WGRR 5 - 9 February 2001, The Hague, Netherlands.
Conformity Assessment matters
Regulatory issues of UWB Devices
WGRR views on the regulative aspects of UWB devices would be presented by Mr Lindfors in a workshop planned on 20th March in Mainz. WGRR noted that SE24 has been tasked to study the compatibility aspects and these are also studied by ITU-R WP1. WGRR concluded that it was difficult to answer questions on the regulatory issues before the compatibility issues have been clarified but that some alternative scenarios could be developed on various assumptions. It was agreed that delegates will send any views to Mr Lindfors at the latest two weeks before the workshop and at least the Chairmen of RR6 and RR11 would participate in the workshop too.
Conformity Assessment of RF Modules
During the last year SRD/MG and WGRR have exchanged several liaison statements concerning this issue. The Guide prepared by RTTE CA on conformity assessment of RF modules is now available and it was also discussed at the R&TTE-ADCO meeting 30 January. The document prepared by SRD/MG had not been taken into account by R&TTE CA and it was agreed to do this in a further revision of the R&TTE CA Guide. It had been recognised by R&TTE-ADCO that marking of the final product, where the RF module is inside, needs to contain the R&TTE directive marking for that module. In the type approval regime, where a third party is always involved, and where there is always some kind of registration of all different type designations, it has to be recognised that the module to be type approved may become integrated in different makes of final products. In this regime, either all final products must be type approved and registered separately, or it must be arranged in the type approval process of the module so that the type approval also covers situations where the module can be integrated in many different final products. These are not even known at the time the type approval certificate is issued.
WGRR agreed that the Chairman of RR9 would contact R&TTE CA to discuss the possibility to give the Guide some kind of recognition by TCAM.
PMR446 implementation information on the ERO web pages has been updated in October 2000. RR9 had not received any new input concerning new technical developments, like digital modulation and time division duplex, as proposed by industry about a year ago. It was noted that the original PMR446 concept had been well received by the users. However ETSI proposed that possible introduction of digital modulation should be studied on the condition that it complies with the same spectrum mask as the analogue modulation. This would require amendment of ERC/DEC(98)25. It was also decided to shorten the text devoted to PMR446 implementation on the ERO web pages to the implementation information in the table and to make it easier to find.
Maritime work items
A liaison statement from SE35 to RR2 states that the proposals made by RR2 have been accepted by SE35 and that the proposals will be incorporated in the draft ERC Report. RR2 therefore sees no need to pursue the matter further.
The CPG Chairman has proposed that maritime, amateur radio and HF issues shall be dealt with in CPG/PT4. RR2 has discussed possible ways of co-operation with CPG/PT4. RR2 will contact the new CPG/PT4 Chairman and agree on a practical arrangement.
RR2 expects to provide input papers to the proposed new CPG/PT4 on agenda items 1.9 and 1.10,(Maritime matters) and 1.14 (Protection of maritime and aero frequencies + maritime MF/HF frequencies). First sets of draft texts were provided on 1.9 and.1.14.
On agenda item 1.9 a number of Administrations have not decided on their positions and therefore the proposed draft brief, draft ECP on revision of Res. 331 and CPM input could not be agreed on. The Administrations have been urged to consider the matter thoroughly and be prepared to discuss the matter at the next meeting of RR2.
RR2 also considered input documents for agenda item 1.14. This agenda item has both a regulatory and a technical part. RR2 and SE31 therefore need to provide inputs on the respective parts and a framework for the brief has been worked out to help the groups in their work.
It should be noted that agenda item 1.14 is also of interest to the aeronautical users and that ICAO should be invited to contribute.
Handheld VHF with DSC distress alerting facility
A handheld VHF radio with a DSC alerting facility was recently introduced on the market. A large majority of the attendees to RR2 had supported the view that use of this equipment was not in conformity with ITU-RR. At the WGRR meeting, UK announced they will licence the use of such equipment in their territorial waters.
RR2 work programme
RR2 will develop a CEPT Recommendation on GMDSS coast station radio operators certification.
Monitoring of IMO activities
The IMO COMSAR/5 was held in December 2000 and a number of the RR2 members had attended the meeting. It was noted that just before the COMSAR meeting a small group had drafted a proposal on how to avoid exhaustion of the MMSI numbering.
During COMSAR/5 a draft paper on IMO positions on the WRC2003 agenda items had been prepared.
Work items on licensing and free circulation
During the WGRR meeting a “Licensing Day” was organised. During this day various presentations on electronic licensing and other licensing aspects were given and discussed. The event was considered a success and may be repeated for other topics at future meetings. RR6 were thanked for their work in preparing the event. A summary of these presentations and conclusions can be found on this website.
Mr Rieder presented the outcome of the questionnaire on electronic licensing initialised by RR6. Some Administrations indicated that harmonisation of electronic licensing systems might be time consuming and not be possible nor be beneficial to the market. Others stated that the issue was too important to remove from the work programme and that at least an ERC Report should be prepared which could contain issues such as an analysis of the questionnaire, the goals and aims of electronic licensing, lessons learnt from Administrations and the OSS, do’s and dont’s, applications suitable for electronic licensing, advantages and disadvantages of harmonisation of electronic licensing, expanded OSS as an alternative to national electronic licensing, proposals for future work, any recommendations etc.
Phasing out of CT equipment
Input to Decisions on changes to frequency allocations to take account of regulatory requirements had been requested by WGFM. A document had been drafted explaining the steps to be taken and preparing wording to be included in Recommendations or Decisions for changes in frequency allocation. Different processes needed to be applied depending or whether or not the equipment used is covered by individual licence or licence exemption.
The WGRR document would be converted into an ERC Report and WGFM would then restrict their Decisions to the frequency change, and refer to the Report.
Results of Public Consultation of Thuraya and S-SMS Decisions
A few remarks were received during the consultation phase indicating that the drafts did not contain sufficient back ground information on the satellite systems as such nor on the protection of other services such as the radio astronomy services and other services. The comments were included and it was agreed to send the revised draft Decisions to the next ERC meeting for final adoption.
Sweden and The Netherlands again expressed their concerns made at the previous WGRR meeting about the continuing process of drafting new ERC Decisions on licence exemption and free circulation of new satellite services in the light of the R&TTE Directive. Other Administrations hesitated to express commitment to the Decisions at this moment and some Administrations said they would need a firm guidance from the EC.
Future licensing policy
As an outcome of the “Licensing Day” (see) WGRR discussed the main conclusions of that day and how to proceed with the necessary work. The following topics were identified:
1) Further exploration of the ‘mental switch’ and the consequences for licensing;
2) Cost recovery and disconnecting fees from frequency management;
4) Structure of future free circulation and exemption Decisions
It was agreed to discuss the subjects 1, 2 and 3 in future WGRR meetings, if possible in the form of workshops.
A document, containing a proposal how to deal with harmonisation of regulatory measures throughout Europe in the line of EU legislation was presented and discussed.
The proposal contains four possible ways to achieve this.
1. Handling in WGRR
2. The forming of a new Project Team
3. An E-mail Correspondence Group
4. A mix between 2 and 3.
Almost all Administrations present supported the idea of forming a project team. The new Vice Chairman Mr Igor Minaev offered to prepare some Terms of Reference for the next WGRR meeting.
Follow up TG2
Withdrawal of commitment to existing Decisions on approval regulations
WGRR discussed the proposals for a standard text re: implementation of Decisions in the ERO database. The proposed standard text for ERC decisions on implementing parts of standards in the national conformity assessment regulations was agreed by WGRR after only a slight modification. The following text was agreed:
Implemented: See remarks
Remark: Due to the implementation of the RTTE Directive, [country name] withdraws its commitment to this Decision with regard to equipment, the conformity of which has been assessed as from 9 April 2000.
Each individual Administration will have to request ERO to insert this text into the database if wanted so.
Regarding ERC Decisions on free circulation and licence exemption WGRR could not agree on a standard text. Some EU Administrations indicated that they would not, others indicated that they might not be able to commit to these Decisions. Others questioned the legal implications of the proposed text.
Conversion TG2 report into ERC Report 102
Annex II of the TG2 report had been converted to an ERC Report. The meeting approved the Report with some changes and it will be published as ERC Report 102.
ERC had adopted the proposals contained in Annex I of the TG2 report in principle. However, ERC had given the opportunity to Administrations to comment until the next meeting of WGRR. In case no substantial comments were received, the proposals of TG2 would automatically be adopted. This is the case, so therefore the proposals are adopted and the ERC Decisions and Recommendations, that were proposed to be withdrawn, can be withdrawn.
Work of JPT-SAT on harmonisation of satellite licensing
The reports of two meetings of the JPT as well as the draft Report of the Comprehensive Satellite Initiative (CSI) were introduced.
The idea of having a joint meeting of WGRR and JPT SAT at the Bergen meeting in June to discuss the CSI proposals was addressed, and generally supported.
Concerning the draft CSI report, there was general support expressed for it as a good start for further work in the satellite area, and indeed some of the proposals might be of use in other areas.
Matters concerning radio fees and charges
Draft ERC Report on PMR
The Report on PMR fees was presented for approval by WGRR. There where no major substantial comments to the draft Report. However, some Administrations gave comments or said they would submit comments during the consultation.
Switzerland indicated that they would submit comments regarding:
- OECD service price indices should be taken into account in the Report;
- Cost recovery and the different ways to calculate the costs;
- The real meaning of having ‘lower fees’.
Finland agreed more or less with Switzerland that the Report might give some more information to explain the differences between the fees (‘what is done for the fee by the Administration?’) in Europe but also admitted that it was too late and may be impossible to get that information. Finland supported the Report.
The Report was approved by the meeting. It will be presented to Administrations for consultation. Comments can be forwarded for a period of 6 weeks from the start of the consultation. Comments will be dealt with by RR8.
Progress Report on Satellite fees
The draft Report could not be finalised for this WGRR meeting. It will be presented at the next meeting of WGRR in Bergen (Norway).
Administrations that have not yet checked the overview of answers to the questionnaire are kindly requested to do so.
Progress Report on refarming
The draft outline of this Report was noted by WGRR. WGFM should be involved during the preparation of this Report.
Power Line Communication (PLC)
RR11 is aware of the risk of interference from the use of PLT and ADSL systems and shared the view that the concern from enforcement is part of discussions in WGSE-PT35. RR11 agreed that no further action is necessary. In the event of interference problems and in the light of experience, RR11 may consider the issue again.
Work programme of RR11
It is proposed by RR11 to revise the current ERC Reports on Market surveillance and enforcement matters (numbers 66 and 78). These Reports were finalised before the implementation of the R&TTE Directive and therefore improvement is necessary. The revised ERC Report should also contain items such as e-commerce and Software Defined Radio (SDR).
Radio Frequency Identification Systems (RFID);
The SRD/MG proposed a very sophisticated automatic system control in order to restrict 2.45 GHz RFID readers with a transmitter power of 4 Watt e.i.r.p. to indoor operation only. The proposed automatic indoor/outdoor power control scheme is expected to make it impossible for the normal user of RFIDs to obtain a power of 4 Watt outdoor positions. A special indoor, fixed mounted, short range, system control unit should allow higher power of 4 Watt within its range of coverage. In case the exact same RFID reader is moved outdoor the power should be reduced to 500mWatt.
In response to this request RR11 preliminary concluded that it would be difficult to enforce the proposals at least when it is assumed that the equipment will not be covered by an individual licence. A liaison statement containing the provisional view of RR11 was submitted to the Chairman of SRD/MG for consideration. Furthermore, RR11 indicated that a fundamental discussion with SRD/MG is needed in order to optimise the role of enforcement in preparing new Short Range Devices regulatory provisions.
Draft Recommendation on Receiver requirements
Based on the RR11 liaison statement about the quality of receiver parameters, WGFM and WGSE have submitted their responses to RR11. In principle they agreed that a common approach on receiver performance is necessary within the CEPT countries. RR11 noted that a strong consensus emerges from this consultation and also took the view that a more formalised implementation is now necessary. It was agreed that, in principle, users should be responsible for any problems caused by the poor quality of their own receivers.
RR11 also suggested dividing receiving equipment in two categories.
· Radio equipment that is guaranteed a certain level of protection by Authorities, since they comply with the performance for receiver parameters which are assumed for spectrum management purpose;
· Other radio equipment whose use is in principle not protected.
The above consensus should be consolidated through a more formalised framework. ETSI, and in particular the newly created ERM/TG18 should be encouraged to:
· Confirm with the Commission Services when receiver parameters constitute an essential requirement under the R&TTE Directive and when it does not;
· Inform the ERC where such receiver parameters do not constitute an essential requirement, and maintain appropriate specification for these parameters.
In cases where such receiver parameters do not constitute an essential requirement, CEPT could prepare the appropriate official document (Recommendation/Decision) to encourage Administrations to base their spectrum planning on the receiver parameters specified in such documents, preferably through a reference to ETSI standards.
Based on this conclusion, a draft Recommendation was prepared and submitted to WGFM and WGSE for consideration. WGFM supported the approach by RR11 but asked attention to the some elements of the Recommendation.
WGRR agreed that RR11 will continue the work in close co-operation with the ERC Workings Groups.
Draft ERC Report on EPIRBs
RR11 prepared a Report on the increasing number of false alarms by EPIRBs. This Report was submitted to RR2 for comments. RR2 and RR11 agreed to continue the joint work on the Report and submit a final draft for the next WGRR meeting.
Comments to the Revision of the Recommendation T/R 61-02
The following comments were received during the consultation phase on the revision of T/R 61-02:
· One administration found it premature to adopt a change in Morse code examination requirements prior to WRC2003 where a complete revision of the relevant provisions in the Radio Regulations is on the agenda.
· One considered the proposed lowering of Morse code speed requirements in TR 61-02 to 5 Word per minute too low and therefor proposed lowering the speed to 8 words per minute.
WGRR decided to adopt the revision of the Recommendation 61-02 without including the comments. ERO will publish the revised version.
Belgium and Germany announced that the Morse code speed has been lowered from 12 to 5 words per minute.
WGRR took note of the revised list of Administrations that have implemented T/R 61-01 and/or T/R 61-02.
The meeting agreed on a status update of WRC-2003 agenda-items 1.7, 1.9, 1.10 and 1.14, being the items of direct WGRR interest. The status report will be sent to Chairman CPG for consideration by next week’s CPG. It explains that WGRR’s Project Teams RR2 and RR6 are proposed to do the necessary preparatory work regarding the earlier mentioned agenda items. On special request of Chairman CPG to present proposals (names) for CEPT co-ordinators , the meeting decided to propose Chairman RR2 (Mr Trond Olsen) as CEPT co-ordinator for the agenda-items 1.9, 1.10 and 1.14 and Mr Jaap Steenge as CEPT co-ordinator for agenda-item 1.7.
Sweden took on Presidency of EU on 1 January 2001 and negotiations on the text of the draft Directives continue in Council Working Groups. The text of the Framework Directives was almost finalised under the previous French Presidency. Discussions on the rest of the package are expected to be finished by June so that the Directives can be implemented before the end of next year.
Aspects of those Directives – particularly new structure for authorisation, possibility of using spectrum trading, auctions and comparative selection, will require study in WGRR.
The draft spectrum Decision could also have some implications for the WGRR, but negotiations on it have only just begun; in particular proposals for information about national frequency allocations are related to the separate proposal for an ERO frequency database.
Separately, the EU Licensing Committee continues to meet. Last meeting in December, looked at a possible CEPT Mandate for IMT 2000 expansion bands, fees, Broadband Fixed Wireless Access (BFWA) and OSS for Satellites.
Mr Igor Minaev of the Russian Federation was unanimously elected as Vice Chairman of WGRR. The Chairman congratulated Mr Minaev on his election and wished him good luck in his task.
ERO Frequency Data Base Project
The progress of the FDG group was noted. It was also noted that the FDG will propose to ERC the establishment of an ERC Project Team because the issue is dealt with in WGFM and WGRR and that the group is needed for a longer period of time.
During the meeting Mr Reinwein of Austria collected information from the participating countries on the following subjects:
· National regulations for the CB-band;
· National duty cycles for SRD in the 433 MHz band;
· National regulations for RLAN (SRD) in the 2,4 GHz band;
· General or class licences in the radio area.
He proposed ERO to complete the questionnaire with information from countries not present in the WGRR meeting.
It was agreed that RR9 will produce a revised version on the first three items.