >> Most home solar systems share like-components so they all have the
> >> potential to cause RFI regardless of the brand. At least one
> >> company specifically warns against installing solar panel systems
> >> near ham radio installations and that's SolarEdge. The quote below
> >> was taken from a SolarEdge document titled: "Installing a
> >> SolarEdge System near an Amateur Radio System".
> >>
> >> It says in part:
> >>
> >> "/due to the afore-mentioned factors and to the higher sensitivity
> >> and physical layout of HAM radio equipment, we have seen in the
> >> past installations where the noise level measured by HAM radio
> >> operators was above the urban ambient noise especially, in the 6M
> >> band and lower frequencies, while having a much lower noise level on the
> >> 2M band.
> >> *Therefore we do not recommend the installation of SolarEdge
> >> systems at sites where HAM radio equipment is installed. * / / /
> >> For what it's worth, I contacted Generac on N1UK's behalf and the
> >> gist of the conversation was that their equipment meets all FCC
> >> requirements which is the standard answer you'll get from most if
> >> not all solar equipment manufacturers. I'm sure you'll get the same
> >> answer if you ask your Generac salesmen about RFI.
> >>
> >> Best of luck,
> >>
> >> Tony -K2MO/
> >> /
> >> /
> >> /
> >>
> >>
> >>
> >>
> >>
> >>
> >>
> >> On 12/16/2021 12:06 AM, Ken Bandy, KJ9B wrote:
> >> > Hi all. I am contemplating having a “PowerHome Solar” power
> >> > system installed at my house, and am a little concerned about
> >> > possible RF noise generation from the system. This system uses a
> >> > Generac
> controller.
> >> Does
> >> > anyone have any experience with a system using a Generac
> >> > controller? I
> >> know
> >> > early inverters were often RF noisy, but I’m hoping that the
> >> > later
> >> models
> >> > have addressed noise generation.
> >> >
> >> > Any input is appreciated.
> >> >
> >> > 73,
> >> > Ken, KJ9B
> >> >
> >> >
> >> > _______________________________________________
> >> > RFI mailing list
> >> > RFI@contesting.com
> >> > http://lists.contesting.com/mailman/listinfo/rfi
> >>
> >> _______________________________________________
> >> RFI mailing list
> >> RFI@contesting.com
> >> http://lists.contesting.com/mailman/listinfo/rfi
> >>
> >
> >
> > --
> > *Dave - WØLEV*
> > *Just Let Darwin Work*
> >
> >
>
> --
> *Dave - WØLEV*
> *Just Let Darwin Work*
> _______________________________________________
> RFI mailing list
> RFI@contesting.com
> http://lists.contesting.com/mailman/listinfo/rfi
>
--
*Dave - WØLEV*
*Just Let Darwin Work*
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