C.I.S.P.R. Project Team Dominated
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:
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
Manager EMC Center, Access Networks Business Headquarter, NTT ADVANCED
TECHNOLOGY CORP., a unit of NIPPON TELEGRAPH AND TELEPHONE CORP. (NTT).
Mr Serafin Arroyo
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.
SONY ELECTRONICS INC., Product Quality Division, EMC Group.
Mr John Boot (US)
Director of Standards at CURRENT TECHNOLOGIES, a major PLC technology
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,
Head of the EMC laboratory at the CATHOLIC UNIVERSITY COLLEGE OF BRUGES
- OSTEND (KHBO), Belgium.
Chief Technical Consultant at INTEL CORPORATION SA, Belgium.
Karl Dietrich (DE)
SIEMENS POWER TRANSMISSION AND DISTRIBUTION (PTD). Promotes PLC for
ICT-based energy systems.
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
GERMAN FEDERAL NETWORK AGENCY (BNetzA).
Mr R. T. Garrett
Marketing Engineer at TESTING & CERTIFICATION AUSTRALIA (TCA),
owned by ENERGY AUSTRALIA, national market leader in electrical
Mr Juan A.
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.
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
Professor at the UNIVERSITY DUISBURG-ESSEN, an OPERA project partner.
Promotes narrowband and broadband PLC applications.
Mr Jacob Keret
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
Mr Peter J. Kerry
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
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
GERMAN AMATEUR RADIO CLUB (DARC).
Dr. Jeffrey A.
FRANCE TELECOM, second-largest internet accesss provider in Europe, PLC
Mr Trevor Morsman
BRITISH TELECOM, one of the world's leading providers of
telecommunication services, PLC service provider.
Systems Engineer Distribution Division at ENEL, the second largest
European power utility company and a PLC operator.
Dr. John Newbury
Head of the Power Systems Communications Research Group at THE OPEN
UNIVERSITY, United Kingdom. IEC, IEEE, the European EMC Committee,
Mr Yves Ollivier
AGENCE NATIONALE DES FRÉQUENCES (ANFR), ETSI Reporter for ITU-R
Mr Kunihiro Osabe
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.
Mr Purva Rajkotia
INTELLON, which is a HomePlug Powerline Alliance member manufacturing
PLT chipsets for many vendors, for example for the German company
Research and Development at ORANGE, the key brand of FRANCE TELECOM,
which is a PLC service provider.
Mr Praneel Ruplal
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
Mr Saneh Saiwong
NATIONAL TELECOMMUNICATIONS COMMISSION, Thailand.
Engineer for Home Networking at SONY Germany, member of the CE
POWERLINE COMMUNICATION ALLIANCE (CEPCA).
GERMAN FEDERAL NETWORK AGENCY (BNetzA).
Mr Ronald L.
TELIA, the Swedish telecom operator and leading Nordic communication
company, PLC service provider.
NORWEGIAN POST AND TELECOMMUNICATIONS AUTHORITY (NPT).
Mr Christian M.
DANSK STANDARD, Danmarks national standardization organization. EMC
Adviser for the INTERNATIONAL AMATEUR RADIO UNION (IARU).
Mr Eric Winter
Owner of EMC ASSIST, EMC and regulatory consulting.
Mr Martin A.
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
members are dedicated
representatives of a radio service, namely the amateur radio
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
Therefore it does not meet the basic requirement and it
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
"[...] 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
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
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
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 (email@example.com) as well as to the IEC National Committees
which can be found on the List of IEC members
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
5 September 2008: http://cq-cq.eu/cispr22part2
Author and publisher:
Amateur Radio Station DJ5IL
Email: DJ5IL (at) cq-cq.eu