Regulatory: Powerline Current Carrier Systems

Response to Industry Canada (ICES-006, Issue 2)

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Background
Industry Canada, the regulatory body in Canada, has released the 2nd version of its regulations (ICES-006) for Powerline systems (AC wire carrier current devices). Our view is that these changes will negatively affect the industry - for more background, click here.

Comment to Industry Canada
There is a comment period, which ends October 10, 2009 - LATEST DEADLINE!!. Here are our comments so far:

Manager, Radio Equipment Standards,

These comments are directed at Canada Gazette, Part 1, published May 20, 2009, AC Wire Carrier Current Devices (Unintentional Radiators), Notice No. SMSE-004-09, (Issue 2 of ICES-006).


1. The new definition of "In-house BPL" states that "the electric power lines may be underground or inside the walls, floors or ceilings of user premises". This allows for houses with underground power feeds, but in many places, including here in BC, transformers are mounted on poles and fed to the houses through aerial drops.

Therefore, the wording seems to imply that houses with aerial feeds would not be considered "in-house BPL" systems while those houses with underground power feeds would be considered "in-house BPL" systems. We submit that this is impractical and unfair, and that there is no valid reason provided why there is such a differentiation. We suggest that aerial feeds be allowed for "in-house BPL" systems.


2. In addition, we understand that there is an upcoming Access BPL regulation from Industry Canada that will deal with power line carrier products that are not considered "in-house BPL" systems. Therefore, it seems, that these upcoming regulations would deal with the houses with aerial feeds (if the definition was not changed). It seems unfair not to reveal at this time the consequences of the added definition.

We suggest that the Issue 2 of ICES-006 be released at the same time as the new Access BPL regulation (and reference to each other), as the two regulations are closely related. In addition, the full ramifications of the added "in-house BPL" definition in ICES-006 would then be clearly understood, and respondents would be given the full context in order to provide their comments.


3. In the development of Issue 1 of ICES-006, there was significant work with Industry into setting the output voltage levels which would result in acceptable radiation levels. It was understood (and supported by the Industry) that by requiring only an output voltage test, manufacturers would not require complex and expensive test equipment setup. With the addition of the "in situ testing" for "three typical installations", section 4.3, manufacturers would now have more expensive test setups, and negates the understanding and foundation on which ICES-006 was developed.

Also, section 4.3 refers to another standard, ANSI C63.4-2003, which costs $121 US. It does not seem fair to require each respondent to pay for that standard. For those respondents that choose not to buy the ANSI standard, they will not be able to make a full assessment of the suitability of the new section 4.3.

We suggest that section 4.3 be removed.

Next Steps
We urge you to submit similar comments to Industry Canada, or contact Ludo Bertsch at (250) 592-1488 or email at powerline@horizontec.com for improving the comments and/or responding with a joint submission.

References
Gazette Notice SMSE-004-09
ICES-006 Issue 1; 2001
ICES-006 Issue 2; 2009

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