Contribution by the German delegation RSC 1.10.2003

Comments on the

"Working Document on broad band communication through power lines" RSCOM03-12

The eEurope 2005 Action Plan contains a comprehensive and ambitious concept for the EU-wide use of broad band services in the member states. In this context, the German Government welcomes the Commission’s initiative to create more competition in the last mile. The Commission regards power line communication (PLC) as an appropriate technology for this. The regulatory barriers are to be discussed by all sides and removed this autumn. The Radio Spectrum Committee (RSC), the Communication Committee (COCOM), the EMC Working Party and the Telecommunication Conformity Assessment and Market Surveillance Committee (TCAM) are covering the various aspects. A joint workshop is planned for Brussels in October. The Commission hopes that this comprehensive dialogue will produce a consensus which would be taken up in a recommendation on the basis of Article 19 of the new framework directive.

The German Government does not regard a European legal framework which results in general freedom to use PLC as desirable at the present time, because Germany has a lot of negative experience with the compatibility of radio networks and line-bound networks. Initial findings about PLC applications suggest that, despite contrary assurances by the manufacturers, the ceilings in force nationally cannot be adhered to.

The Joint Working Group at CENELEC/ETSI on mandate M/313 of the European Commission to develop an EMC conformity standard for telecommunications networks and equipment is still far from solving its task. Judging by the present status of the discussions, we believe there is little likelihood of a useful and practical outcome.

The interconnection of equipment in PLC networks involves not only the compatibility aspect, as reflected in the EMC directive, but also a technical communications-related aspect when the signals are transmitted via the connecting cable; cf. illustration. Merely by being present between two appliances, each of which in isolation meets the relevant EMC rules, the transmission path acts as an antenna.

/ / Connecting cable / /

/Appliance/---o------o---/Appliance/

/ / / /

Source Transmission path Sink

= Antenna

It is true that the antenna effect can be minimised using modern technology, but it varies widely from appliance to appliance, depending on the cabling technology and the type of cable. A PLC network has many such small individual antennas, all of which together have a cumulative effect. In the past, measurement flights to check interference caused by cable networks in Germany have found that much greater interference is measured on board an aircraft than on the ground, and that this is due to the geographical cumulation.

In Germany, the simultaneous use of frequencies for radio purposes on the one hand and within and along lines on the other represents an extraordinary compatibility problem. This particularly affects services which uphold public safety and therefore require particular protection. Here, it must not be forgotten that line-bound applications can be protected by shielding, but that this is not true of radio applications. Not only air traffic needs to be able to deploy the frequencies it uses absolutely free of interference: other safety-related services like the police, fire brigades, civil disaster support and of course national defence also have an essential need for protection. There are a large number of frequencies worthy of protection which are in no way harmonised on a European basis. They split the spectrum into many sub-bands.

For radio signals to be of commercial use, they must be above the background noise or below it and capable of being filtered out. If the overall background noise rises due to large-scale PLC use, it will be necessary to transmit the desired signals of other applications at higher power or to accept interference. This would counteract the real sense of, for example, short wave, i.e. transmission over large distances at low power. The transmission at higher power would result not only in costs for new transmission facilities, correspondingly higher energy costs and a further increase in the general noise level, but also in a new certification of the transmitter with new protective distances.

Every approach which results in more competition is welcomed and accepted by Germany. But genuine competition can only take place once mature, compatible technologies are available on the market and compete with each other.