WGRR, 14-17 September 1999, Marbella, Spain.
The Working Group considered the following subjects:
- Results of Public Consultation
- Conformity Assessment matters
- R& TTE directive
- Maritime issues
- Licensing and free circulation
- PMR Satellite issues
- Spectrum pricing
- Radio Amateurs
- ERO Reports
- Power Line Communications
Results of Public Consultation
Only very few comments were received during the Public Consultation of the Decisions II (Exemption from Individual Licensing of Inmarsat-B terminals for land mobile applications), JJ (free circulation and use of Inmarsat-B terminals in CEPT member countries enlarging the field of application of ERC/DEC(95)01), KK (Exemption from Individual Licensing of Inmarsat-M4 terminals for land mobile applications), LL(free circulation and use of Inmarsat-M4 terminals in CEPT member countries enlarging the field of application of ERC/DEC/(95)01) and MM (the Establishment of a Regulatory Database of licensing regimes for telecommunication networks and services).
WG RR agreed that the comments do not require changes of the text of the Decisions. The Decisions will be presented to the ERC for final approval.
Conformity Assessment matters
The Chairman of RR9 reported on the results of the RR9 meeting. The meeting continued to follow the national implementation issues of the 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 database is growing steadily and is now about 250. Also entries from Austria, Denmark and Norway have been received although most of them are still from Finland and UK.
There are now several Certification Authorised Bodies (CAB) in the UK, who undertake type approval certification on behalf of the UK RA.
Application and test report forms
RR9 had scrutinised the draft application and test report forms for ETS 300 718 (Avalanche beacons) received from ETSI/ERM/RP-08 and, in addition to the deletion of some irrelevant parts, only some editorial changes were made. .
WG RR approved the application and test forms and they will be published by ERO.
After having considered the TG2 draft proposals which included keeping ERC/DEC/(97)10 in force for application by non-EEA countries RR9 endorsed this approach. RR9 will hibernate until the outcome of TG2 work has been discussed by the ERC and WG RR. However e-mail mode of operation can be used for solving interpretation problems in the ERC/DEC/(97)10 regime.
Other Conformity Assessment matters
Austria introduced a document about the use of programmable radio equipment. This proposed that when issuing type approvals for equipment covered by a general licence regime, equipment programmable to fit into several Radio Interfaces should have a unique type designation for each Interface and should not be able to be (too easily) programmed by the user to change the factory/supplier set Radio Interface. This same principle should also be followed when the manufacturer notifies such equipment on the basis of art. 6.4 of the R&TTE Directive. In the discussion the responsibility of the manufacturer in designing the programming method to follow this principle was emphasised.
WG RR agreed that RR11 would take the issue of programmable radio equipment in the CEPT countries into consideration.
A draft CEPT Recommendation on receiver parameters, developed by SE21 was discussed. The purpose of the Recommendation is to follow up the decision made by ERC last year that, on a case by case basis, receiver parameters might have to be included in a standard.
In principle WG RR agreed with the idea of SE21 but some doubts were raised whether a Recommendation was the appropriate instrument for such purpose.
Short Range Devices
The possibility of handling a type approval application using the ERC/DEC/(97)10 procedure for a toy at 27 MHz using one-way narrow-band voice (AM) was discussed. In Finland (where the issue came up) this device could only be allowed on remote control channels because the application was similar to a baby alarm and was treated in the same way. However, in Germany only CB channels are allowed for speech and 5 channels with 50 mW output are reserved for baby alarms. In the UK baby alarms are also using CB channels and Switzerland does not allow speech on these remote control channels. Some other countries that once implemented T/R 01-04 (the old LPD Recommendation) probably still allow all kinds of use on any of the 27 MHz channels. The conclusion of RR9 was that if a type approval certificate is issued under the ERC/DEC/(97)10 regime, the certificate should contain a warning about the need of different frequencies in different countries. In WG RR discussions the need for a better frequency alternative for baby alarms was mentioned and an ERO questionnaire on the development of ERC/REC 70-03 launched in June was noted.
RR9 had noted that until the R&TTE Directive regime can be used, the ERC/DEC/(97)10 regime could be used for placing equipment like Bluetooth on the market since there is also an ERC Decision on the relevant radio standard and the frequencies are (almost) harmonised.
R& TTE directive
Report from ERC TG2
TG2 split the work in two items, the relation between EU and non EU member states and the influence of the R&TTE Directive on the current and future ERC output documents.
With regard to the first item TG2 would present a report to the next ERC meeting.
With regard to the second item, the different categories of ERC Decisions, some preliminary proposals were formulated. Items that should be discussed at the next TG2 meeting would include marking, the relation with ETSI and the influence on some Recommendations and Reports.
The Netherlands and Finland informed WG RR about comments received from the EU Commission on a notification of the implementation of the SRD Recommendation 70-03. The comment from the Commission was that they - in view of the R&TTE Directive - questioned the need for type approval procedures and licensing of radio equipment with transmitter power below 10 mW.
WG RR concluded that Recommendation 70-03 might have to be reviewed by TG2 as a matter of urgency in the light of the R&TTE Directive and the comments given by the Commission.
Report from TCAM 1, 2 and 3
The Commission representative informed the meeting about the progress of the implementation of the R&TTE Directive (99/5) and the results of the R&TTE workshop held on the 13th of September in Brussels.
The main topics were:The mandatory notification procedure of art. 6.4. may be relaxed for a number of radio equipment types (e.g. for receivers, radio equipment of a receive before transmit type, GSM terminals etc.); Radio spectrum management parameters: depending on the type of radio equipment, spectrum parameters might be included either in a Harmonised Standard or in national regulations; The simple radio equipment classes proposed by AHG B might have to be modified to add additional subclasses, e.g. for ISDN, NMT etc.); WTO: the consequences of the WTO for telecommunication regulations are not fully clear, but it was stressed that there are also a number of Community rules that limit the possibilities of telecom regulations. EC will provide a legal document on this issue for the third TCAM meeting, which will be held on 14-15 October 1999 in Brussels; Due to a change of the EC rules in the future non EU members have the possibility to attend TCAM or other EC meetings with the status of observer; EC will organise a Seminar on the R&TTE for non EU countries and other interested parties;
The ‘equipment on board of non SOLAS vessels’ issue was addressed as a problem to the EC because this maritime equipment is falling under the scope of the R&TTE Directive, however, the safety aspects are not covered in the R&TTE Directive.
The Administrations of the UK and the Netherlands expressed their concern about the missing safety aspects and indicated to address this concern to TCAM for consideration.
Development of free circulation and use of radio equipment
Austria addressed the problem of different marking systems (national marking, CE marking, CEPT marking and the R&TTE alert sign) within the CEPT and the consequences for free circulation. WG RR concluded that the current marking systems should be reviewed in the light of the R&TTE regime. ECTEL and ETSI advocated a marking system, as simple as possible and this view was supported by a number of administrations. WG RR also discussed the purpose of the marking: should it serve the enforcement authorities or the consumer?
TG2 should consider marking. RR11 was also requested to present a position on marking from an enforcement point of view to TG2.
ETSI draft guide on the development of Harmonised Standards
The ETSI draft guide on the development of Harmonised Standards prepared by TG6 and some suggestions for the discussion prepared by the vice Chairman of the ERC were discussed. A response from WG RR was prepared, which will be brought to the attention of the next ETSI ERM meeting scheduled the 5th of October 1999.Maritime issues
The chairman of RR2 reported the following activities: RR2 has reviewed the proposals of non-CEPT administrations and some organisations on WRC-2000 agenda item 1.7. The preliminary CEPT position has been identified for each non-CEPT proposal. The positions have been submitted to CPG/PT4, which has inserted them in the preliminary CEPT brief. RR2 has considered the situation arising from two different EU Directives relating to maritime radio equipment. The equipment of Convention ships would be subject to the Marine Equipment Directive and thus all the maritime safety aspects would be observed in the conformity assessment. However, the equipment of non-Convention vessels would be subject to the R&TTE Directive, which does not recognise the maritime safety aspects. The conclusion of RR2 was that all maritime equipment should be included in the Marine Equipment Directive. Thus the Directive should be amended to include also non-SOLAS vessels. Some concerns had been expressed in RR2, as to whether the EU Directive on the minimum level of training of seafarers (which reflects the STCW-95 convention) might require a modification of the ERC Decision concerning General Operators Certificate (GOC) and Restricted Operators Certificate (ROC) examination syllabi. RR2 had concluded that the ERC Decision is in full harmony with both the STCW and the Radio Regulations and that no modification is required. Some administrations participating in RR2 have prepared the quality system required by the Directive (EU Directive 98/35/EC amending Directive 94/58/EC on the minimum level of training of seafarers) and at least one administration is in the process of preparing one. The majority of administrations have not started the preparation of the quality system. Several administrations are in the process of extending their national licensing databases to include the information items required by WRC-97 Resolution 340 (ship information for search and rescue).
The meeting considered the proposal to prepare an ERC Decision on the harmonised use of spectrum and free circulation and use of terminals operating within satellite personal communication services (S-PCS) for the maritime service in the bands 1610-1625.5 MHz, 2483.5-2500 MHz, 1980-2010 MHz and 2170-2200 MHz. Some comments had been given by RR2 and some additional ones were brought up at the WG RR meeting. Despite these questions and concerns, the attitude of the meeting was positive towards developing a proposal on the use of basically non-maritime equipment on board ships. However, instead of a Decision on maritime S-PCS it was decided to have a broader discussion on this matter first and prepare a Report or Recommendation, which would also take into account other kinds of terminals as well as S-PCS.
The meeting requested RR2 to start work on this issue. Because of the ongoing preparations for WRC-2000, the work can be started only mid-2000.
Licensing and free circulation
The Chairman of RR6 reported on the progress of the group.
RR6 prepared draft Decisions for VSATs, SITs, SUTs and Receive Only Earth Stations (ROES). The problem still pending since the last meeting was the „Protection Requirements of Aircraft Avionics from VSAT and SNG Systems Operating in Close Proximity to Airports and Glide Paths" dealt with in the WG SE Report. This report will be discussed by WG SE next week and the value given as max. EIRP may still change. Some of the values are still to be discussed also at a meeting planned to be held on the 14th of October. The purpose of this meeting is to discuss any remaining problems regarding the protection of avionics by administrations, satellite industry, military experts and the ICAO.
Draft ERC Decision on Exemption from Individual Licensing of Receive Only Earth Stations (ROES)
This Decision was adopted for public consultation according to the new procedure.
It will be put on the ERO FTP server on Monday 20 September 1999. Administrations will be notified by e-mail or by fax by ERO. Administrations have 14 days notice to respond (until 4 October 1999) to ERO of any objections before it goes out for public consultation.
Draft ERC Decision on free circulation and use of IMT-2000 terminals
WG RR approved this Decision and submitted it to the ERC for public consultation.
High Level Statement UMTS Forum
Following the request expressed in ERC Report 60, the General Assembly of UMTS Forum has adopted a High Level Statement on Global Circulation of UMTS/IMT-2000 Terminals. The High Level Statement identifies a set of principles to support the global circulation of terminals and recommends authorities to subscribe to the principles. Regional telecommunications organisations (CEPT, CITEL, APT etc.) are requested to assist their members to implement the principles of global circulation as expeditiously as possible in advance of the planned introduction date for UMTS/IMT-2000 systems.
The meeting noted that the High Level Statement is fully in line with the developments in WG RR and that the Statement is reflected in the draft ERC Decision on the global circulation of IMT-2000 terminals.
A document giving information on the current state of affairs to the GMPCS MoU and the Arrangements was presented. Very few CEPT administrations have signed the MoU and the document contains therefore a proposal to draft an ERC Recommendation recommending CEPT administrations to sign the GMPCS MoU and implement the Arrangements.
In the discussion it became clear that that there was in general support for the idea of promoting the GMPCS MoU and Arrangements and support for bringing the issue once more to the attention of the administrations. The question was in this respect raised why administrations did not sign, since signature did not oblige to anything nor did it bring costs and many administrations had implemented the relevant ERC Decisions anyway. However, there were doubts expressed by some administrations whether a Recommendation would be the right instrument and whether this would add anything. Others were of the opinion that such a Recommendation would give the right signal to the outside world that CEPT was positive towards global circulation.
The meeting decided to annex the draft text of the Recommendation to the Minutes of the meeting and discuss it again at the next meeting. Administrations are requested to discuss the proposed Recommendation internally. PMR
Report of the Ad Hoc Group on PMR
Work was being carried out on drafting Decisions for generic application forms and licence documents. It was noted that the EC Licensing Committee followed the work of this Ad Hoc Group with great interest. WG RR also noted the intention of the Group to submit the draft ERC Report on PMR and the Decisions for consideration at the next WG RR meeting.
Implementation of PMR446 Decisions
A proposal to evaluate the implementation of the PMR 446 Decisions at the next RR meeting was introduced, since it seems that administrations have implemented or will implement this Decision in different ways.
The Short Range Radio Group had sent a letter to the Netherlands Administration requesting clarification on their position on the possibility to introduce in PMR446 equipment such features like simple scrambling using spectrum inversion, combining with other equipment like FM radio, selective call and CTCSS-DCS function. It was noted that questions on similar subjects had also been sent to other administrations and to ERO. The meeting did not see problems in allowing such functions which are neither specifically prohibited in the relevant ERC Decisions nor in ETS 300 296. However, RR9 had in their meeting noted a need to change test modulation frequency for the wanted signal in the receiver measurements to 2300 Hz if spectrum inversion is used without the possibility to bypass the circuits for the measurements.
In order to achieve a common idea about the different questions, the Netherlands proposed to evaluate the implementation of the PMR Decisions at the next WG RR meeting and proposed to collect more relevant information from administrations about PMR446 practice in order to see whether action is needed to safeguard harmonised use of PMR446 in CEPT countries.
The WG RR agreed that RR9 should take this matter on board in order to prepare a report for the next WG RR meeting and Administrations are asked to inform RR9 about the way they have implemented the Decisions on PMR446.Satellite issues
One Stop Shopping for satellite networks
The minutes of the last meeting of the sub group for the Common Application Form (CAF) were introduced as well as the selection procedure and final choice of the Steering Group for the Software House, that will build the database and the CAF.
Though there are still a lot of issues to be solved it was expected that the software house would be able to develop the software for the regulatory database and the CAF and to finalise it March 2000.
WG RR members were invited to attend the next meeting of the SIG (7 - 8 October), which would develop a Recommendation on the implementation of an OSS procedure.Satellite Scorecard
This scorecard was prepared by the regulatory Working Group of the Satellite Action Plan (SAP) and was distributed at the start of the WG RR meeting.
The meeting discussed the table which is aiming at comparing the implementation of ERC Decisions and Recommendations and comparing licence fees affecting satellite services. A number of administrations expressed concern that while the table appears to be a useful comparison, the information has been compiled from different sources without accuracy or consistency. It also appears to include both service and radio fees without clarification of which is which. Furthermore, many administrations have in practice implemented Decisions informally, but may not yet have been able to adjust their laws and regulations accordingly. Consequently readers, e.g. the European Commission, may gain the wrong impression about progress on these issues.
It was agreed that it is important that the table be made accurate.
Administrations were therefore urged to recheck their entries and inform Mr. David Wright of Inmarsat of any corrections and updates needed. They should also advise the Chairman of RR8 accordingly.Spectrum Pricing
Draft ERC Report
RR8 concentrated on the finalisation of the Draft ERC Report, "The role of spectrum pricing as a means of supporting spectrum management". The draft was presented to WG RR for approval. It contains chapters on cost based pricing, administrative incentive pricing, auctioning, spectrum trading and refarming. Its aim is to give information to administrations and practical advice.
With regard to the further procedure it was decided to approve the Draft Report preliminarily. It would be sent to administrations for comments, which should be made before the next RR8 meeting, which will be held in Groningen, 28 and 29 October.
RR8 made a start with investigating satellite fees. Contact was made with the SAP RWG score card group. There does not seem to be an overlap in the tasks of both groups. RR8 will collect information on the situation in a limited group of countries, since it does not seem realistic to expect to be able to collect information on the situation in all 43 countries. Countries, who had not yet reacted to the request to send information on the background of their satellite fees were requested to do so. It was intended to concentrate on this issue at the next RR8 meeting. A representative of the score card group would be invited.
The WG RR Ad Hoc group on PMR had collected information on the PMR fees in the different countries and had asked RR8 to develop some proposals on how to calculate PMR fees. The next RR8 meeting would concentrate also on this issue. A representative from ECTEL would be invited to the next RR8 meeting.
Chairman of RR11 on Enforcement highlighted a number of activities going on in the PT.
Draft ERC report on Market Surveillance aspect of Enforcement for Radio Equipment;
RR11 had produced a draft ERC Report on Market Surveillance aspect of Enforcement for Radio equipment. It was recognised that many aspects of this item had a close relationship with the new R&TTE Directive (99/5) for EEA countries and for non EEA countries the ERC/DEC(97)10 conformity assessment regime. WG RR emphasised that Administrations are responsible for all market surveillance issues in their countries.
WG RR concluded that this ERC Report has to be read as a CEPT/ERC guidance for Market Surveillance and Enforcement authorities. Many issues such as the control of the notification procedure, confidentiality of the collected information of notified equipment (article 6.4), should be clarified by TCAM. Further discussion will be necessary about the policy of testing equipment in order to control compliance to the essential requirements.
The Draft ERC Report will be presented for approval at the next WGRR meeting.
ISM equipment in radio communications
RR11 discussed the item of interference in radio (aeronautical) communications caused by ISM machines in the UK. RR11 came to the conclusion that probably the problem is not restricted to the United Kingdom only, but also exists in other CEPT countries. To identify the scale of the problem it has been agreed to send out a simple questionnaire to all CEPT countries. Based on the answers from the Administrations and conclusions RR11 will discuss this item in its next meeting. The outcome of the discussion will be forwarded to WG RR for considerations
Investigation of the possibility of a central database to exchange internal information for Enforcement purposes
WG RR concluded that several electronic systems such as the ERO/FTP server and e-mail groups within the ERC family fulfilled for the time being the need to exchange internal information for Enforcement authorities
WG RR agreed that when the Commission has finalised the feasibility study (Einstein project) on exchanging information the ideas of using a central database for this purpose can be worked out further by RR11.Radio Amateurs
An Australian application to join T/R 61-02. This application was distributed to ERC list D. Administrations should inform ERO before the 5th of October 1999 if they can accept the participation of Australia.
The CPG ‘shopping list’ of the possible items to be included in agenda of WRC-2002/3 was discussed. It was decided to set a certain order of priorities with respect to possible WRC-2000 agenda items. Namely, items 2.2 (revision of Article S25 of RR) , 2.4, 2.10, 2.11.1 and 2.11.2 (maritime issues) of the Resolution 722 (WRC-97) were considered as high priority, and proposal on the ‘shopping list’ concerning global circulation of radio terminals was considered a medium priority issue.
WG RR also commented on proposals on the ‘shopping list’ concerning protection of radio astronomy (emissions, spurious/out of band and radio quiet zones, remote areas, Radio Astronomy Services), considering these issues as medium priority ones.ERO Reports
ERO distributed the following reports by mail last week: Conformity Assessment in the CEE countries Harmonisation of free circulaation between regional telecommunications organisations
An overview of the process and work plan regarding the Detailed Spectrum Investigation Phase III covering the frequency range 862-3400 MHz was discussed. It was remarked that the report contained regulatory issues, which should be outside the scope of DSI III. In particular, there seems to be a wish to regulate the methods which administrations use for refarming. A strong message should be sent to the management of the DSI process that the method of refarming shall remain in the national competence.
As this document was distributed very late, it was decided to discuss this matter at the next WG RR meeting in order to produce a report on DSI III. Power Line Communications and the use of frequency spectrum
Norway asked the attention of the possible radio interference caused by communications via power lines. WG FM was asked to study this problem.
It was noted that ETSI is already dealing with this development. UK informed the meeting about their experience with PLC and that the UK would provide the next WG RR meeting with more information.
Because of the expected interference RR11 was asked to discuss this item in their next meeting and provide the next WG RR meeting with a document.
It was agreed to discuss this matter at the next WG RR meeting on the basis of the provided informationDate and place of the next meeting
The next meeting will take place in Helsinki (Finland) on 24- 28 January 2000.