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From: "Karl Fischer, DJ5IL" <dj5il@cq-cq.eu>
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Subject: IEC/CISPR Threatens Radio Services ...
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IEC/CISPR Threatens Radio Services by a Planned 18 dB Relaxation of PLT =
Disturbance Limits

CISPR is the Special International Committee on Radio Interference of =
the International Electrotechnical Commission IEC with central office in =
Geneva, Switzerland. It is concerned with the development of standards =
regarding electromagnetic interference and most of these are adopted by =
the European Union and many other countries. Disturbance limits for =
Power Line Telecommunications (PLT) systems are defined by the standard =
CISPR 22 and its European equivalent EN 55022 entitled "Information =
technology equipment - Radio disturbance characteristics - Limits and =
methods of measurement".

A PLT Project Team (PT) was formed in 2005 to produce an amendment to =
CISPR 22 to cover special requirements for PLT equipment and its first =
Committee Draft (CD) was issued in February 2008 (doc. CISPR/I/257/CD). =
However, the comments of 23 IEC members National Committees (NC) and the =
European Broadcasting Union (EBU) showed insufficient support for the =
selected approach (doc. CISPR/I/266A/CC) as only 6 NCs supported the =
draft: Belgium, France, Israel, Italy, Spain and Switzerland. =
Interestingly, the major European PLT technology providers, developers =
and manufacturers reside in 5 of these 6 countries.

8 NCs strongly opposed the draft - Australia, Austria, Cyprus, Denmark, =
Finland, South Africa, Sweden and the United States of America - and =
some well-founded comments revealed its true purpose: to camouflage an =
intended 18 dB relaxation of the present PLT disturbance limits by =
introducing a revised method of measurement with an estimated =
Longitudinal Conversion Loss (LCL) of 24 dB in contrast to 6 dB in CISPR =
22:2005.

For the measurement of disturbance an Impedance Stabilization Network =
(ISN) is needed, which provides a known port termination impedance and a =
measurement port. The ISN is used to measure the common mode =
disturbances and it is built to mimic a network with a certain LCL =
value, which is the ratio of differential mode signal injected into a =
network to common mode signal resulting from the network imbalance. A =
higher value indicates a higher symmetry of the network and hence less =
common mode signals and less radiation. An ISN with LCL =3D 24 dB would =
mimic an almost perfectly symmetric network and effectively yield an 18 =
dB relaxation of the present limits, but as many NCs noted this value is =
unrealistically high and not representative for real power networks. =
Additional unrealistic presumptions inherent to the proposed method =
would even further increase the effective relaxation.

Some short excerpts out of 35 pages of NC comments are quoted as =
follows:

Austria:
"... the use on the real Austrian electricity network of devices =
fulfilling the above CD cannot be considered as an adequate basis for =
the protection of radio communication systems ... CISPR/I/257/CD does =
use a model based on LCL assumption to describe Powerline network. This =
does not represent real Powerline network in Austria. Furthermore the =
value of 24dB is much too high ... "The 25 W common mode impedance ..." =
makes a not realistic presumption ..."

Australia:
"... This CD does not wholly reflect the opinions and recommendations of =
the task group. Around half the task group expressed concern that the =
method and limits of the CD constitute a substantial relaxation of the =
CISPR 22 limits and is therefore unacceptable. However, the task group =
agreed to send the CD out, without prejudice, to test the opinions of =
the NCs, in order to expedite a way forward ... The Australian National =
Committee disagrees in principle with the use of the T-ISN method in =
this document ..."

Cyprus:
"... CISPR S and CISPR Plenary instructed the CISPR I PT to prepare the =
amendment with the strict objective of providing the same protection for =
radio services as provided by the pesent published edition of CISPR22. =
This instruction seems not to have been followed ..."

Denmark:
"... DK is of the opinion that regardless of the measurements made, the =
LCL value of 24 dB will not protect radio services from PLT emissions. =
In the latest CISPR 22:2005, modified, the value is 6 dB using AMN ..."

Finland:
"... Finnish NC disagree of using an LCL value of 24 dB for ISN: This =
value does not give the same level of protection of radio services as =
provided by CISPR 22 for other IT equipment. The proposal actually is a =
technology specific relaxation of EMC requirements for PLT products ..."

United Kingdom:
"... The British NC does not support the approach taken in this CD. We =
are of the view that this CD is misleading in that it hides the reality =
that PLT requires a relaxation in the emission limit. We recognise that =
this relaxation is required to allow PLT to have a signal to noise ratio =
necessary for its operation. The British NC does not believe the LCL =
approach is the appropriate way to characterise the interference =
potential of the power network ... The British NC is concerned to ensure =
that the potential for cumulative effects from multiple individual =
equipment possibly having an adverse effect on the HF noise floor is =
fully addressed ..."

Netherlands:
"... The complicated measurement camouflages the real issue: a =
differential-mode relaxation of 18 dB for PLC ..."

Sweden:
"... The Swedish National Committee does not support this CD because we =
do not believe that LCL is suitable to access the disturbance impact of =
power lines, no supporting measurements are given to show that a =
relaxation of 18 dB would not give raise to serious radio interference =
and no mention is made of either passive or dynamic techniques which =
might justify relaxed limits ..."

U.S.A.:
"... PLT devices use the power mains for communication. Therefore, they =
have the same interference potential as any other power main connected =
device. Because PLT injects desired signals on the power mains is no =
justification to change the required emission control ..."

European Broadcasting Union (EBU):
"... The document is seeking a means of significantly relaxing the =
present limits to enable PLT systems to operate. This approach is not =
acceptable unless other factors are identified to compensate for such =
relaxations ... The LCL value of 24dB is not acceptable, as the field =
strength measurements work indicates that a much lower value is =
warranted ..."

It has to be noted that the latter concern of the British NC has been =
commented by the Secretary with the words "Rejected. UK NC should =
provide evidence there is an issue there". Cumulative effects of PLT of =
course are an issue and have been treated extensively by the NATO =
Research and Technology Organisation (RTO) in Technical Report =
TR-IST-050 "HF Interference, Procedures and Tools". The whole report is =
worth reading.

In June 2008 the project team issued a "Proposed Approach on EMC =
emission requirements for PLT" (doc. CISPR/I/269/DC) wherein it abandons =
the busted camouflage and declares:

"... there was deemed to be insufficient support for the selected =
approach and the group came up with an alternative approach based on 6dB =
ISN. The group recognized that the basic requirement that PLT be able to =
operate sets a basic limit on the wanted signal which effectively =
produces a need for somewhat higher limits than are given in CISPR 22 =
.. the PLT PT agreed that the level of Power Spectral Density implied =
by I/257/CD is necessary for the appropriate operation of the PLT =
systems ... The PLT PT proposes the use of an ISN with an LCL of 6 dB, =
as a compromise, in response to several NC comments ... Against this =
background the PLT PT proposes the specification of Average and Quasi =
Peak limits which comprise a nominal 18 dB relaxation on the mains port =
limit ... NCs are advised that the current measurement method specified =
in I/257/CD will produce somewhat different results than the voltrage =
measurement ... this may produce a further relaxation ..."

In other words: LCL shall be decreased by 18 dB from 24 to 6 dB but at =
the same time disturbance limits shall be increased by 18 dB which =
yields the very same net relaxation of 18 dB as in draft I/257/CD. And =
18 dB are not "somewhat" but much higher as they represent a power =
increase by a factor of 63 ! National Committee comments and suggestions =
on that proposal are requested by the Secretary CISPR/I by 15 August =
2008 in order to allow the PLT project team to discuss the comments at =
its next meeting in Berlin on 8 - 9 September 2008. Then a revised =
committee draft will be distributed for comment by December 2008.

If this amendment would be realized as planned, the European standard EN =
55022 would most likely be adapted as well as many other national =
standards and according to BNetzA, the German Federal Network Agency, =
the following consequences would arise:
  a.. Relaxation of 18 dB on disturbance limits for PLT devices ...=20
  b.. Additional relaxation in the order of 0 to 20 dB if it should be =
adopted that the current measurement on the power cable and the voltage =
measurement on the new T-ISN are treated equally ranking ...=20
  c.. Though the relaxation would be granted to PLT devices only, it is =
doubtful that future claims of other industrial branches for the same =
relaxation could be rejected ...=20
  d.. Operation of standards compliant PLT devices in the future could =
cause an increase in interference field strength at radio receiving =
sites as well as an increase in conducted interference entering radio =
receivers via the mains supply by at least 18 dB.
This substantial relaxation would seriously threaten radio services =
operating on shortwave, especially the broadcasting and amateur radio =
service which already suffer from ever increasing interference. Without =
doubt PLT is a dirty technology which pollutes the electromagnetic wave =
spectrum as a precious and limited natural resource, simply because the =
mains is neither intended nor suited for carrying broadband HF signals. =
Thus relaxing PLT disturbance limits is like relaxing justified and =
necessary air pollution limits just because an industrial lobby calls =
for it.

"The primary aim of CISPR is the protection of radio services ..." - =
These are the introductory words of the CISPR strategic policy =
statement. But instead of asking which PLT limits are needed in order to =
protect radio services, CISPR only asks which limits are good for PLT =
and thus grossly violates its prime policy. In fact, the proposed =
approach would serve the PLT lobby and fill their needs while totally =
ignoring the disastrous impact on radio services, which is certainly not =
the way to go. As a serious standardization body, and if only for its =
own policy statement, CISPR is supposed not to push a dirty technology =
like PLT by specific relaxations. If PLT is not able to leave intact the =
whole electromagnetic wave spectrum - not just some small "notches" - =
for the intended use by radio services, then it is simply unsuited for =
deployment and should leave the field to smarter technologies like Wi-Fi =
or WiMAX, just to name two.

Finally, it should be clear that the adoption of such a standard with =
drastically relaxed PLT disturbance limits by any member of the =
International Telecommunication Union (ITU) would be an infringement of =
the Radio Regulations (RR) as part of a binding treaty which clearly =
state:

"S15.12 =A7 8 Administrations shall take all practicable and necessary =
steps to ensure that the operation of electrical apparatus or =
installations of any kind, including power and telecommunication =
distribution networks, but excluding equipment used for industrial, =
scientific and medical applications, does not cause harmful interference =
to a radiocommunication service and, in particular, to a radionavigation =
or any other safety service operating in accordance with the provisions =
of these Regulations."

This information paper is published on http://cq-cq.eu/cispr22 and =
distributed by email to a large number of amateur radio associations as =
well as organizations, companies, magazines and individuals concerned =
with radio. I urge all affected recipients to further circulate this =
information and to take any appropriate measures that could help to =
prevent the planned relaxation of PLT limits. These measures include =
protest notes and comments to the IEC/CISPR ( info@iec.ch ) as well as =
to the IEC National Committees which can be found on the List of IEC =
members. In addition, administrations should be informed and sensitized =
and at the same time reminded of the binding status of the Radio =
Regulations. I herewith declare that I undertake this information =
campaign as an independent idividual for the sole purpose to support all =
radio services and without pursuing any other goals.

7 August 2008,

author and publisher:

Karl Fischer
Amateur Radio Station DJ5IL
Friedenstr. 42
75173 Pforzheim
Germany
Email: DJ5IL@cq-cq.eu
Website: http://cq-cq.eu



DISCLAIMER
________________________________________________________________
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<DIV><FONT face=3DArial size=3D2>
<DIV><FONT face=3DArial size=3D5><STRONG>IEC/CISPR Threatens Radio =
Services by a=20
Planned 18 dB Relaxation of PLT Disturbance Limits</STRONG></FONT></DIV>
<DIV><STRONG><FONT face=3DArial size=3D5></FONT></STRONG>&nbsp;</DIV>
<DIV><FONT face=3DArial size=3D2>CISPR is the Special International =
Committee on=20
Radio Interference of the <A href=3D"http://www.iec.ch/">International=20
Electrotechnical Commission IEC</A> with&nbsp;central office in Geneva,=20
Switzerland. It is concerned with the development of standards regarding =

electromagnetic interference and most of these are adopted by the =
European Union=20
and many other countries. Disturbance limits for Power Line =
Telecommunications=20
(PLT) systems are defined by the standard CISPR 22 and its European =
equivalent=20
EN 55022 entitled "Information technology equipment - Radio disturbance=20
characteristics - Limits and methods of measurement".</FONT></DIV>
<DIV><FONT face=3DArial size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT face=3DArial size=3D2>A PLT Project Team (PT) was formed in =
2005 to=20
produce an amendment to CISPR 22 to cover special requirements for PLT =
equipment=20
and its first Committee Draft (CD) was issued&nbsp;in February 2008 =
(doc.=20
CISPR/I/257/CD). However, the comments of 23 IEC members National =
Committees=20
(NC) and the European Broadcasting Union (EBU) showed insufficient =
support for=20
the selected approach (doc. CISPR/I/266A/CC) as only 6 NCs supported the =
draft:=20
Belgium, France, Israel, Italy, Spain and Switzerland. Interestingly, =
the=20
major&nbsp;European PLT technology providers, developers and =
manufacturers=20
reside in 5 of these 6&nbsp;countries.</FONT></DIV>
<DIV><FONT face=3DArial size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT face=3DArial size=3D2>8 NCs strongly opposed the draft - =
Australia,=20
Austria, Cyprus, Denmark, Finland, South Africa, Sweden and the United =
States of=20
America - and some well-founded comments revealed its true purpose: to=20
camouflage an intended 18 dB relaxation of the present PLT disturbance =
limits by=20
introducing a revised&nbsp;method of measurement with an estimated =
Longitudinal=20
Conversion Loss (LCL)&nbsp;of 24 dB in contrast to 6 dB in CISPR=20
22:2005.</FONT></DIV>
<DIV><FONT face=3DArial size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT face=3DArial size=3D2>For the measurement of disturbance an =
Impedance=20
Stabilization Network (ISN) is needed, which provides a known port =
termination=20
impedance and a measurement port. The ISN is used to measure the common=20
mode&nbsp;disturbances and it is built to mimic a network with&nbsp;a =
certain=20
LCL value, which is the </FONT><FONT face=3DArial size=3D2>ratio=20
of&nbsp;differential mode&nbsp;signal injected into a&nbsp;network to =
common=20
mode signal resulting from the&nbsp;network imbalance.</FONT><FONT =
face=3DArial=20
size=3D2> A higher value indicates a higher symmetry of the network and =
hence less=20
common mode signals and less radiation. An ISN with LCL =3D&nbsp;24 dB=20
would&nbsp;mimic an almost perfectly symmetric network =
and&nbsp;effectively=20
yield an 18 dB relaxation of the present limits, but as many NCs noted =
this=20
value is unrealistically high and not representative for real power =
networks.=20
Additional unrealistic presumptions inherent to the proposed method =
would even=20
further increase the effective relaxation.</FONT></DIV>
<DIV><FONT face=3DArial size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT face=3DArial size=3D2>Some short excerpts out of 35 pages of =
NC comments=20
are quoted as follows:</FONT></DIV>
<DIV><FONT face=3DArial size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT face=3DArial size=3D2>Austria:</FONT></DIV>
<DIV><FONT face=3DArial size=3D2><EM>"... the use on the real Austrian =
electricity=20
network of devices fulfilling the above CD cannot be considered as an =
adequate=20
basis for the protection of radio communication systems ... =
CISPR/I/257/CD does=20
use a model based on LCL assumption to describe Powerline network. This =
does not=20
represent real Powerline network in Austria. Furthermore the value of =
24dB is=20
much too high ... "The 25 <FONT face=3DSymbol>W</FONT><FONT =
face=3DArial> common=20
mode impedance ..." makes a not realistic presumption=20
.."</FONT></EM></FONT></DIV>
<DIV><FONT size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT size=3D2>Australia:</FONT></DIV>
<DIV><FONT size=3D2><EM>"... This CD does not wholly reflect the =
opinions and=20
recommendations of the task group. Around half the task group expressed =
concern=20
that the method and limits of the CD constitute a substantial relaxation =
of the=20
CISPR 22 limits and is therefore unacceptable. However, the task group =
agreed to=20
send the CD out, without prejudice, to test the opinions of the NCs, in =
order to=20
expedite a way forward ... The Australian National Committee disagrees =
in=20
principle with the use of the T-ISN method in this document=20
.."</EM></FONT></DIV>
<DIV><FONT size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT size=3D2>Cyprus:</FONT></DIV>
<DIV><FONT size=3D2><EM>"... CISPR S and CISPR Plenary instructed the =
CISPR I PT=20
to prepare the amendment with the strict objective of providing the same =

protection for radio services as provided by the pesent published =
edition of=20
CISPR22. This instruction seems not to have been followed =
.."</EM></FONT></DIV>
<DIV><FONT size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT size=3D2>Denmark:</FONT></DIV>
<DIV><FONT size=3D2><EM>"... DK is of the opinion that regardless of the =

measurements made, the LCL value of 24 dB will not protect radio =
services from=20
PLT emissions. In the latest CISPR 22:2005, modified, the value is 6 dB =
using=20
AMN ..."</EM></FONT></DIV>
<DIV><FONT size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT size=3D2>Finland:</FONT></DIV>
<DIV><FONT size=3D2><EM>"... Finnish NC disagree of using an LCL value =
of 24 dB=20
for ISN: This value does not give the same level of protection of radio =
services=20
as provided by CISPR 22 for other IT equipment. The proposal actually is =
a=20
technology specific relaxation of EMC requirements for PLT products=20
.."</EM></FONT></DIV>
<DIV><FONT size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT size=3D2>United Kingdom:</FONT></DIV>
<DIV><FONT size=3D2><EM>"... The British NC does not support the =
approach taken in=20
this CD. We are of the view that this CD is misleading in that it hides =
the=20
reality that PLT requires a relaxation in the emission limit. We =
recognise that=20
this relaxation is required to allow PLT to have a signal to noise ratio =

necessary for its operation. The British NC does not believe the LCL =
approach is=20
the appropriate way to characterise the interference potential of the =
power=20
network ... The British NC is concerned to ensure that </EM></FONT><FONT =

size=3D2><EM>the potential for cumulative effects from multiple =
individual=20
equipment possibly having an adverse effect on the HF noise floor is =
fully=20
addressed ..."</EM></FONT></DIV>
<DIV><FONT size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT size=3D2>Netherlands:</FONT></DIV>
<DIV><FONT size=3D2><EM>"... The complicated measurement camouflages the =
real=20
issue: a differential-mode relaxation of 18 dB for PLC =
.."</EM></FONT></DIV>
<DIV><FONT size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT size=3D2>Sweden:</FONT></DIV>
<DIV><FONT size=3D2><EM>"... The Swedish National Committee does not =
support this=20
CD because we do not believe that LCL is suitable to access the =
disturbance=20
impact of power lines, no supporting measurements are given to show that =
a=20
relaxation of 18 dB would not give raise to serious radio interference =
and no=20
mention is made of either passive or dynamic techniques which might =
justify=20
relaxed limits ..."</EM></FONT></DIV>
<DIV><FONT size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT size=3D2>U.S.A.:</FONT></DIV>
<DIV><FONT size=3D2><EM>"... PLT devices use the power mains for =
communication.=20
Therefore, they have the same interference potential as any other power =
main=20
connected device. Because PLT injects desired signals on the power mains =
is no=20
justification to change the required emission control =
.."</EM></FONT></DIV>
<DIV><FONT size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT size=3D2>European Broadcasting Union (EBU):</FONT></DIV>
<DIV><FONT size=3D2><EM>"... The document is seeking a means of =
significantly=20
relaxing the present limits to enable PLT systems to operate. This =
approach is=20
not acceptable unless other factors are identified to compensate for =
such=20
relaxations ... The LCL value of 24dB is not acceptable, as the field =
strength=20
measurements work indicates that a much lower value is warranted=20
.."</EM></FONT></DIV>
<DIV><FONT size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT size=3D2>It has to be noted that the latter concern of the =
British NC=20
has been commented by the Secretary with the words <EM>"Rejected. UK NC =
should=20
provide evidence there is an issue there"</EM>.&nbsp;Cumulative effects =
of PLT=20
of course are&nbsp;an issue&nbsp;and&nbsp;have been treated extensively =
by the=20
NATO Research and Technology Organisation (RTO)&nbsp;in&nbsp;</FONT><A=20
href=3D"http://ftp.rta.nato.int/public//PubFullText/RTO/TR/RTO-TR-IST-050=
/$$TR-IST-050-ALL.pdf"><FONT=20
size=3D2>Technical Report TR-</FONT></A><A=20
href=3D"http://ftp.rta.nato.int/public//PubFullText/RTO/TR/RTO-TR-IST-050=
/$$TR-IST-050-ALL.pdf"><FONT=20
size=3D2>IST-050 "HF Interference, Procedures and Tools"</FONT></A><FONT =
size=3D2>.=20
The whole report is worth reading.</FONT></DIV>
<DIV><FONT size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT size=3D2>In June 2008 the project team issued a <EM>"Proposed =
Approach=20
on EMC emission requirements for PLT"</EM>&nbsp;(doc. CISPR/I/269/DC) =
wherein it=20
abandons the busted camouflage and declares:</FONT></DIV>
<DIV><FONT size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT size=3D2><EM>"... there was deemed to be insufficient support =
for the=20
selected approach and the group came up with an alternative approach =
based on=20
6dB ISN. The group recognized that the basic requirement that PLT be =
able to=20
operate sets a basic limit on the wanted signal which effectively =
produces a=20
need for somewhat higher limits than are given in CISPR 22 ...&nbsp;the =
PLT PT=20
agreed that the level of Power Spectral Density implied by I/257/CD is =
necessary=20
for the appropriate operation of the PLT systems ... The PLT PT proposes =
the use=20
of an ISN with an LCL of 6 dB, as a compromise, in response to several =
NC=20
comments ... Against this background the PLT PT proposes the =
specification of=20
Average and Quasi Peak limits which comprise a nominal 18 dB relaxation =
on the=20
mains port limit ... NCs are advised that the current measurement method =

specified in I/257/CD will produce somewhat different results than the =
voltrage=20
measurement ... this may produce a further relaxation =
.."</EM></FONT></DIV>
<DIV><FONT size=3D2></FONT>&nbsp;</DIV>
<DIV>In other words: LCL shall be decreased by 18 dB from 24 to 6 dB but =
at the=20
same time disturbance limits shall be increased by&nbsp;18 dB =
which&nbsp;yields=20
the very same net relaxation of 18 dB as in draft I/257/CD. And 18 dB =
are not=20
"somewhat" but much higher as&nbsp;they represent a power increase by a =
factor=20
of 63 !&nbsp;<FONT size=3D2>National Committee comments and suggestions =
on that=20
proposal are requested by the Secretary CISPR/I by 15 August 2008 in =
order to=20
allow the PLT project team to discuss the comments at its next meeting =
in Berlin=20
on 8 - 9 September 2008. Then a revised committee draft will be =
distributed for=20
comment by December 2008.</FONT></DIV>
<DIV><FONT size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT size=3D2>If this amendment would be realized as planned, the =
European=20
standard EN 55022 would most likely be adapted as well as many other =
national=20
standards&nbsp;and&nbsp;according to BNetzA, the German Federal Network =
Agency,=20
the following consequences would arise:</FONT></DIV>
<UL>
  <LI><FONT size=3D2>Relaxation of 18 dB on disturbance limits for PLT =
devices=20
  ...</FONT>=20
  <LI><FONT size=3D2>Additional relaxation in the order of 0 to 20 dB if =
it should=20
  be adopted that the current measurement on the&nbsp;power cable and =
the=20
  voltage measurement on the new T-ISN are treated equally ranking =
..</FONT>=20
  <LI><FONT size=3D2>Though the relaxation would be granted to PLT =
devices only,=20
  it is doubtful that future claims of other industrial branches for the =
same=20
  relaxation could be rejected ...</FONT>=20
  <LI><FONT size=3D2>Operation of standards compliant PLT devices in the =
future=20
  could cause an increase in&nbsp;interference field strength at radio =
receiving=20
  sites as well as an increase&nbsp;in conducted interference entering =
radio=20
  receivers via the mains supply by at least 18 dB.</FONT></LI></UL>
<DIV><FONT size=3D2>This substantial relaxation&nbsp;would seriously=20
threaten&nbsp;radio services operating on shortwave, especially the =
broadcasting=20
and amateur radio service which already suffer&nbsp;from ever increasing =

interference. Without doubt PLT is a dirty technology which pollutes the =

electromagnetic wave spectrum as a precious and limited natural =
resource, simply=20
because the mains&nbsp;is neither intended nor suited for carrying =
broadband HF=20
signals. Thus relaxing PLT disturbance limits is like relaxing justified =
and=20
necessary air pollution limits just because an industrial =
lobby&nbsp;calls for=20
it.</FONT></DIV>
<DIV><FONT size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT size=3D2>"The primary aim of CISPR is the protection of radio =
services=20
.."&nbsp;- These are the introductory words of the CISPR strategic =
policy=20
statement. But instead of asking which PLT limits are needed in order to =
protect=20
radio services, CISPR only asks which limits are good for PLT and thus =
grossly=20
violates its prime policy. In fact, the proposed approach =
would&nbsp;serve the=20
PLT lobby&nbsp;and fill their needs&nbsp;while totally ignoring the =
disastrous=20
impact on radio services, which&nbsp;is certainly not the way to go. As =
a=20
serious&nbsp;standardization body, and&nbsp;if only for its own policy=20
statement, CISPR is supposed&nbsp;not to push a dirty technology like =
PLT by=20
specific relaxations. If PLT is not able to leave intact the whole=20
electromagnetic wave spectrum - not just some small "notches" -&nbsp;for =
the=20
intended use by radio services, then it is simply unsuited for =
deployment and=20
should leave the field to smarter technologies like&nbsp;Wi-Fi&nbsp;or =
WiMAX,=20
just to name two.</FONT></DIV>
<DIV><FONT size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT size=3D2>Finally, it should be clear that the adoption of =
such a=20
standard with drastically relaxed PLT disturbance limits by any member =
of the=20
International Telecommunication Union (ITU) would be an infringement of =
the=20
Radio Regulations (RR) as part of a binding treaty which=20
clearly&nbsp;state:</FONT></DIV>
<DIV><FONT size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT size=3D2><EM>"S15.12 =A7 8 Administrations shall take all =
practicable and=20
necessary steps to ensure that the operation of electrical apparatus or=20
installations of any kind, including power and telecommunication =
distribution=20
networks, but excluding equipment used for industrial, scientific and =
medical=20
applications, does not cause harmful interference to a =
radiocommunication=20
service and, in particular, to a radionavigation or any other safety =
service=20
operating in accordance with the provisions of these=20
Regulations."</EM></FONT></DIV>
<DIV><FONT size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT size=3D2>This information paper is published on </FONT><A=20
href=3D"http://cq-cq.eu/cispr22"><FONT=20
size=3D2>http://cq-cq.eu/cispr22</FONT></A><FONT size=3D2> and =
distributed by email=20
to a large number of amateur radio associations as well as =
organizations,=20
companies, magazines and individuals concerned with radio. I urge all =
affected=20
recipients to further circulate this&nbsp;information and to =
take&nbsp;any=20
appropriate measures that could help to prevent the planned relaxation =
of PLT=20
limits. These measures include protest notes and comments to the =
IEC/CISPR ( <A=20
href=3D"mailto:info@iec.ch">info@iec.ch</A>&nbsp;) as well as to the IEC =
National=20
Committees which can be found on the <A=20
href=3D"http://www.iec.ch/dyn/www/f?p=3D102:5:0">List of IEC =
members</A>. In=20
addition, administrations should be informed and sensitized and at the =
same time=20
reminded of the binding status of the Radio Regulations. I herewith =
declare that=20
I undertake this information&nbsp;campaign as an independent idividual =
for the=20
sole purpose to support all radio services and without pursuing any=20
other&nbsp;goals.</FONT></DIV>
<DIV><FONT size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT size=3D2>7&nbsp;August 2008,</FONT></DIV>
<DIV><FONT size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT size=3D2>author and publisher:</FONT></DIV>
<DIV><FONT size=3D2></FONT>&nbsp;</DIV>
<DIV><FONT size=3D2>Karl Fischer<BR>Amateur Radio Station =
DJ5IL<BR>Friedenstr.=20
42<BR>75173 Pforzheim<BR>Germany<BR>Email: </FONT><A=20
href=3D"mailto:DJ5IL@cq-cq.eu"><FONT =
size=3D2>DJ5IL@cq-cq.eu</FONT></A><BR><FONT=20
size=3D2>Website: </FONT><A href=3D"http://cq-cq.eu"><FONT=20
size=3D2>http://cq-cq.eu</FONT></A></DIV>
<DIV>&nbsp;</DIV></FONT></DIV></BODY></HTML>



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