PLC WORKSHOP

1. PLC WORKSHOP Introduction and Input stakeholders

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

3. Background Results of Consultation

4. Background • 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

5. Issues - Radio 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 COCOM03-32 document will kill amateur radio • NB30 limits are too high to adequately protect • Expensive mitigating measures

6. Issues - Radio 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

7. Way forward - Radio 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

8. Issues - 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

9. Way forward - 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)

10. Issues - Incumbent 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

11. Way forward - 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 NB30 • 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

12. Issues - others • 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

13. Issues - Standardisers • In urban areas, PLT contribution is hidden in the background noise up to about 10MHz • In the higher frequency band (10 to 30MHz) 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 NB30 limits but may comply with EN55022 • Absence of consensus in the JWG

14. Issues - PLC 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

15. Way forward - PLC 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

16. Issues • 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?

17. Markets • 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: WiFi delivery, cable, satellite • In house potential unclear, competition from low cost WiFi alternatives

18. Limitations • 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 • 1st generation: single carrier • 2nd generation: spread spectrum technologies • 3rd generation: advanced OFDM technologies

19. Digital Divide • 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

20. Services threatened • 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

21. Interference • 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

22. Harmonisation • 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

23. Way Forward • 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”