MINUTES OF THE 6th WGRA MEETING IN HELSINKI, FINLAND, 26-30 September 2005.
1. REPORTS OF OTHER MEETINGS
1.1. Report of the 11th ECC meeting
A report on the 11th ECC meeting was given by the WGRA chairman, based on Document (05)124, an excerpt from the minutes of that meeting.
The meeting noted in particular the adoption of the ECC Decisions on ESVs and AES, the modification of ERC/DEC/(95)01 and ERC/DEC/(97)05. Further issues included the procedure for determining whether to start work on a new Decision, the work on a draft ECC Decision by JPT MSS 2GHz, the preparation of draft LEST and HEST Decisions, the work on GSM on board vessels and GSM on aircraft as well as the need for free circulation Decisions.
1.2. ETSI Co-operation
The ETSI ERM group had discussed the definition of ‘integral antenna’, but the ETSI liaison officer had not been in a position to report on this issue yet.
The ETSI liaison officer had not been in a position to attend this week’s WGRA meeting, and the meeting noted the clash of the meetings of WGRA and WGFM. However, there may also be advantages of the two groups meeting in the same week.
1.3. Report from EFIS Maintenance Group
ERO reported on the progress in EFIS. The software had been upgraded in the spring of 2005 as to enable inclusion of detailed radio interface information. Important points from the EC input to the June 2005 RSCOM meeting were highlighted, notably the need for inclusion of more information in a European frequency information portal that could be EFIS.
Finally, the importance of using standard terminology in all ECC Decisions and Recommendations was stressed, since national administrations would have a problem in uploading non-standard information into EFIS when implementing those in national legislation.
It was suggested that the process of introducing new terms for applications should be formalized within the ECC.
1.4. Report of SRD/MG
The report of the SRD MG (document FM(05)133) was introduced by ERO, highlighting the activities of the group.
The meeting noted developments, especially the modifications and amendments in the ERC REC 70-03. Annex 1 of this recommendation was felt being far too complex to be used by interested parties outside national administrations.
Notably the RA11 team had detected dissatisfaction with the structure and the very detailed regulations in SRD frequency bands in the market.
On the matter of micro FM transmitters, it was suggested to aim at R&TTE class 1 for this category of SRD’s.
Finally, it was noted that the revision of ERC REC 70-03 annex 7 had not led to submission of a deliverable to WG FM.
1.5. Report of ECC TG3 on UWB
ERO reported on the progress in ECC TG3, dealing with UWB. TG3 aims to develop a complete proposal for regulation of UWB in Europe by October 2005.
A draft ECC Decision was developed by ECC TG3 which provides a “reference general regulation” for UWB devices, recognizing that some specific regulation may be developed as appropriate in addition.
The meeting noted the progress made by TG3. Regarding the final regulatory text on UWB, the meeting felt uneasy on the eventual enforcement. It was questioned for example how to enforce the DAA mechanism as it would become mandatory as from 2010.
The meeting also felt uneasy when reading the proposed text under 'Decides' of the recommended draft DEC. The wording was felt not mature enough for definitive incorporation in a DEC. WGRA could have delivered added value if it was consulted in some stage of preparation of the draft DEC.
1.6. Report of JPT 2 GHz MSS
The WGRA Chairman presented the two reports from the JPT 2GHz MSS in Document (05)141 and (05)142, and the draft ECC Decision in Document FM(05)142 , which had been sent to WGRA from WGFM. These documents had been briefly considered in RA5. WGRA noted the documents and produced a liaison statement to WGFM and the JPT. In the liaison statement there is a comment on the described discrepancy or divergence in the national regulations applicable to authorisations of satellite transmissions and of the associated Complementary Ground Component. WGRA asked the JPT, if this situation is envisaged to continue after the adoption/implementation of the associated ECC Decision, or if the JPT sees a need or possibility for administrations to harmonise in this respect.
WGRA further agreed that since WGFM is scheduled to agree the draft ECC Decision for public consultation two weeks before the next WGRA meeting, RA5 will be tasked to follow the JPT MSS 2GHz work and liaise as necessary. A final regulatory judgement on the draft ECC Decisions can be discussed at the February 2006 WGRA meeting.
In addition, the WGRA chairman had discussed with the WGFM chairman the following practical arrangements for the draft Decision: In January 2006 WGFM could adopt the draft ECC Decision for public consultation. However, it would not go into public consultation until after the WGRA had adopted it, possibly making minor changes to the regulatory aspects of the Decision. In this way, the public consultation process for the draft ECC Decision would only start after the WGRA meeting in February 2006. This procedure was agreed by WGRA.
1.7. Report from PT7 meeting
The WGRA Chairman introduced document ECC PT7(05)33rev1 which contained the result of discussions about the future of WGRA. It proposes a more focused WGRA dealing with the general regulatory issues within the ECC family. The proposed terms of reference for the WGRA were given in an annex to the document.
The meeting noted the proposals. As the issue should be decided in the ECC, WGRA would not directly comment on the PT7 report. It was noted by a country that cooperation with TCAM ADCO should be included in the WGRA ToR.
It was further suggested that delegates would liaise with their colleagues participating in the ECC meeting.
1.8. Report from ECC PT8
A report was given of the last ECC PT8 meeting, 19-20 September. The aim had been to finalize the draft ECC report on “enhancing harmonization and introducing flexibility in the spectrum regulatory framework” and forward it to the ECC for adoption for public consultation in October.
Issues addressed in the report include the definitions of the concepts of harmonisation and flexibility and the analysis of their interrelation; ways of enhancing harmonization and flexibility at each level of frequency management (ITU, regional, national); scenarios and models for increasing flexibility; technical assumptions affecting spectrum management and new sharing approaches (e.g. cognitive radio, underlay services, new geographical and time sharing…).
WGRA noted the report.
2. MARITIME WORK ISSUES
2.1. Report of RA2
Document (05)143 containing the report of the last RA2 meeting was introduced. Issues addressed included a status update on the evaluation of the R&TTE Directive, the ongoing discussions in ECC PT7 regarding the future role of WGRA and of RA2, the need for extra frequencies for AIS, progress on activities within IMO and the CEPT participation and interest herein, the follow up work on the results of the survey on competences of GMDSS certified radio operators and the developments of the EMSA – Paris MoU campaign to assess further the situation with respect to this, the further work related to the review and broader CEPT harmonization on the required competences for SRC and LRC certification and of the underlying ERC Recommendations from 1994, the evaluation of the EU directive on seafarers, the issue of Class ‘D’ VHF radios being brought in to UK with US and Canadian channels programmed, the AIS time slot allocation, the implementation and the impact of the WEEE Directive, the use of scramblers by e.g. fishing vessels in relation to the efficient and effective use of the frequency spectrum and the development of a ‘SRC Satellite Operator’s Certificate’.
2.2. Draft ECC Report on maritime licensing
Document (05)144 containing the draft Report on maritime Licensing was introduced. At its February 2004 meeting, WGRA tasked RA2 to produce a Report on the arguments and reasoning behind maritime licensing. The draft Report is the 1st attempt to fulfil this request.
A brief presentation and summary of the content was introduced. It was mentioned that further work is still required and the WGRA participants was invited – already in this phase of the preparation process - to propose suggestions for amendments and for further completion of the draft Report.
The meeting noted the progress of work on the issue.
3. WORK ITEMS ON LICENSING & FREE CIRCULATION
3.1. Report of RA6
RA6 held one meeting in Helsinki from July 18-19 2005. The following issues had been discussed:
3.2. Describe how industry needs can best be served in the area of Free circulation and licence exemption, taking into account R&TTE and also policy towards non-CEPT countries.
The 11th meeting of ECC (agenda 5.4.6), requested that WGRA further analyze the needs of industry for free circulation. RA6 had been in charge of free circulation and expressed the view that industry and operators over the years had been very positive. On the other hand, the ECC had noted that only very few countries would need free circulation decisions, since most countries, also those not being in the EEA.
It was suggested to continue developing free circulation and use decisions emphasizing the use and the services to be offered by certain equipment.
The meeting decided that the WGRA document on free circulation that had been send to ECC (Document ECC(05)053 Annex 4) should be reviewed with the aim to further clarify this issue. A drafting group developed the text for the document.
3.3. Draft ECC Decision for GSM on aircraft
Document RA(05)132, the draft Decision on GSM on board airplanes was introduced. The work was done in parallel with the technical studies carried out by WGSE. It is becoming increasingly apparent that the SE7 compatibility report, which has been worked on with considerable diligence by SE7 during a number of meetings, will provide a range of situations in its results, and hence there will not be a single defined set of parameters to which the system can be defined according to this compatibility report. Furthermore, the outcome of the TCAM consultation requires the elaboration of harmonized standards applicable to the system on-board. That process will start with work via the European Telecommunications Standardisation Institution (ETSI).
The question was raised whether the document should be forwarded to ECC even though the WGSE Report was not ready yet and could therefore not be consulted by the delegates. Some delegates found it premature to forward the document to ECC as the WGSE Report seems to be delayed. It was decided to finalize the document and submit it to ECC at the October meeting as this was what they had requested WGRA to do.
A number of administrations reserved their position as they felt that some technical and legal questions were still open.
It was indicated that the current draft decision was incomplete as it was missing technical information from WGSE. This technical information should consist in the regulated interface, for the GSM On Board System –included the NCU-, as stated in article 4.1 of the R&TTE directive.
3.4. Liaison statement to WGFM and SE on Pseudolites
WGSE sent a liaison statement to WGRA asking to study the regulatory aspects of Pseudolites. Possible applications of Pseudolites are child tracking systems, precision landing systems etc.
RA6 prepared a liaison statement (Document (05)133) with a list of possible regulatory issues to be treated. This statement was endorsed by WGRA and has been sent to WGFM and to WGSE.
It was decided that RA6 should follow the work of WGSE PT SE39 and consider the regulatory items during the process.
3.5. Liaison statement sent to PT8 on flex-bands
ECC PT8 asked WGRA to analyze the possible ways to license the flex bands concept. RA6 after initial consideration suggested that individual licences should contain a minimum set of conditions, mostly technical conditions needed to ensure protection of adjacent bands.
A liaison statement had been sent to ECC PT8 by the chairman RA6 as ECC PT8 had their meeting already before the meeting of WGRA.
3.6. Draft ECC Decision/Recommendation for GSM base stations on board vessels.
The meeting was informed that work on the draft Decision for GSM on board vessels will start at the next meeting of RA6.
4. EU MATTERS
4.1. Radio Spectrum Committee, TCAM
An oral summary was provided on the June 2005 TCAM meeting. He highlighted the following subjects:
- The R&TTE Directive will cover regulations on air traffic management (ATM) as from October 20th 2005. Problems will arise because harmonized regulations under the R&TTE Directive will not be ready in time.
- The GSM equipment on board aircrafts will probably fall under the R&TTE Directive.
- In the future, UWB devices could interfere in case many would be used. The EC would then mandate ETSI to amend the harmonized standard in order to manage the situation in case of such aggregated interference.
- It was questioned if passive RFID tags fall under the R&TTE Directive. Austria proposed tags to be declared class 1 since they only transmit under control of a reading device, but the meeting was not clear about this and most tags to this date were not CE marked. ADCO has been asked to take this issue up in their next meeting.
- The SRR class 1 radio interfaces (class 52 and 53) were briefly discussed and the EC will modify these, taken the comments received into account and present them for consolidation and subsequent written consultation.
5. WORK ITEMS CONCERNING SATELLITE ISSUES
5.1. Report from RA5
The WGRA chairman, in the absence of an RA5 chairman, presented Document (05)148, the report from the RA5 meeting held on 20.9.2005 which had been chaired by himself.
This RA5 meeting had in particular developed new versions of the draft ECC Decisions for LEST (see item 7.2) and HEST (item 7.3).
WGRA agreed with the suggestion from RA5 to leave reconsideration of the SIT, SUT and VSAT Decisions until about a year after the adoption of the LEST and HEST Decisions, so that administrations have had an opportunity to sign up to and implement the new Decisions to cover the 14 and 29 GHz transmit exclusive bands.
WGRA noted the continued support from the satellite industry to the concept of ECC Decisions for Free Circulation, as expressed to RA5.
Concerning the review of old Decisions relating to satellites, RA5 had proposed a way forward to have this work done in the coming months. The basic principles were supported, however WGRA agreed, in order to avoid misinterpretation, the following understanding of the procedure: “To save work during any RA5 meetings in the period up to March 2006, the associated operators should be asked by RA5 to contribute to drafting new (generalised) Decisions to take account of these developments, including the criteria for keeping ECC Decisions.”
5.2. and 5.3. Draft Decision on Low EIRP satellite terminals (LEST) and Draft Dec. on exemption of SITs, SUTs, VSATs with eirp above 34 dBW (=High eirp satellite terminals, HEST)for approval by WGRA for public consultation
On request of WGRA two satellite ECC decisions on HEST (Document (05)145) and LEST (Document (05)146) were considered by RA11 and RA5. In order to avoid a conflict with the R&TTE directive the meeting agreed to modify the appropriate considering as follows: that the LEST shall comply with the R&TTE Directive and its Article 3(2) which may be demonstrated by compliance with harmonised standard EN 301 459 or EN 301 428 or equivalent technical specifications.
WG RA improved and finally agreed both ECC Decisions for public consultation.
5.4. Appointment of new RA5 Chairman.
During the WGRA meeting the UK administration submitted a candidature for the chairmanship of RA5. The WGRA chairman announced this information to the meeting. WGRA noted the candidature with gratitude, and it was agreed that the working group had hereby appointed a new RA5 chairman.
6. MATTERS CONCERNING FEES AND CHARGES
6.1. Report of RA8
Document (05)129 which was the report of the last RA8 meeting was introduced. The main objectives of the meeting had been to discuss responses to the questionnaire on licence exemption and draft a first report, as well as to produce a questionnaire on the issue of fees for broadcasting and fees for non-commercial and passive services. Further, discussions took place during the meeting on developments within Administrations.
6.2. Draft report on Licence exemption
ERO made a presentation highlighting the main issues addressed in the draft report on licence exemption. The draft report covered in particular the current status of licence exemption for specific services, future plan for further exemption, consequences of exemption on the revenues of the administration, impact on its tasks and activities, benefits of licence exemption and views on “commons”.
6.3. Questionnaire on fees for broadcasting, non-commercial and passive services
The questionnaire in Document (05)128rev1 was introduced. In discussion clarification was sought on the rationale for carrying out such an investigation. The work item had been discussed and added to the WGRA work programme in 2004. At that time administrations expressed an interest in finding out what was being done in the area of fees for broadcasting and fees for non-commercial and passive services in CEPT. The outcome of the work should serve that purpose. One administration provided further explanation on their interest in such a report. One country questioned whether work relating to broadcasting fees was within the scope of the RA8 ToR as accepted by the ECC. After checking the WGRA report to the Sorrento ECC meeting, it was concluded that the ECC had been informed about that work item.
7.1. Report of RA11
Document (05)137 was introduced, which was the report of the last RA11 meeting Issues discussed included plans for a new market surveillance campaign on SRDs, desktop market surveillance, and placing on the market of FM broadcast transmitters
7.2. Definition of integral antenna
It was mentioned the misinterpretation of definition of the integral antenna on PMR 446 devices (Document (05)138). RA11 discovered different definitions of integral antenna in ETSI standards EN 300 296-1, 300 086-1, EN300 113-1 and 301 166-1. In order to clarify the situation for industry and CEPT administrations, RA11 agreed to send a letter to ETSI ERM-RM for advice, if from a technical point of view an integral antenna fitted externally to the equipment is in compliance with the R&TTE Directive for every definition of integral antenna within ETSI Standards. The discussion in ETSI on this issue had started but could not be concluded yet.
7.3. Draft ECC Report on GSM Mobile Phone Interceptors. Results of the public consultation.
Objections to the public consultation on the draft report on GSM Mobile Phone Interceptors had been received from France and from Sweden. The meeting discussed the status of this report. It was suggested to publish it in the WGRA document area on the ERO website as a WGRA internal document. However, this could not be accepted since the content of the document was not supported by three countries. In order to resolve the issue, the RA11 chairman was invited to discuss the status and contents of the report with the delegates from two countries on the basis of their respective contributions in the first phase of the public consultation process.
7.4. Questionnaire on Benchmarking on enforcement
The meeting was informed that RA11 finalized the questionnaire on benchmarking. This had been sent to all official contact persons of the national administrations (Document (05)139). The questionnaire has recently been sent to the CEPT administrations.
7.5. SRR 24 GHz enforcement difficulties
The meeting was informed that RA11 has prepared a document on guidance for a common approach to a harmonized enforcement for 24 GHz SRR. RA11 raised the question on whether, if equipment would be sold separately as after sales product, it should be compliant with the R&TTE Directive or with the Automotive Directive. A further question was raised concerning the use of the safeguard procedure which comes into affect for this equipment after the date of July 2013. As a consequence, the status of the present standard for this equipment after the cut off date becomes unclear. The moment in time when the maximum penetration rate or the cut-off date is reached could result in enforcement problems in several countries. For example, the efficiency of the reporting system on the number of registered vehicles equipped with 24 GHz SRR devices is doubtful. RA11 concluded that the interim solution is not clearly covered in the scope of Commission Decision ´2005/50/EC. Therefore a decision of the EC is required, although RA11 is aware that the EC is actually working on an amendment to the Automotive Directive. This amendment aims to quantify the number of vehicles with 24 GHz SRR equipment registered in each country and to prohibit their placing on the market after 30 June 2013 at the latest. During the course of meeting the draft guidance was improved and forwarded to ADCO/R&TTE for comments.
The Chairman thanked the RA11 Chairman and the participants for all their hard work.
8. RADIO AMATEURS
8.1. Updates of Amateur matters
ERO informed the meeting that ERO had received an application from New Zealand to participate in T/R 61-02 as presented in Document (05)134. Documents (05)134 Annex 1 and (05)134 Annex 2 provided further explanation on the New Zealand amateur licensing regime and examination syllabus.
A small group of amateur radio experts was convened to review the application documents. The group concluded that the New Zealand examination syllabus was fully compatible with the HAREC and recommended accepting New Zealand's participation.
WGRA therefore agreed that a consultation with CEPT administrations should be launched by ERO, in accordance with procedures, with the recommendation to accept the participation of New Zealand in T/R 61-02. Results of the consultation will be presented at the February 2006 meeting.
An update of the implementation status of T/R 61-01 and T/R 61-02 was given in Document (05)135. ERO underlined that implementation data from 2003 had been re-inserted into the table for all CEPT administrations that had not provided any update following the revision of T/R 61-01, as agreed at the Brijuni meeting. The meeting was thanked for allowing these changes which had cleared the uncertainties that had emerged after the revision of T/R 61-01.
A brief update was given on the Thai application. The request for further information sent by ERO in October 2004 remained unanswered. ERO had been advised to write to the Thai Ministry of Foreign Affairs. After a letter was sent by ERO in July 2005, the Thai regulator was asked by the Ministry of Foreign Affairs to consider the issue, which would hopefully lead to some progress.
8.2. ECC Report on radio amateur entry level license for public consultation
The Report on entry level licenses had been stopped from going into public consultation due to a veto by one administration and two administrations sent input documents with proposals concerning the entry level licenses. In particular the structure of the entry and novice license was felt to be unclear. It was also commented that the first level requirements should be more relaxed.
One administration underlined that, in general, the radio amateur licensing regime should be as simple as possible in order to reduce the burden and associated costs to administrations. That administration recalled that their national radio amateur licensing regime consisted of only one license level and that this was considered as sufficient. Nevertheless, in order not to prevent WGRA from processing in its work related to radio amateurs, this administration would not oppose to the proposed draft Recommendations for the CEPT novice and entry level radio amateur license.
8.3. Draft Rec. on CEPT novice radio amateur licence for final adoption
Provided the document on entry level license will be revised, the meeting could adopt the draft ECC Recommendation (05)06, the CEPT novice radio amateur licence.
The meeting was informed that one country currently have legal difficulties in implementing radio-amateur Recommendations and that therefore would not be able to implement the new Recommendations currently in draft versions.
8.4. Revision of ERC Report 32 for final adoption
Taking the results of the previous discussions into account, the meeting could now approve ECC Report 32, the amateur radio novice examination syllabus and amateur radio novice examination certificate within CEPT and non-CEPT countries.
9. IMPLEMENTATION OF ECC DECISIONS
9.1. Implementation of ECC Decisions
Document (05)117 that showed the progress with implementation of WGRA Related ECC/ERC Decisions, was introduced.
ERO then introduced Document (05)118, containing charts relating to the implementation of Satellite Decisions.
10. REVIEW OF ECC DECISIONS
10.1. List of relevant ECC Decisions
Document (05)123 was introduced. This document gave an overview of the WGRA Decisions to be reviewed for the criteria which WGRA selected from the list defined by the ECC. ERO had completed the table of criteria to the extent possible. The meeting decided to request project team RA5 to review the satellite related decisions and request RA 6 to review the remaining decisions, taking the following into account:
- liaison with RA11 for enforcement aspects if any.
- the list of R&TTE class 1 equipment.
- in general the discussions on free circulation in WG RA including considering to change the term free circulation into harmonized use.
It was noted that the decision ERC/DEC(98)23 on ERMES receivers should be abrogated since the corresponding decision on the designation of the ERMES frequency band had been withdrawn by ECC. The document was completed with information on the responsible project team.
11. RA WORK PROGRAMME & SCHEDULE
11.1. RA Work Programme
The meeting reviewed the WGRA work program and amended it as necessary.
11.2. Alignment of WGRA work programme as required
See the above.
12. ANY OTHER BUSINESS
12.1. Vice Chairmanship vacancy
Candidates are still invited from administrations.
13. MINUTES OF 6th MEETING
The draft minutes were agreed.
14. DATE AND PLACE OF NEXT MEETING
WGRA will meet in Luxemburg, 6-10 February 2006 and from 24-28 April (venue to be decided).