Unconfirmed Minutes of the Thirtieth Meeting of CLC/TC210 Held On

TC210/Sec0409/RM

December 2004

Extract from…

Unconfirmed minutes of the thirtieth meeting of CLC/TC210 held on

16 and 17 November 2004 in Brussels, Belgium

Discussion on the implications of the new EMC Directive

Mr Brefort of the Commission gave a presentation to the meeting on the new version. He expected publication in the Official Journal to take place on 25 November 2004.

A workshop on the new requirements will be held in Brussels on 3 February 2005.

Mr Brefort’s presentation resulted in a lively discussion, during which the following points and questions were raised:

i The new EMCD will have requirements for installations. The Commission will need to reflect on the need for standards in this area, and the subject may be discussed at the workshop in Brussels.

ii The national implementations of the new EMCD must be on the date of application; it cannot be sooner. Mr Brefort advised the meeting that there was a document on this subject for the EMC Working Party and that he would provide a copy for the Secretary to circulate to TC210.

ACTION Mr BREFORT AND SECRETARY

iii There have no significant changes to the text since the last public document of April 2004.

iv In connection with the new versions of EN 50121, the Commission would be willing to see all the parts harmonised and listed in the Official Journal, but partial listing would be acceptable if there were difficulties with all parts. It was accepted that not all problems are technical in nature, for example there is a mixture of requirements for equipment and installations in some parts, and these should be separated.

v Mr Brefort expressed dissatisfaction with progress in the CENELEC/ETSI JWG, and asked TC210 whether it felt that a solution with limits could be achieved, or whether another solution was necessary.

Mr Sisolefsky doubted that the JWG could establish limits for conformity testing. He expressed the view that in any case, administrations would apply tighter limits for enforcement in cases of radio interference. Mandate M313 does not address PLC modems, and this work will be carried out in CISPR/I. CENELEC should await an amendment to CISPR22 that could be parallel-voted, or a new publication.

Mr Kerry advised the meeting that CISPR is working on such a document, to allow modems that are compliant with it to be placed on the market. However, the actual level of emissions from such modems, when connected to actual networks of unbalanced cables, may be too high to protect radio services. A practical approach may be needed to resolve interference cases. CEPT may deal with the issue if the JWG cannot produce a solution. He believed that the slow progress in the JWG was due to the evolving technology - current products have less potential to create interference than those produced five years earlier. He suggested that the best solution may be to move forward slowly, although he accepted that this may not be acceptable to the Commission.

The Chairman reminded the meeting that the draft Technical Specification had received negative votes in both CENELEC and ETSI. Voting on draft standards is a democratic process. ETSI was working on a product standard for PLC, and CISPR, at its last meeting in Shanghai, had decided not to produce a CDV on the PLC amendment for CISPR 22. The JWG could consider producing a product standard.

Mr De Vré felt that agreement on limits at the JWG was unlikely. If agreement were possible, it was probable that the result would be in conflict with the limits in EN 55022. The Commission should be aware of this problem. He did not feel that there was a contradiction in different limits for placing on the market and enforcement in individual cases of interference.

Mr Kerry suggested that if limits were to be relaxed for placing PLC modems on the market, there would be pressure for a similar relaxation from other industry sectors, and indications of this had already been seen in the UK. This would produce a greater potential for interference to other services, but no gain to the PLC industry as a positive signal to noise ratio would not have been achieved.

Mr Sisolefsky felt that if the limits of EN 55022 were not relaxed for PLC access systems only, there could be no suitable business case. It was up to the Commission to decide, as the issue is political as well as technical.

Mr Goldberg wished to see a measurement campaign initiated, to better understand the characteristics of the networks.

Mr Almering felt that the terminal products should be assessed, not the networks. If a reassessment of the V-network could allow a higher level of differential mode emissions, this could solve the problem.

Mr Brefort reminded the meeting that the mandate did not call for higher emission levels, and that there was no pressure to have a standard published. It was however, better to have an agreed standard than de facto limits, as had happened with in-home systems.

Mr Detrez expressed an alternative view to the earlier discussion, which was to reserve part of the radio spectrum for PLC where no limits would apply. This would result in emissions without interference.

Mr Sisolefsky responded that this had also been considered at the JWG. Mr Kerry urged caution with this approach, since PLC required several MHz bandwidth to function, yet the spectrum was allocated in 3 kHz steps. The available spectrum is already contested keenly. Radio broadband internet access is already available, which provides an alternative access, possibly rendering PLC unnecessary.

Mr De Vré reminded the meeting that a standard without limits cannot give a presumption of conformity under the EMC Directive, and that the use of spectrum is a political decision, rather than one for the JWG.

Mr Detrez suggested that there are obsolete services that could have spectrum re-allocated. Mr Kerry responded that VHF Band I is obsolete, and the spectrum was offered for PLC, but these frequencies are difficult to transmit down a powerline and the operators wanted to use frequencies below 20 MHz.

Mr Brefort indicated that he did not wish to re-open old debates, but had merely sought views on solutions to the current impasse.

Secretary’s note: Mr Brefort attended the meeting only on 16 November, when this agenda item was discussed. Mr Maumy, Secretary of CLC/TC9X, and Mr Storrs, Chairman of the CENELEC/ETSI JWG, attended the meeting only on 17 November.