Solar systems are not appliances.
Here are some excerpts from the rules:
15.103 Exempted devices.
The following devices are subject only to the general conditions of operation
in §§ 15.5<https://www.ecfr.gov/current/title-47/section-15.5> and
15.29<https://www.ecfr.gov/current/title-47/section-15.29> and are exempt from
the specific technical standards and other requirements contained in this part.
The operator of the exempted device shall be required to stop operating the
device upon a finding by the Commission or its representative that the device
is causing harmful interference. Operation shall not resume until the condition
causing the harmful interference has been corrected. Although not mandatory, it
is strongly recommended that the manufacturer of an exempted device endeavor to
have the device meet the specific technical standards in this part.
(b) A digital device used exclusively as an electronic control or power system
utilized by a public utility or in an industrial plant. The term public utility
includes equipment only to the extent that it is in a dedicated building or
large room owned or leased by the utility and does not extend to equipment
installed in a subscriber's facility.
(d) A digital device utilized exclusively in an appliance, e.g., microwave
oven, dishwasher, clothes dryer, air conditioner (central or window), etc.
The word "appliance" is not specifically defined in FCC rules, other than the
description in Sec. 15.103(d), but a system generating electricity using
digital devices to control power does not come close to any of the examples
provided.
It is (a) that suggests to me that large solar arrays MIGHT be classifiable at
an exempt device. It is a power system used by a public utility. It is not in a
"large room," but is on dedicated property owned or leased by the utility and
does not extend to any subscriber facility. I am guessing that if FCC were
pressed, that is what it would decide. We don't want to press them. I have
visted about a half dozen large solar array sites and found them all to be
rather quiet.
Ed, W1RFI
From: EDWARDS, EDDIE J <eedwards@oppd.com>
Sent: Thursday, December 16, 2021 3:28 PM
To: Hare, Ed, W1RFI <w1rfi@arrl.org>; Cianciolo, Paul, W1VLF
<pcianciolo@arrl.org>; David Eckhardt <davearea51a@gmail.com>; Tony
<73guddx@gmail.com>
Cc: Rfi List <rfi@contesting.com>
Subject: RE: [RFI] Noise from Generac Solar controllers?
Ed,
Now I remember that we did have this conversation a while back. Your
clarification implies that smaller, residential solar systems are designed to
use radio frequencies as part of their operation so they are not an incidental
radiator. Whereas Incidental radiators are not designed to use RF as part of
their operation.
In the future, if power companies who go mostly solar could be redefined as
unintentional emitters, could that loosen up requirements that they stop
harmful interference if that's what it does for smaller scale solar systems?
Why does the size of the electrical system matter at all?
I disagree with calling Solar Systems "appliances". Appliances are end-users
of electricity, not power generators. We don't call power plants appliances no
matter the scale. They don't even call smaller backup power generators
appliances in the industry. Sounds like the solar industry lawyers found a way
to use linguistics to get them looser RFI requirements by calling a power
generator an appliance like a washer/dryer or dishwasher.
As long as Part 15.3(m) still applies to all electrical systems, it's all just
legal semantics. I think Jim Brown points out the Part 15 failure of many
solar systems: They are not using good engineering practice and design to avoid
harmful interference as required by Part 15. The ones that do use proper
design do not cause RFI.
73,
Ed -K0iL
From: Hare, Ed, W1RFI <w1rfi@arrl.org<mailto:w1rfi@arrl.org>>
Sent: Thursday, December 16, 2021 1:43 PM
To: Cianciolo, Paul, W1VLF <pcianciolo@arrl.org<mailto:pcianciolo@arrl.org>>;
David Eckhardt <davearea51a@gmail.com<mailto:davearea51a@gmail.com>>; Tony
<73guddx@gmail.com<mailto:73guddx@gmail.com>>; EDWARDS, EDDIE J
<eedwards@oppd.com<mailto:eedwards@oppd.com>>
Cc: Rfi List <rfi@contesting.com<mailto:rfi@contesting.com>>
Subject: Re: [RFI] Noise from Generac Solar controllers?
________________________________
<Since electric power company's power generation, transmission and distribution
systems all fall under Part 15 Incidental Radiator regulations, wouldn't the
same thing to apply to an electric power solar system's power generation,
transmission and distribution systems? >
No. The solar systems are unintentional emitters under the Part 15 rules.
Ed, W1RFI
________________________________
From: RFI
<rfi-bounces+w1rfi=arrl.org@contesting.com<mailto:rfi-bounces+w1rfi=arrl.org@contesting.com>>
on behalf of EDWARDS, EDDIE J via RFI
<rfi@contesting.com<mailto:rfi@contesting.com>>
Sent: Thursday, December 16, 2021 2:36 PM
To: Cianciolo, Paul, W1VLF <pcianciolo@arrl.org<mailto:pcianciolo@arrl.org>>;
David Eckhardt <davearea51a@gmail.com<mailto:davearea51a@gmail.com>>; Tony
<73guddx@gmail.com<mailto:73guddx@gmail.com>>
Cc: Rfi List <rfi@contesting.com<mailto:rfi@contesting.com>>
Subject: Re: [RFI] Noise from Generac Solar controllers?
I think I mentioned this before, so forgive me for repeating this.
Since electric power company's power generation, transmission and distribution
systems all fall under Part 15 Incidental Radiator regulations, wouldn't the
same thing to apply to an electric power solar system's power generation,
transmission and distribution systems?
73,
de ed -K0iL
Eddie Edwards
Omaha, NE
-----Original Message-----
From: RFI
<rfi-bounces+eedwards=oppd.com@contesting.com<mailto:rfi-bounces+eedwards=oppd.com@contesting.com>>
On Behalf Of Cianciolo, Paul, W1VLF
Sent: Thursday, December 16, 2021 1:14 PM
To: David Eckhardt <davearea51a@gmail.com<mailto:davearea51a@gmail.com>>; Tony
<73guddx@gmail.com<mailto:73guddx@gmail.com>>
Cc: Rfi List <rfi@contesting.com<mailto:rfi@contesting.com>>
Subject: Re: [RFI] Noise from Generac Solar controllers?
Dave,
Actually this is not BS...however it is a little deceiving. Check out this PDF
on a typical Generac inverter.
https://urldefense.com/v3/__https://a1solarstore.com/index.php?dispatch=attachments.getfile&attachment_id=441__;!!AvPafw!ZQmS2D3N1B3KLYGH11sb9rRX9jGaVhymO4ubUy_wntm43sFZQBoGcHw9VQQDIw$<https://urldefense.com/v3/__https:/a1solarstore.com/index.php?dispatch=attachments.getfile&attachment_id=441__;!!AvPafw!ZQmS2D3N1B3KLYGH11sb9rRX9jGaVhymO4ubUy_wntm43sFZQBoGcHw9VQQDIw$>
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(tm)
225 Main Street, Newington, CT 06111-1400 USA
Telephone: (860) 594-0210
FAX: (860) 594-0259
Email: w1vlf@arrl.org<mailto:w1vlf@arrl.org>
World Wide Web:
https://urldefense.com/v3/__http://www.arrl.org__;!!AvPafw!ZQmS2D3N1B3KLYGH11sb9rRX9jGaVhymO4ubUy_wntm43sFZQBoGcHzDnwHh9w$<https://urldefense.com/v3/__http:/www.arrl.org__;!!AvPafw!ZQmS2D3N1B3KLYGH11sb9rRX9jGaVhymO4ubUy_wntm43sFZQBoGcHzDnwHh9w$>
-----Original Message-----
From: RFI
<rfi-bounces+pcianciolo=arrl.org@contesting.com<mailto: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<mailto:73guddx@gmail.com>>
Cc: Rfi List <rfi@contesting.com<mailto: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<mailto: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<mailto: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<mailto:RFI@contesting.com>
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>> > tinfo/rfi__;!!AvPafw!ZQmS2D3N1B3KLYGH11sb9rRX9jGaVhymO4ubUy_wntm43s
>> > FZQBoGcHztxMCjDQ$
>>
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>
>
> --
> *Dave - WØLEV*
> *Just Let Darwin Work*
>
>
--
*Dave - WØLEV*
*Just Let Darwin Work*
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