Preface:

C.I.S.P.R. is the Special International Committee on Radio Interference of the International Electro technical Commission, IEC, with central office in Geneva, Switzerland. It is concerned with the development of standards regarding electromagnetic interference and most of these standards are adopted by the European Union and many other countries.

C.I.S.P.R. Project Team Dominated by PLT Lobby - Rationale Behind Proposed Approach Disproved
 
From Karl Fischer, DJ5IL http://cq-cq.eu/cispr22part2 : "While the first part of my report (http://cq-cq.eu/cispr22) explained how a CISPR Project Team (PT) tried to camouflage a planned 18 dB relaxation of Power Line Telecommunications (PLT) disturbance limits, which would seriously threaten radio services, this second part sheds a light on the composition of that very Project Team and on the findings of two Japanese scientists. Let the reader be reminded that "the primary aim of CISPR is the protection of radio services" according to its own strategic policy statement and that as a standardization body it is assigned to act accordingly by developing appropriate EMC standards.
 
What is expected of a serious Project Team which is assigned to protect public health by appropriate air pollution limits ? I think there is broad agreement that as the basic prerequisite it must be dominated by independent and dedicated health specialists and not by representatives of the automotive industry. Of course the same principle applies to any CISPR Project Team: it must be dominated by independent radio specialists with a deep understanding and rich experience in radio engineering, propagation and communication - and not by any industrial lobby. Does the CISPR PLT Project Team meet this requirement ?

Based on the Project Team member list published by the IEC as per 15 August 2008, I have investigated which backgrounds and interests hide behind the names:
 
Mr Jean-Philippe Faure (FR), Project Leader:
Co-founder of PROGILON which developed, manufactured and marketed powerline communication products and provided consultancy in PLC (Power Line Communications). Consultant for EASYPLUG, a THOMSON - SCHNEIDER ELECTRIC joint-venture and for ILEVO, a company of SCHNEIDER ELECTRIC POWERLINE COMMUNICATIONS. Currently acting as Vice-President Standardization at ILEVO, which is based in France and Sweden manufacturing PLC products based on DS2 chipsets. Chairman of two key groups for the development of the PLC industry: the IEEE P1901 Corporate Working Group and the CISPR/I PLT Project Team.

Mr Fujio Amemiya (JP):
Manager EMC Center, Access Networks Business Headquarter, NTT ADVANCED TECHNOLOGY CORP., a unit of NIPPON TELEGRAPH AND TELEPHONE CORP. (NTT).
 
Mr Serafin Arroyo (ES):
Standardization Manager at DS2, a global provider of PLC technology and HomePlug Powerline Alliance member. DS2 is project partner of OPERA (Open PLC European Research Alliance), the EU sponsored powerline project and consortium of 26 PLC project partners. Head of Delegation at international fora (ETSI, IEEE, ITU) and Vice-President of the UNIVERSAL POWERLINE ASSOCIATION (UPA). Spanish National Committe expert at IEC (CISPR) and CENELEC.
 
Mr Mark G. Arthurs (US):
SONY ELECTRONICS INC., Product Quality Division, EMC Group.
 
Mr John Boot (US):
Director of Standards at CURRENT TECHNOLOGIES, a major PLC technology provider.
 
Mr Werner Bäschlin (CH):
Member of former ASCOM SYSTEC AG, which in 2004 merged with ASCOM AG. Now at CURRENT TECHNOLOGIES INTERNATIONAL (CTI) Switzerland, a major PLC technology provider and OPERA project partner. ASCOM sold its PLC actvities to CURRENT TECHNOLOGIES in 2006, which now has a branch office at the former ASCOM SYSTEC AG headquarter site in Mägenwil, Switzerland.
 
Prof. Johan Catrysse (BE):
Head of the EMC laboratory at the CATHOLIC UNIVERSITY COLLEGE OF BRUGES - OSTEND (KHBO), Belgium.
 
Mr Jean-Luc Detrez (BE):
Chief Technical Consultant at INTEL CORPORATION SA, Belgium.
 
Karl Dietrich (DE):
SIEMENS POWER TRANSMISSION AND DISTRIBUTION (PTD). Promotes PLC for ICT-based energy systems.
 
Mr Victor Dominguez Richards (ES):
Co-founder and Business Development Director of powerline chipmaker DS2, which claims to be the world's leading supplier of chipsets for powerline and which is the designer of reference-standard chips for the UNIVERSAL POWERLINE ASSOCIATION (UPA).
 
Mr Lutz Dunker (DE):
GERMAN FEDERAL NETWORK AGENCY (BNetzA).
 
Mr R. T. Garrett (AU):
Marketing Engineer at TESTING & CERTIFICATION AUSTRALIA (TCA), owned by ENERGY AUSTRALIA, national market leader in electrical metering.
 
Mr Juan A. Garrigosa (ES):
Technology and Innovation Manager at ENDESA NETWORK FACTORY (ENF), developing and promoting PLC. ENF is owned by ENDESA GROUP, the leading utility in the Spanish electricity system and the number one private electricity company in Latin America. ENDESA is a PLC operator.
 
Mr Michel Goldberg (FR):
Research Engineer at ELECTRICITÉ DE FRANCE (EDF), a PLC operator and OPERA project partner. Board Member of the PLCforum Association, representing the interests of manufacturers, energy utilities and other organisations active in the field of PLC.
 
Mr Holger Hirsch (DE):
Professor at the UNIVERSITY DUISBURG-ESSEN, an OPERA project partner. Promotes narrowband and broadband PLC applications.
 
Mr Jacob Keret (IL):
Head of Research and Development at MAINNET COMMUNICATIONS LTD., Israel, a leading provider of PLC systems and solutions. Co-Inventor of US Patent 6927672 - Information Transmission Over Power Lines - for MAINNET.
 
Mr Peter J. Kerry (GB):
Former CISPR President and Director EMC Policy & Research Division at the RADIOCOMMUNICATIONS AGENCY (RA), the predecessor of the OFFICE OF COMMUNICATIONS (OFCOM), which is regulator and competition authority for the UK communications industries.
 
Mr Raouf L. Khan (CA): ?
 
Mr Michael Koch (DE):
Vice President Strategy and Regulation at POWER PLUS COMMUNICATIONS AG (PPC), Mannheim, Germany, a joint-venture between MVV ENERGIE AG, ABB and MAINNET, which exploits PLC technology in Germany. Promotes PLC within ETSI, CENELEC, CISPR and the PLCforum. Board member of the PLCforum, chairman of BITKOM (German association), and Vice-Chairman of ETSI PLT. Leader of the OPERA Work Package "Business Deployment" and member of the Steering and Technical Committee.
 
Mr Thilo A. Kootz (DE):
GERMAN AMATEUR RADIO CLUB (DARC).
 
Dr. Jeffrey A. Krauss (US): ?
 
Mr Philippe Lancelin (FR):
FRANCE TELECOM, second-largest internet accesss provider in Europe, PLC service provider.
 
Mr Trevor Morsman (GB):
BRITISH TELECOM, one of the world's leading providers of telecommunication services, PLC service provider.
 
Mr Romano Napolitano (IT):
Systems Engineer Distribution Division at ENEL, the second largest European power utility company and a PLC operator.
 
Dr. John Newbury (GB):
Head of the Power Systems Communications Research Group at THE OPEN UNIVERSITY, United Kingdom. IEC, IEEE, the European EMC Committee, CENELEC, ISPLC.
 
Mr Yves Ollivier (FR):
AGENCE NATIONALE DES FRÉQUENCES (ANFR), ETSI Reporter for ITU-R SG1, CEPT.
 
Mr Kunihiro Osabe (JP):
VOLUNTARY EMC LABORATORY ACCREDITATION CENTER INC. (VLAC), the Japanese accreditation body for EMC test laboratories.
 
Mr John Pink (GB):
RADIO SOCIETY OF GREAT BRITAIN (RSGB).
 
Mr S. J. Pretorius (ZA): ?
 
Mr Purva Rajkotia (US):
INTELLON, which is a HomePlug Powerline Alliance member manufacturing PLT chipsets for many vendors, for example for the German company DEVELO.
 
Mr Richard Razafferson (FR):
Research and Development at ORANGE, the key brand of FRANCE TELECOM, which is a PLC service provider.
 
Mr William Rhoades (US): ?
 
Mr Praneel Ruplal (ZA):
INDEPENDENT COMMUNICATIONS AUTHORITY OF SOUTH AFRICA (ICASA).
 
Mr John Ryan (GB):
PLC promoter and consultant to the ENERGY NETWORKS ASSOCIATION (ENA), the trade association for UK energy transmission and distribution licence holders.
 
Mr Saneh Saiwong (TH):
NATIONAL TELECOMMUNICATIONS COMMISSION, Thailand.
 
Andreas Schwager (DE):
Engineer for Home Networking at SONY Germany, member of the CE POWERLINE COMMUNICATION ALLIANCE (CEPCA).
 
Dr. Bernd Sisolefsky (DE):
GERMAN FEDERAL NETWORK AGENCY (BNetzA).
 
Mr Ronald L. Storrs (SE):
TELIA, the Swedish telecom operator and leading Nordic communication company, PLC service provider.
 
Mr Rasmus Trevland (NO):
NORWEGIAN POST AND TELECOMMUNICATIONS AUTHORITY (NPT).
 
Mr Christian M. Verholt (DK):
DANSK STANDARD, Danmarks national standardization organization. EMC Adviser for the INTERNATIONAL AMATEUR RADIO UNION (IARU).
 
Mr Eric Winter (ZA):
Owner of EMC ASSIST, EMC and regulatory consulting.
 
Mr Martin A. Wright (GB):
BT EXACT, the technology and IT operations division of BRITISH TELECOM (BT). Chairman CISPR I.
 
The result is that of a total of 42 Project Team members at least 22 - including the Project Leader - represent the PLT lobby (ILEVO, DS2, SONY, CTI, INTEL, SIEMENS PTD, TCA, ENF, EDF, UNIVERSITY DUISBURG-ESSEN, MAINNET, PPC, FRANCE TELECOM, BRITISH TELECOM, ENEL, INTELLON, ENA, TELIA). 6 members represent national regulating authorities which are regarding themselves more and more as spectrum management agencies trying to satisfy the ever growing demands of the markets - with the consequence that they are more and more neglecting and even denying the protection of radio services, which actually is their obligation in many countries, in favor of liberalisation and deregulation of markets. And only 3 members are dedicated representatives of a radio service, namely the amateur radio service, which is reresented by its international and two national associations (IARU, RSGB, DARC). I emphasize that I do not claim for the results of my investigations to be absolutely correct and up to date and I apologize for any possible errors. But despite any possible errors and the fact that the background of 4 members remains to be seen, there can be no doubt that the CISPR PLT Project Team is dominated by the PLT lobby. Therefore it does not meet the basic requirement and it is safe to assume that its proposals are favouring the interests of the PLT lobby and thus threatening instead of protecting the radio services.
 
PLC promoter and Project Team member John Ryan writes on the ENA wbsite http://2008.energynetworks.org/public-plc/ :
 
"[...] The new Broadband technologies such as ADSL and Powerline use existing wiring not originally designed for the purpose and the contentious issue is whether significant interference to radio might be caused. Powerline systems use the HF-band (short-wave), which is also used by the BBC World Service, some safety related services and radio amateurs.
 
However, some of these services are already moving to new delivery media, so there is also a new versus old technology issue. There are now significant deployments of broadband powerline systems in several European countries, with Germany taking the lead, despite the fact that this was originally a British invention.
 
Genuine complaints that are upheld by the regulator are few if any, despite an orchestrated campaign by radio amateurs. National regulators have robust powers to shut down any source of interference following a complaint [...]"
 
However, this is a misstatement which is exemplary for the ignorance of the PLT lobby regarding radio services and radio communication topics and which must be corrected:
 
1) It is implied that ADSL and PLC are comparable concerning their disturbance potential, which is not true. Though ADSL and PLC indeed both use existing wiring not originally designed for the purpose, the telephone line which is used by ADSL is in many ways much better suited for that misuse than the power line used by PLC and hence ADSL demonstrably causes much less interference than PLC.
 
2) The shortwaves are used by many radio services including the aeronautical, maritime, broadcasting, amateur, fixed, standard frequency, radio determination and radio astronomy services. And most of them rely on the unique feature of the ionosphere to bend and reflect radio waves in the shortwave part of the spectrum, which makes possible long-range and intercontinental radio communication even with very modest radio equipment. In appreciation of this fact, the ITU Radio Regulations (RR) as part of a binding treaty state that the shortwave bands are part of a limited natural resource (RR 0.3) and "particularly useful for long-distance communications" (RR 4.11), hence the ITU members are obliged and agreed "to make every possible effort to reserve these bands for such communications" (RR 4.11).
 
3) Shortwave radio still is and will remain to be important. It is the easiest way to reach people living abroad and in many countries it is the only way to communicate with people living in extensive undeveloped rural areas, just to name two of many reasons. And it should be clear that those radio services which rely on the unique features of shortwave can not and will not move to "new delivery media". In addition, the scope of many radio services goes far beyond the mere "delivery" of information. Therefore the protection of radio services is certainly not a "new versus old technology issue" - shortwave radio is alive and well as long as the precious shortwave spectrum is not spoiled by dirty technologies like PLT.
 
4) PLC trials and deployments have an inglorious and notorious history of interference problems, for example in the USA, the United Kingdom, Austria and Germany. In parts of the city of Mannheim, Germany, the reception of amateur radio and even broadcasting on shortwave is nearly impossible due to harmful interference caused by PLC. "Genuine complaints that are upheld by the regulator are few" simply because many administrations boost PLC due to political reasons and pressure from the PLT lobby and at the same time the regulating authority in many countries ironically is subordinate to the department of commerce, which is interested in a flourishing industry but not in the protection of radio services. And while it is partly true that national regulators have powers to shut down sources of interference, it is also true that most of them notoriously neglect complaints of individual broadcasting listeners and radio amateurs because they know only too well that they will hardly be sued for inactivity, simply because most individuals are not able to fight out an administrative lawsuit.
 
Many administrations and the PLT lobby seem to favour sort of postponed interference management where the protection of radio services is merely an option. This attitude does not only show a lacking sense of responsibility, it is also very opportunistic, shortsighted, dangerous and even illegal. For example, what happens if harmful interference is caused by the cumulated disturbances of a large number of individual PLT devices ? Who is responsible ? Which devices to shut down ? How to stop the harmful interference ?

In fact, protection of radio services is not an option but an obligation anchored within the ITU Radio Regulations as well as within the latest EU EMC directive.



At the symposium "EMC Europe 2008", held in Hamburg on 8-12 September 2008, the two Japanese scientists Masahiro Kitagawa (Graduate School of Engineering Science, Osaka University) and Masatoshi Ohishi (National Astronomical Observatory of Japan) will present their highly interesting paper entitled "Measurements of the Radiated Electric Field and the Common Mode Current from the In-house Broadband Power Line Communications in Residential Environment". They have investigated common-mode current (CMI) and radiated electric field strength (REF) caused by various commercial PLC adapters and found no causality between CMI or LCL and REF. They also found that CMI along the power line could exceed that measured at the modem output by more than 20 dB and that the differential-mode current (DMI) is the major cause for the REF, proving that REF or DMI must be regulated instead of CMI and at the same time disproving the rationale behind the CISPR/I/257/CD as well as the Japanese PLC regulation. They also show that the standing wave common-mode current measured at the PLC adapter output can be arbitrarily reduced by increasing the common-mode impedance of the adapter without reducing the radiated emission, which is a fatal loophole of the regulation.
 
These findings of the two Japanese scientists are a clear proof of what radio engineers already know and what can be calculated, simulated and demonstrated - namely that the common-mode current measured at any point on a network tells absolutely nothing about the possible current imbalance at any other point on the network or about the energy radiated by the whole network. If it could, a perfectly balanced and thus non-radiating transmission line feeding energy from a transmitter to a radiating antenna would be impossible. And by the same token, the common-mode current measured at the ISN tells absolutely nothing about the energy radiated by the whole power line network. It is blatantly obvious that not only the planned 18 dB relaxation of PLT disturbance limits would seriously threaten radio services, but that the regulation of common-mode current measured at an ISN according to CISPR/I/257/CD is through and through an invalid concept which serves PLC but which is completely unsuited to protect radio services. The adoption of such regulation would be a gross violation of the prime policy of CISPR and a clear infringement of the Radio Regulations as part of a binding treaty between ITU members.
 
This information paper is published on http://cq-cq.eu/cispr22part2 and distributed by email to a large number of amateur radio associations as well as organizations, companies, magazines and individuals concerned with radio. I urge all affected recipients to further circulate this information and to take any appropriate measures that could help to prevent the planned relaxation of PLT limits and adoption of the proposed method. These measures include protest notes and comments to the IEC/CISPR (info@iec.ch) as well as to the IEC National Committees which can be found on the List of IEC members (http://www.iec.ch/dyn/www/f?p=102:5:0). In addition, administrations should be informed and sensitized and at the same time reminded of the binding status of the Radio Regulations. I herewith declare that I undertake this information campaign as an independent idividual for the sole purpose to support all radio services and without pursuing any other goals."
 
5 September 2008:   http://cq-cq.eu/cispr22part2
 
Author and publisher:
 
Karl Fischer
Amateur Radio Station DJ5IL
Friedenstr. 42
75173 Pforzheim
Germany

Email: DJ5IL (at) cq-cq.eu

Website: http://cq-cq.eu

EMC Links

Ofcom - Reporting Interference Problems:  http://www.ofcom.org.uk/complain/inter/

EMC UK EMC Exhibition and Conference: www.emcuk.co.uk

European Telecommunications Standards Institute (ETSI), PowerLine Telecommunications (PLT); Coexistence between PLT Modems and Short Wave Radio broadcasting services:  http://webapp.etsi.org/action/PU/20080805/ts_102578v010201p.pdf

Regulation of the European Parliament and of the Council 2007/0029 (COD) LEX 901:
http://ec.europa.eu/enterprise/newapproach/pdf/regulation_en.pdf