CISPR Project Team Dominated by PLT
Lobby - Rationale Behind Proposed Approach
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
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
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
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
Mr Mark G. Arthurs (US):
ELECTRONICS INC., Product Quality Division, EMC Group.
Mr John Boot (US):
Standards at CURRENT TECHNOLOGIES, a major PLC technology provider.
Mr Werner Bäschlin (CH):
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):
of the EMC laboratory at the CATHOLIC UNIVERSITY COLLEGE OF BRUGES - OSTEND
Mr Jean-Luc Detrez (BE):
Technical Consultant at INTEL CORPORATION SA, Belgium.
Karl Dietrich (DE):
POWER TRANSMISSION AND DISTRIBUTION (PTD). Promotes PLC for ICT-based energy
Mr Victor Dominguez Richards
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):
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. Garrigosa
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
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 (IL):
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
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):
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
Mr Thilo A. Kootz (DE):
AMATEUR RADIO CLUB (DARC).
Dr. Jeffrey A. Krauss (US):
Mr Philippe Lancelin
FRANCE TELECOM, second-largest internet accesss provider in
Europe, PLC service provider.
Mr Trevor Morsman (GB):
TELECOM, one of the world's leading providers of telecommunication services, PLC
Mr Romano Napolitano
Systems Engineer Distribution Division at ENEL, the second
largest European power utility company and a PLC operator.
Dr. John Newbury (GB):
the Power Systems Communications Research Group at THE OPEN UNIVERSITY, United
Kingdom. IEC, IEEE, the European EMC Committee, CENELEC, ISPLC.
Mr Yves Ollivier (FR):
NATIONALE DES FRÉQUENCES (ANFR), ETSI Reporter for ITU-R SG1, CEPT.
Mr Kunihiro Osabe
VOLUNTARY EMC LABORATORY ACCREDITATION CENTER INC. (VLAC), the
Japanese accreditation body for EMC test laboratories.
Mr John Pink (GB):
SOCIETY OF GREAT BRITAIN (RSGB).
Mr S. J. Pretorius (ZA):
Mr Purva Rajkotia
INTELLON, which is a HomePlug Powerline Alliance member
manufacturing PLT chipsets for many vendors, for example for the German company
Mr Richard Razafferson
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):
COMMUNICATIONS AUTHORITY OF SOUTH AFRICA (ICASA).
Mr John Ryan (GB):
and consultant to the ENERGY NETWORKS ASSOCIATION (ENA), the trade association
for UK energy transmission and distribution licence holders.
Mr Saneh Saiwong (TH):
TELECOMMUNICATIONS COMMISSION, Thailand.
Andreas Schwager (DE):
for Home Networking at SONY Germany, member of the CE POWERLINE COMMUNICATION
Dr. Bernd Sisolefsky
GERMAN FEDERAL NETWORK AGENCY (BNetzA).
Mr Ronald L. Storrs
TELIA, the Swedish telecom operator and leading Nordic
communication company, PLC service provider.
NORWEGIAN POST AND TELECOMMUNICATIONS AUTHORITY
Mr Christian M. Verholt
DANSK STANDARD, Danmarks national standardization
organization. EMC Adviser for the INTERNATIONAL AMATEUR RADIO UNION
Mr Eric Winter (ZA):
EMC ASSIST, EMC and regulatory consulting.
Mr Martin A. Wright
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.
"[...] 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 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
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
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
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 (email@example.com) as
well as to the IEC National Committees which can be found on the List of IEC
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
To be continued - stay tuned !
author and publisher:
Amateur Radio Station DJ5IL