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Memorandum submitted by Electromagnetic Compatibility Industry Association (EMCIA)
Broadband Speed Contents Page No. 2 The EMCIA - a brief introduction.. 3 3.1 PLT causes unacceptable electromagnetic interference (EMI) 4 3.2 Ofcom suffers from a conflict of interest over PLT. 4 3.3 EMC standards experts have failed to find a solution for PLT. 5 3.4 PLT cannot comply with the EMC Directive. 5 3.6 Further information, discussions and demonstrations. 6 4 What we would like the Committee to consider including in its report 7
1 Executive SummaryWe very strongly recommend that the Committee specifically excludes the use of PowerLine Telecommunication (PLT*) technologies as an option for the delivery of broadband Internet. One mechanism for providing broadband Internet access might be thought to be PLT, and similar digital communications technologies, that use the electric power lines (the "mains") to, and within, homes to carry the high speed data signals used by broadband Internet. But mains wiring is unsuitable for carrying such signals, and so PLT results in excessive electromagnetic interference (EMI). The very high levels of EMI emitted by PLT have serious consequences for radio communications in the "Short-Wave" band (1 - 30MHz), including potentially severe safety consequences. It can also interfere with the delivery of broadband Internet by xDSL technologies using telephone cables, slowing their data rate.
* PLT PLT also goes by other names,
including PowerLine Communications (PLC)
2 The EMCIA - a brief introductionThe full name of the EMCIA is the Electromagnetic Compatibility Industry Association. The EMCIA was formed in March 2002 for the benefit of companies involved in the supply, design, test or manufacture of EMC* products, or the provision of EMC Services. The EMCIA is a UKTI Accredited Trade Organisation.
*EMC is short for Electromagnetic Compatibility - the ability of equipment or a system to function satisfactorily in its electromagnetic environment, when used as intended: - without causing intolerable electromagnetic interference (EMI) into its environment, and, - without suffering unacceptable degradation of performance due to EMI present in its operating environment. The achievement of EMC is vital for everything that employs electricity and/or electronics, and is necessary for: (a) All manufacturers who incorporate electronic devices within their products. Including: agricultural; consumer; commercial; communications; industrial; education; science; military; transport (road, rail, air, space, marine, etc.); national infrastructures (electricity and gas generation and distribution; telecommunications and internet; radio and TV broadcasting; water supply and sewage treatment, etc.); medical; security; building automation; etc. Based on figures from ORGALIME, the total value of these manufactured
goods in the (b) Owners/operators of systems/installations that employ electronic equipment Including all buildings and vehicles: agricultural; scientific; residential; commercial; industrial; healthcare; national infrastructure; communications; military (land, sea, air, space); educational; governmental; etc. (c) All service organisations that employ electronic equipment. (d) Employers who provide work equipment incorporating electronic devices Including: agricultural; retail; commercial; entertainment; industrial; government; military; communications; scientific research; transport; healthcare; education; transport; etc.
The author of this Memorandum is Keith Armstrong, the President of the EMCIA, who may be contacted at keith.armstrong@cherryclough.com, telephone & fax: 01785 660 247. The EMCIA
Secretariat is Nutwood UK Limited, 3 Factual information3.1 PLT causes unacceptable electromagnetic interference, EMIThe mains power distribution network, both to and within homes, is unsuited to carrying the high frequencies used by high-speed data signals. Furthermore the mains network already carries high-frequency interference caused by the operation of electrical and electronic products - although its magnitude is regulated by international standards. For these reasons, for PLT to communicate a data rate that is sufficient for broadband internet, over adequate distances, it must inject such high levels of signals into the mains network that copious levels of EMI are emitted from the mains wiring. The emitted levels of EMI are far above those permitted by test standards generally used for ensuring compliance with the EMC Directive [1]. In fact, a single PLT device in a home creates as much EMI as would over 1,000 barely-EMC Directive-compliant products all plugged into the same mains socket. This EMI has a negative effect on users of radio communications, both nearby and further afield [2], and could have severe safety consequences (e.g. for short-wave radiocommunications with aircraft, or in the case of a national disaster). It
is often implied by proponents of PLT (and by The EMI from PLT also affects the delivery of broadband signals via telephone wires, for example the new VDSL2 standard, as shown by [4]. 3.2 Ofcom suffers from a conflict of interest over PLTThe
last publicly available figure is that 143 such complaints were recorded over a
period of 12 months, making it by far the largest single cause of interference
complaints to a) The radio spectrum (the airwaves used by everyone from taxi firms and boat owners, to mobile-phone companies and broadcasters) is used in the most effective way. b) The In order
to satisfy Item b) by permitting PLT to exist, 3.3 EMC standards experts have failed to find a solution for PLTNumerous attempts have been made at the international standards level [6] for the last twelve years to attempt to find a way in which PLT apparatus could be made to coexist with radio services, without causing excessive EMI. 3.4 PLT cannot comply with the EMC DirectiveWithin
Serious concerns have been raised regarding the compliance of PLT apparatus with this Directive [7]. As already mentioned, a single PLT device in a home creates as much EMI as would more than 1,000 barely-EMC Directive-compliant products - that each just about scraped under the emissions limits in the relevant EMC test standards - all of them plugged into the same mains socket in that house and operating at the same time. The European Commission, accepting that "PLC manufacturers have the impression that, even if their technical file is convincing, they run a serious risk of a sales ban by market surveillance authorities", have seen fit to neuter the enforcement of the Directive rather than require the PLT manufacturers to make their products comply [8]. 3.5
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