WGRR, 24 – 28 January 2000, Helsinki, Finland.
The Working Group considered, among other things, the following subjects:
- Conformity Assessment matters
- R& TTE directive
- Maritime issues
- Licensing and free circulation
- Satellite issues
- Spectrum pricing
- Radio Amateurs
- DSI III
Conformity Assessment matters
ERC Decision on the mutual recognition of conformity assessment procedures including marking of radio equipment and radio terminal equipment (ERC/DEC(97)10).
The implementation situation of this Decision has not changed since the previous WG RR meeting but the number of entries in the equipment database is growing steadily and has recently exceeded 500. Entries from Austria, Denmark and Norway have also been received although most of them are still from Finland and UK. There are now several Conformity Assesment Bodies (CABs) in Denmark and UK. In total, there are 18 CABs notified to the ERO for this regime. It was reported that on the basis of questions raised by some manufacturers it was found that they were not quite aware of the meaning of mutual recognition achieved by this regime, even if they had received certificates according to ERC/DEC/(97)10, and even worse, there had been cases where the CAB had not sent information to the ERO.
R& TTE directive
A joint WG RR/TG2 meeting was held. Results of the joint TG2/WG RR meeting were:
TG2/WG RR agreed to draft a document which lists Recommendations and Reports that might be outdated and superfluous and therefore could now be withdrawn. It was decided to send the list to ERC administrations for comments after which the list will be finalised and send to the ERC meeting in October for final adoption.
A document containing Frequently Asked Questions (FAQ) about the consequences of the R&TTE Directive for the CEPT was finalised and will be published on the ERO web server.
The EC will send the FAQ to their legal service for a legal scrutiny. TG2 will be the maintainer of the FAQ, which is a living document that might be changed regularly.
It was agreed that an information document about the R&TTE Directive from the Netherlands will be published on the server as an example for other Administrations that also want to issue information about the R&TTE Directive.
It was decided that ERO will devote a special section on the web site on R&TTE matters. Links will be made to Administrations’ web sites containing R&TTE information.
Administrations are requested to inform ERO about specific R&TTE information on their web sites, in order to establish links.
The R&TTE Directive does cover radio equipment and it allows equipment to be placed on the market for its intended purpose where it complies with the appropriate essential requirements. The putting into service however may be subject to authorisations -e.g. a licence - on the use of the radio spectrum. However, the spirit of the R&TTE Directive might be that the use of equipment should be allowed without restrictions and that licensing of equipment should be justified explicitly. The need for individual frequency assignment and the risk of interference are the main justifications for issuing individual licences.
In the light of the R&TTE Directive - and other communications from the EC - it would be desirable to have a common CEPT view on licensing of radio equipment, its justification in individual cases and on the restrictions to be put onto the use of radio equipment. As proposed by TG2 the ERC approved that as a first step the possible impact of EU legislation and policy within the current ERC licensing policy should be studied.
WG RR/TG2 agreed to reconsider the existing ERC policy on licensing.
Report from TCAM 4
The EC representative gave a short overview of the TCAM4 meeting in December 1999. He explained that there are still 22 legal issues to be solved. He advised the meeting that access to TCAM documentation is available to all WG RR delegates.
At the previous meeting of WG RR concerns and questions had been raised on the development of an ERC Decision concerning the use of S-PCS terminals onboard ships. The answers of RR2 to those concerns and questions were presented and WG RR was requested to approve that the work would be continued on the development of the ERC Decision.
A number of concerns were raised, in particular the following:
Although the RR2 report explains that similar Decisions will not be required for land mobile terminals, some delegates still considered that such a requirement may be raised;
S-PCS may cause interference to radio astronomy. This difficulty should be taken into account and relevant text inserted in the Decision;
There have been cases where S-PCS terminals have caused interference to navigation equipment. This issue should be taken into account and relevant text should be inserted in the Decision;
A concern was raised that Administrations would require the S-PCS terminals of passengers to be included in the licence. The Decision should be rewritten to make it clear that it relates only to the terminals that 'belong to the ship';
Also, a somewhat contrary opinion was raised, i.e. that the S-PCS terminals of the ships crew should be listed in the ship station licence;
The Decision should avoid duplicating texts that are already in the existing S-PCS Decisions;
In accordance with the Radio Regulations references to the possible utilisation of these kinds of equipment in order to provide safety of navigation and safety of life at sea should be included in the text of the Decision.
Some administrations supported the continuation of the work, others questioned the need for the proposed Decision since a lot of Administrations probably exempted these equipment from licensing.
After discussion, it was decided to continue the work but rewrite the Decision in order to remove any uncertainties.
IMO should be informed about the development of the Decision and the elements that were discussed in relation to this Decision.
Licensing and free circulation
WGRR discussed the possibilities to prepare a report on this matters. It was noted that the EC would give full support to prepare such a report and that ERO would have the experience and knowledge to assist in the work. It was however concluded that it was too early to start the work and that the task should be clearly defined and that ERC support for such a task would be needed in order to get the necessary participation in the work.
Comments of the EC on licence exemption
The Commissions Services were surprised to note the adopted Decision on ROES by the ERC. The putting into service of receive-only equipment cannot be limited for spectrum reasons. Provided that receivers comply with the EMC and electrical safety requirements of the Directive, their use can only be limited for reasons foreseen in Article 30 of the EC Treaty (e.g. public order, health). Such reasons however fall outside the remit of ERC. The EC representative stated that from a EU point of view the ROES Decision, as already adopted by ERC, was superfluous for EU members but that since the Decision itself had no immediate legal effect, EU countries could - if they want to - commit themselves to this Decision.
Revision of ERC Decision (95)01 of 1st December 1995 on the free circulation of radio equipment in CEPT member countries
There were several possibilities to modify this Decision considered, such as revision of the existing Decision without changing the number of the Decision, amend Annex 1 to include all types of equipment which were addressed in separate follow up Decisions or cancel Decision (95)01 and replace it by a new Decision.
It was decided not to change the existing Decision for the time being because the changes will be only minor but it would need a new Decision since the amended ERC Rules of Procedure do not provide for a modification procedure. The proposed modifications would hardly justify the long process of redrafting and adoption of a new Decision.
Revision of CEPT/ERC Recommendation 01-07 (harmonised Regime for Exemption from Individual Licensing of radio equipment)
The revised version - which would bring the existing text in line with the R&TTE Directive - was approved by the meeting. It was noted that the future work of TG2 might have influence on this Recommendation.
The modified Recommendation will be sent out for comments to Administrations and approved if no major comments are received by ERO.
Meteor Scatter Communications
A draft Recommendation prepared by WG FM was produced. WG RR had asked WGFM to prepare a Recommendation on the frequencies to be used for Meteor Scatter Communications as a basis from which to develop measures on free circulation. However, the draft Recommendation from WG FM already included the free circulation aspects in their Recommendation. WGFM expected that Decisions on free circulation and licence exemption would not get the necessary support of the Administrations at the ERC and therefore a Recommendation had been prepared.
Finland and Czech Republic stated that they cannot support this Recommendation because the frequency is used for other purposes.
Poland stated that for operation of this equipment in Poland a national type approval is necessary..
WG RR did not have strong arguments against the WG FM proposal and therefore agreed in general to support it. Some comments were made.
The remarks from WG RR will be forwarded to the Chairmen of WG SE and WG FM.
Report of the Ad Hoc Group on PMR
The draft final Report on the investigation of the possibilities of harmonising licences and fees for the PMR service within CEPT Administrations (ERC Report 73) was introduced. It was emphasised that RR8 is dealing with harmonisation of licensing fees. As licence fees had been changed by several Administrations recently it was proposed that a revised version of the draft Report should be produced.
Draft ERC Recommendation on PMR definition, processing time, PMR Classification and PMR licence duration
Draft ERC Decision on harmonisation of licence documentation for PMR
Draft ERC Decision on harmonising PMR Licence Application Form
Some countries questioned the need for Decisions on these subjects and were of the opinion that ERC Recommendations would be a sufficient instrument to achieve the proposed goal. Since WG RR could not find proper grounds for Decisions, it was finally agreed to change the Decisions into Recommendations.
The following remarks were made.
Many Administrations questioned the need to include PMR sectors classification in the Recommendation on PMR definition, processing time, PMR classification and PMR licence duration. This was regarded as only being of benefit for industry and of no benefit for Administrations. Also, most Administrations would have to change their automated administrative systems to fulfil the wishes of the industry at considerable costs. Overall, the pros would not outweigh the cons of the proposed classification.
Other Administrations had problems with the definition of PMR, whether the contents of the licence documentation are a minimum or a maximum requirement, the influence of the R&TTE Directive and the need to mention the make/model of the equipment.
Finally, it was decided to return the Decisions and the Recommendation back to the Ad Hoc Group with a request to redraft them, taking into account the comments made. UK said that the Ad Hoc Group would work mostly by email.
The Ad Hoc Group was requested to merge the two Decisions into one new Recommendation. The PMR classification should be deleted from the Recommendation since it is already incorporated in the Report, and appropriate revisions to both documents will be redrafted.
The representative of ECTEL expressed his disappointment about the outcome of the discussion because he thought that Decisions would be more beneficial than Recommendations.
WG RR participants were asked to provide updated information on the content of the Report (such as licence fees) and other comments to the report and the proposed Recommendations before the end of February 2000.
A draft letter from the Chairman WG RR to the Austrian Administration regarding a proposal for modification of the Vienna Agreement regarding shortening the co-ordination procedure was introduced by the Chairman. It was noted that a similar recommendation was made in the ERO Study on PMR and PAMR Licensing of July 1997 but no action had been taken. It was agreed to send this proposal to the Austrian Administration.
Implementation of PMR446 Decisions
WG RR decided in the previous meeting to prepare a report on this issue for the next WG RR meeting. A summary document had been prepared on the basis of information received from various sources. It was noted that some Administrations had implemented the Decisions only partly and that some Administrations had implemented the Decisions in different ways.
The summary table of this document, after having been completed by inserting the latest information from a number of countries, was agreed for publication on the ERO web pages.
The UK Administration had received proposals from the industry concerning the possibility to use time-division duplex and digital modulation in PMR 446. These proposals would be studied.
Draft ERC Decision on Exemption from Individual Licensing of Satellite User Terminals (SUTs)
Draft ERC Decision on Exemption from Individual Licensing of Satellite Interactive Terminals (SITs)
Draft ERC Decision on Exemption from Individual Licensing of VSATs operating in the frequency bands 14.0 - 14.25 GHz and 12.5 - 12.75 GHz
The outcome of the ERC discussion in November 1999, which could not adopt the Decisions at that time and returned them to WG RR, was noted. WG RR discussed documents, which contained modifications proposed by the EU Commission in order to align the Decisions with the R&TTE Directive. A proposal to develop a system which would only permit terminals to be registered by the Administration for site clearance reasons, instead of a system of full licence exemption, was discussed as well.
The discussion showed equal numbers of Administrations in favour of licensing exemption Decisions, and the other proposal. No Administrations objected to the Decisions on a matter of principle.
WG RR decided to proceed with the development of Decisions to deregulate the licensing of VSATs, SITs and SUTs. Since some Administrations preferred licensing exemption and others supported the registration proposal it was decided to combine the new proposal with the existing text, and also take account of the modifications proposed by the European Commission.
A new text was drafted for all three draft Decisions and adopted by the meeting.
Though some Administrations said they might not be able to implement the Decisions, there were no objections to adopting them for public consultation in accordance with the new Rules of Procedure. The draft Decisions will therefore be published on the ERO FTP server on January 31st. Provided no objections to proceed with the consultation procedure are received by ERO, the consultation will start on 15 February and they will be considered for final adoption at the March meeting of the ERC (27-31 March). The previous ERC meeting already agreed that such a short public consultation period (4 weeks) was acceptable since the Decisions had been under consideration for such a long time.
The EC representative congratulated WG RR on the completion of the work on these Decisions since these were important Decisions for the satellite industry.
France and the Russian Federation stated that their current telecommunications law does not allow implementation of the three draft Decisions.
Portugal stated that, taking into account the location of some Portuguese airports and potential harmful interference (electronic navigation and control equipment used on board aircraft) it has no intention to adopt these Decisions for the time being. The matter is under study.
Sweden indicated that for legal reasons it cannot implement the Decision on Exemption from Individual Licensing of Satellite Interactive Terminals (SITs) with regard to Decides 2. It will however investigate the possibilities of changes to the law.
Romania stated that they could not adopt these Decisions due to sharing problems with other services. Additional studies will be necessary.
One Stop Shopping for satellite networks
The Chairman reported on the developments of the SIG OSS SAT. Given the complexity of the task good progress has been made so far. The Decision on the regulatory database was adopted by ERC and ECTRA and is being implemented at present. A software house is currently developing the software for the application form and the database.
During the meeting ETO gave a short overview of the work done by the SIG OSS SAT so far and of the constraints encountered such as:
- the complex task of defining requirements
- the electronic application form
- differences between national regimes
- limited time and budget
Other constraints were the language requirement, the variety of requirements and questions asked by NRAs, and the means of electronic submission.
It was also noticed that 15 countries need the application form in their national language and that 18 countries accept applications in English.
The difference in the numbers of questions needed by Administrations to handle the same type of satellite applications was considered remarkable.
ETO gave also a presentation of the first version of the OSS electronic application form. Several Administrations and representatives of the satellite industry congratulated the SIG OSS SAT on the results and indicated that their earlier scepticism of the OSS project had been removed.
The costs of maintaining the OSS will be discussed at the next meeting of the SIG OSS SAT.
Draft Recommendation on the establishment of a CEPT One Stop Shopping procedure for Satellite Licences and Authorisations
The Chairman introduced the draft Recommendation on the establishment of a CEPT One Stop Shopping procedure for Satellite Licences and Authorisations, as prepared by the SIG OSS SAT. It is SIG OSS SAT’s intention to submit the Recommendation together with a final presentation of the software to the next ERC/ECTRA meeting for final approval and to ask ERC/ECTRA to give the green light for the start of the OSS from July 1st 2000.
Since SIG OSS SAT will have one more meeting for finalisation of the Recommendation, any additional comments from Administrations are welcomed. Comments should be submitted up to 29th February to the secretary of the SIG OSS SAT Mr. Ad Wouterson by e-mail (email@example.com) for discussion at the next meeting of the SIG OSS SAT on 2/3 March 2000
WG RR agreed that ERC and ECTRA should be advised to approve this Recommendation.
A draft Recommendation was already discussed at the last WG RR meeting and participants were asked to discuss the proposed Recommendation internally since the need for such a Recommendation had not been clear at the previous WG RR meeting. The proposed Recommendation was discussed at the last joint ERC/ECTRA meeting where it was agreed that the Recommendation would be beneficial and that WG RR should continue to work on it. The EC representative informed the joint ERC/ECTRA meeting that the Commission has not signed on behalf of the CEPT countries and advised EU member states to sign the Recommendation or even better sign the MOU as soon as possible.
The Russian Federation stated that at the present time the current telecommunications legislation does not allow to sign the GMPCS MoU.
The Recommendation was provisionally approved and will be circulated for comments.
The reactions from some Administrations to the draft ERC Report on the role of spectrum pricing as a means of supporting spectrum management were included in the text and the report was published as ERC report 76.
Frameworks for Reports on Satellite fees and PMR fees were produced.
Further work should be undertaken in the area of refarming issues and WG RR was requested to agree to putting the theme on the work programme.
It was noted that - despite the growing importance of economic aspects in frequency management - only a few Administrations attended RR8 meetings. Administrations were urged to take part in the work of RR8. Administrations that cannot take part in the Project Team do have the possibility to collect the documents from the PT by electronic means and any written contribution would be welcomed.
Some Administrations remarked that the economical aspects of the work carried out by RR8 was distinct from the other more practical items of fee harmonisation and these two items demanded different people.
Administrations were urged to participate in the work of RR8 either by correspondence or by attending meetings.
Interference caused by ISM Equipment in radio applications.
Based on the outcome of a questionnaire RR11 recognised the importance of the collected information and agreed to prepare an ERC Report on ISM. This report will be sent to WG RR for consideration and adoption.
Marking in the CEPT countries
RR11 produced a document giving an overview of the complexity of marking after the coming into force of the R&TTE Directive. The discussion showed that for EU countries the CEPT marking system has lost its value, and also for non-EU countries it would have consequences if EU-countries would not be able to recognise the CEPT marking any longer. Only a few Administrations present indicated that they would need the CEPT marking in the future. However, some Administrations were not able to give a view on the future need for the CEPT marking right now.
It was concluded that further work was needed in order to decide whether, and to what extent, the CEPT marking would be useful in the future in the light of the R&TTE directive. It was decided that RR11 should continue the work and prepare a proposal for the next WG-RR.
CEPT administrations are strongly requested to forward their view about future CEPT marking to the RR11.
The Commission supported the work to be undertaken by RR11.
Draft ERC report on Market Surveillance aspect of Enforcement for Radio Equipment;
The Report explains the changing telecommunication environment and the consequences for market surveillance. Control of equipment already on the market and in use should be replaced by a type of control that focussed more on the start of the commercial chain, before the equipment would be put on the market. Another conclusion of the report is that market surveillance could only be successful under international co-operation. The Report was seen as a very useful document for those countries still in the process of establishing a market surveillance structure.
It was decided to approve the draft Report provisionally with minor modifications. Administrations are requested to send comments to the report before the next RR11 meeting , which will be held in Biel, 7 - 8 March for adoption of the ERC report.
Power Line Communications (PLT)
The need of development of PLT was recognised, but serious concern was expressed for radio services in the HF band, such as emergency and civil aviation radio services. Furthermore, it is expected that the emission level produced by PLT systems will automatically be in conflict with the essential requirements of the EMC Directive. As a consequence, the introduction of PLT systems in the CEPT member countries without protection of these services, will give a lot of complaints of interference to radio systems. The outcome of the discussion was reflected in a letter and submitted to WG SE, WG FM and the Project Team PLT for consideration.
A press release on the use of so called blinking antennas by the Finnish Administration was introduced.
For some GSM mobile phone hand portables there are available on the European market so called blinking antennas. The original GSM antenna can be screwed off and replaced by an antenna, which blinks when the transmitter is active for a call or other messages.
On the basis of measurements performed in some European countries the original antenna of a GSM phone is considerably better than the "blinking antennas" tested. The blinking antennas cause higher levels of (unwanted) spurious emissions from the transmitter than the original antenna. In addition the transmitted power (wanted signal) on the assigned channel decreases. GSM networks may in such cases command the mobile phone to a higher power setting, which will draw more power from the battery and shorten the available usage time before needing to be re-charged. In addition the GSM network coverage may be limited.
The CEPT Administrations cannot directly set restrictions on placing on the market of blinking antennas in their countries, because the antennas are not considered to be radio equipment when sold separately. However, a GSM mobile phone in which the original antenna has been replaced by such an antenna is not likely to comply with the essential requirements for spurious emissions as mentioned in the EMC Directive.
WG RR concluded that Enforcement Authorities in most of the CEPT member countries have the right to inspect such a GSM phone. if there is reason to doubt that it has caused radio interference, and make it temporarily inoperable. As a consequence, in case of emergence other GSM users are not able to use the GSM network.
In conclusion the use of blinking antennas has more disadvantages than advantages for the users and the GSM network operators. RR11 has expressed their concern about the use of blinking antennas. The Press release published 22 December 1999 by the Administration of Finland was distributed via the e-mail group "enforcement".
The IARU introduced a proposed modernisation of Article S25 of the Radio Regulations prepared by the IARU and accepted by all three IARU Regions. It was the general conclusion that at this stage it would be premature to go into the substance of the proposed changes, however the idea of modernising S25 was unanimously supported by the WG RR. Any further work required will be undertaken by RR6, depending on the results of the WRC-2000 which could put the topic on the agenda for WRC 2002/3.
The representative of the Russian Federation made the following statement:
The Russian Federation supports the proposed changes to Art. S25 of the Radio Regulations but indicated that it is necessary to keep item S25.5 as it is.
It is the opinion of the Danish delegation that the demand on Morse code test in RR S.25.5 should be abolished at a future WRC since there is no justification for this demand.
Reference is also made the agenda item WRC2000.
The application from Australia to join T/R 61-02 was introduced. Denmark made a remark about the Morse code requirements (10 wpm) required in Australia and the 12 wpm required under T/R 61-02. Further reactions were received from a number of Administrations. After a short discussion the WG RR decided to accept the aforementioned application.
Because of the major support to the position to accept issue of Level A certificates to radio amateurs who have passed a Morse code test where the demand were less than the prescribed 12 wpm in T/R 61-02, Denmark announced that Denmark in future will issue Level A certificates to Danish radio amateurs who have passed the present 5 wpm test in Denmark.
Since the trend in a number of countries is to lower the requirements for Morse examinations, it was agreed to accept the application from Australia.
It was also suggested to modify T/R 61-02 (Morse code requirements), however the general feeling of the meeting was that it would be premature to take the decision concerning this issue at this time because of developments at the next WRC.
The outcome of the latest meeting of the CPG-2000 in Stockholm (January 2000) was presented. It was mentioned that a WG RR email group on WRC issues was started by co-ordinating the WG RR position on the issues related to the agenda of future WRC conferences (WRC-2000 agenda item 7.2).
The CPG endorsed the views of the WG RR in this matter and took a preliminary decision to include all its proposals into the draft ECP on this issue. This covers:
- Revision of S25 and rephrasing of S1 (amateur service);
An item related to global circulation of radio terminals, to be included in the preliminary agenda of WRC-2005/6.
- Review of maritime HF allocations;
- Matters related to Ap. S13, Res. 331 and changes to chapter SVII of Radio Regulations;
- Matters related to exhaustion of MMSI numbers and shore-to-ship distress priorities;
In addition, the CPG requested all its PTs and ERC WGs to provide the CPG/PT1 with the refined reasoning for relevant proposals for future WRC agendas, in the form of text of an ECP and CEPT Brief on WRC-2000 agenda item 7.2.
A draft liaison statement to send to the CPG/PT-1 was prepared, with a copy to the CPG/PT4. The statement presented the WG RR position on items related to amateur service and global circulation. In addition WG RR developed guidelines for the WG RR/RR-2 on maritime issues, where a separate input to the CPG/PT-1 should be expected from RR2, possibly jointly with the CPG/PT-4.
It was also proposed to appoint the WG RR co-ordinator for the next crucial meeting of the CPG-2000 (March 2000, Istanbul). Mr. Länsman of Finland agreed to represent WG RR at this meeting on the issues related to the future WRCs.
Any further work on revision of S25 and other related parts of the Radio Regulations is to be undertaken by RR6, depending on the outcome of the WRC-2000.
The draft Recommendations of DSI Phase III were introduced. The DSI III workshop accepted the proposals submitted by the previous WGRR. On the basis of this RR8 proposed to add a new item ‘refarming’ to the work program of RR8.
The UK commented on the time scale of the proposed revision of the European Common Allocation Table (end 2000) mentioned in the conclusions and recommendations and thought this to be too early in relation to the Telecom Review ‘99. This concern will be passed to the final DSI workshop in Mainz, 22 February 2000.
Date and place of the next meeting
The next meeting will take place in Eger, Hungary 10 – 14 April 2000