European Commission EMC Directive Enterprise Directorate General PLC

European Commission EMC Directive Enterprise Directorate General PLC WORKSHOP Introduction and Input stakeholders

European Commission EMC Directive Contributors European Commission Enterprise Directorate General • 48 Contributions Repartition by type Repartition by origin 9 15 16 2 21 2 25 3 9 4 5 8 Company Association private radio amateurs private others 1 Radio Amateur Radio users Broadcaster PLC utilities Incumbent operator Consumers Standardiser Not specified

European Commission EMC Directive Background Enterprise Directorate General Results of Consultation

European Commission EMC Directive Background Enterprise Directorate General • EU regulatory framework unclear, standards lacking • Results into regulatory uncertainty and unfavourable environment for investment • Copper based networks may be expected to be replaced in the future – Bandwidths on telephone lines, cable networks and on PLC will become insufficient in 5 -15 years – Only companies with market share will however invest in fibre in the local loop

European Commission Enterprise Directorate General European Commission Issues - Radio EMC Directive amateurs • Technical – Concerns with mass roll-out – PLC affects many services like Broadcast, mobile radio, military, land mobile, military, radio amateur. Makes them unusable especially with limits proposed in the Commission working paper – Potential to destroy the HF spectrum ( high HF level, not designed for HF transmission, always on, overhead wiring acting as antenna, affects other appliances) – Cumulative effect is likely – DRM reception will be hampered (physical incompatibility with PLC) and investment in DRM are wasted – PLC may suffer from HF transmission – Interferences with air traffic control has been observed in USA - Japan has banned PLC – 4 trials in Austria generated more than 80 complaints of radio users and amateurs for harmful interference. – PLC operators deny to resolve the interference – PLC limits as indicated in COCOM 03 -32 document will kill amateur radio – NB 30 limits are too high to adequately protect – Expensive mitigating measures

European Commission Enterprise Directorate General European Commission Issues - Radio EMC Directive amateurs • Economical/social – PLC will not solve the growing need for broadband access, because it will need a high speed backbone net and will not be deployed in rural areas – Shortwave radio is critical in case of national disaster – Short-wave provides the right to listen to not-controlled content sources, used for training and education, cheaper than satellite and provides cultural diversity – Negative consequences for developing nations that heavily rely on SW and cannot develop alone technology – Radio amateurs provides training and education of young people, private scientific and technical studies as well as emergency and disaster relief communications. This shall be preserved – Impossible to step back once PLC has been allowed if found disturbing – PLC has limited bandwidth, not fulfilling customer needs – PLC allow only dominant electricity provider to enter the market

European Commission Enterprise Directorate General European Commission Way forward - Radio EMC Directive amateurs (individuals) • Various positions: – Disallow PLC, using ADSL, FWA or satellite as alternatives – No positive discrimination • Consider frequencies to be particularly protected • Maximum allowed radiation levels shall be much lower for PLC devices / PLC networks than those for other devices being subject to EMC regulations. • Levels shall be such that no noticeable increase in noise level in radio receivers is observed • Operators to evaluate the interference resolution costs • establish notches for all amateur frequencies • Favour alternatives like ADSL, cable, FWA, satellite

European Commission Enterprise Directorate General European Commission Issues EMC Directive Broadcasters • DRM will revitalise shortwaves • Large investments done shall not be wasted • Shortwave is a unique resource due to its propagation characteristics • PLC is always on and power cables not designed for HF transmission interference likely • Current proposed emission levels will make DRM useless • Experiments have demonstrated (Crieff) interference when PLC operates in radio bands • Recent PLC equipment radiate less and could comply with lower limits • There is no consideration of other party’s interest in standardistaion

European Commission Enterprise Directorate General European Commission Way EMCforward Directive Broadcasters • PLC emissions shall be limited to the level allowing DRM reception • Frequency separation and allocation of a frequency band for PLC • Standards should not define any radiated emission limits at all • NB 30 is considered the minimum acceptable protection • Authorisation shall be be conditioned to limits to be used in case of interference lower than standards (e. g. NB 30) and/or to frequency usage • Conditions shall be set for authorising trials (transparency of measurements, audit on impact, contact point for complaints) • PLC manufacturer shall work on alleviation techniques (e. g. silent idle mode)

European Commission Enterprise Directorate General Issues - Incumbent EMC Directive operators • Technical issues – Radio and PLC are physically incompatible – VDSL is designed according well established EMC principles – Potential coupling between PLC and Telephone at some frequencies (2. 4 MHz) • Commercial/social issues – Potential distortion of market (abuse of dominant position in case on some business models). – Electrical sector not yet liberalized in some countries

European Commission Enterprise Directorate General Way forward EMC Directive Incumbent operators • PLC development shall not affect existing services and infrastructures and avoid frequencies used by radio amateurs and radio • Emission levels shall be restricted to NB 30 • Cumulative effects shall be prevented • Equivalent policy in the electrical sector than in the telecom sector (Local loop unbundling) • Introduction of PLT shall be done carefully

European Commission EMC Directive Issues - others Enterprise Directorate General • Technical – radioastronomy works in the 3 -30 MHz band with very low detection level (0 dbµV). PLC will limit detection • Economic/social – PLC will remain a niche market – Implied economic value of PLT is highly questionable and most certainly insufficient to justify sacrificing the HF-spectrum. – PLC is not transitory

European Commission Enterprise Directorate General • • European Commission Issues EMC Directive Standardisers In urban areas, PLT contribution is hidden in the background noise up to about 10 MHz In the higher frequency band (10 to 30 MHz) PLT operation with present technologies has clearly the potential to interfere with radio services, Reports are contradictory regarding the evaluation of risks due to PLT in respect of cumulative effects Practically no complaints have been recorded from the users. In house, indoor-radiated field measurements appear to be highly unpracticable, outdoor, it seems feasible Other broadband networks (e. g. VDSL) may produce radiated fields comparable to PLT Various PLT technologies may have different interference characteristics. It appears clearly that nowadays PLT systems in operation are not complying with NB 30 limits but may comply with EN 55022 Absence of consensus in the JWG

European Commission Enterprise Directorate General • European Commission Issues - PLC EMC Directive operators Technical – – – Products are mature and Competitive Utilities stable and trusted alternatives Only telecom infrastructure in some eastern countries Solution for the last mile Local/regional utilities in central position-> investment Possible new applications • Commercial/Social – Lack of regulatory certainty, accompanied by an inhomogeneous handling of PLT by the Authorities throughout the Community. – Stable standard specifically dedicated to emission limitation for PLT not available , emission limits should consider economic aspects and value added – Heavy investments already done – Restrictive policy restricts the number of players – Fair treatment shall be offered wrt. ADSL/VDSL – Recognition of a possible price to pay by other actors

European Commission Enterprise Directorate General European Commission Way. EMC forward - PLC Directive operators • The problem can not be solved at standardisation level • Appropriate political decisions are needed • Suitable regulation shall be set-up to allow PLC mass deployment • The working paper shall become a recommendation • Interference stemming from PLC have to be resolved • An accompanied development is necessary (e. g. through conditional licensing scheme) • Non-discriminatory treatment

European Commission EMC Directive Issues Enterprise Directorate General • • What markets for PLC can be distinguished? What market share can PLC realistically reach? What are its technical limitations? Which contributions can it bring to overcome the digital divide? What are the services potentially threatened by PLC? What are its risks to cause unacceptable interference to radio services? Do we need an EU harmonised regulatory approach? What is a wise way for regulators to deal with this issue?

European Commission EMC Directive Markets Enterprise Directorate General • What markets can be distinguished? – Alternative Local Loop for delivering broadband services – Rural coverage (through satellite hub) – In-house applications • What market share can PLC realistically reach? – Mass deployment or niche market : 10 -15% in markets where it is present is the observed realisty – Lowers market access barrier for energy companies to step into telecommunications – Needs substitution when high market penetration. Ultimately optical fibre will offer the required banwdith to match request – Alternatives: Wi. Fi delivery, cable, satellite – In house potential unclear, competition from low cost Wi. Fi alternatives

European Commission EMC Directive Limitations Enterprise Directorate General • What are its technical limitations? – Shared bandwidth, ± 10 Mbit/s shared between the 50 households behind transformer – High attenuation, repeaters required to bridge larger distances – Handling interference affects business plans: • notching out frequencies affects bandwidth • power level vs. need for repeaters • investments in adapting EMC characteristics of electricity networks costly (filters, high frequency bridges) – Certainly older PLC technologies become uneconomic • limited notching out capabilities • higher emission characteristics – Technology continues to be improved • 1 st generation: single carrier • 2 nd generation: spread spectrum technologies • 3 rd generation: advanced OFDM technologies

European Commission EMC Directive Digital Divide Enterprise Directorate General • Which contribution can it bring to overcome the digital divide? – Problematic business case for incumbent operators to cover rural areas – Many areas in the EU without effective competition – Can help fostering new players – PLC low cost local loop technology

European Commission EMC threatened Directive Services Enterprise Directorate General • The risk for interference exists and is recognised. Caution necessary wrt. apocalyptic scenarios. • Shortwave radio and in particular DRM shall not be disregarded – Increase in interference and noise will reduce the coverage – Needs to be assessed against network penetration and level of interferences • Amateur radio, radio astronomy: – should still be possible – usage in extreme cases may be restricted geographically • “Clean spectrum” thinking is unsustainable. Introduction of a new services may restrict the freedom of movement of other services and has to be accepted as long as reasonable

European Commission EMC Directive Interference Enterprise Directorate General • Must base regulations on realistic basis • EMC Directive calls upon standardisation to find the right compromise but – – – – discussions are too emotional there may be hidden agendas lack of recognition of mutual interests is recognised much thinking is based on theory and unproven assumptions worst case scenarios not a realistic basis for regulation PLC opponents don’t have an interest in stable standards PLC proponents seek an easy ride • Electromagnetic Compatibility is a complex phenomenon • Current experience doesn’t seem to point at real problems, but there are only 6000 lines • Most interference cases can be solved locally, if both technology allows for it and willingness is present

European Commission EMC Directive Harmonisation Enterprise Directorate General • Different level of concern in Member States • In certain Member States call for restrictive and mandatory national limits • In other Member States a permissive approach obliging handling interference when it occurs • Do the different electromagnetic compatibility environment require a different set of rules for PLC than for normal radio? • Commission feels there are no reasons to assume there is a need for different regulations and we need a single standard under the EMC Directive • A standard can never give absolute protection and needs to be complemented by a case by case resolution of issues at the local level

European Commission EMCForward Directive Way Enterprise Directorate General • Need to provide legal certainty • Only PLC operators can assess the EMC consequences of their networks • They are under the EMC Directive obliged to ensure they don’t cause interference and need to resolve any concrete complaints • Concrete complaints need to be distinguished from “theoretical complaints”