Hello,
I think you're possibly correct, but I also see that happening regularly with the attempts to squeeze more users into the finite amount of spectrum. A long time ago now, the decision was made that "effective use of spectrum" in the EU RED would mean that all radios have receiver performance tests, and in many cases some additional 'spectrum sharing' (like the adaptivity we see in the WLAN standards, or low duty cycle requirements). It was then decided that part of the solution to this requirement was the addition of the receiver tests. This is one of the main reasons why a test report used as compliance for article 3.2 of the R&TTE Directive, is not sufficient for compliance against article 3.2 of the RE Directive. Simply, there are new test cases added for the RED, that did not exist under the R&TTED. The receiver tests. And FM radio receivers (and other broadcast receivers, such as television) are within scope of the RED. (They were specifically excluded from the R&TTED, but they are not excluded from the RED). A few years ago, the FCC made significant changes to their Part 90 rules in some frequency bands. 'Narrowbanding' was one of the terms used. They basically phased out the use of channels which are "wider than they need to be". For example, if you used a 25 kHz channel for a simple voice call which could be done in 6.25 kHz or 12.5 kHz, then you were no longer permitted to use the 25 kHz channel. It was phased out over a few years and now it's just not permitted. I think it's all part of looking at how people use the spectrum. You could say that this is an example of manufacturers being forced to use a modulation scheme which is most efficient. To quote (almost) the phrase which was used during the creation of the WLAN adaptivity tests.. Sharing of radio spectrum to all users. And in the case of conflict, a graceful degradation of all. You know we'd just get bored if these things didn't keep changing, right? Michael. Michael Derby Senior Regulatory Engineer Director ACB Europe Certification Resource for the Wireless Industry Web: www.acbcert.com <http://www.acbcert.com/> e-mail: [email protected] <mailto:[email protected]> Direct phone: (+1) 703 468 1746 (USA area code) Mobile phone: (+44) 7939 880829 (UK area code) From: John Woodgate [mailto:[email protected]] Sent: 19 September 2016 08:32 To: [email protected] Subject: Re: [PSES] FW: Testing to EN 55013 or EN 55032 Who decides if a given technology makes 'efficient use'? For example, simple AM could be disallowed because it's not as 'efficient use' as 16-OFDM. I am concerned because a certain novel technique may quite possibly be unusable in Europe because of this 'efficiency' provision. With best wishes DESIGN IT IN! OOO - Own Opinions Only <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England Sylvae in aeternum manent. From: Charlie Blackham [mailto:[email protected]] Sent: Monday, September 19, 2016 8:00 AM To: John Woodgate <[email protected] <mailto:[email protected]> >; [email protected] <mailto:[email protected]> Subject: RE: [PSES] FW: Testing to EN 55013 or EN 55032 I'm not sure whether or not you're being serious, but I'll bite - It's got nothing to do with "suppressing stuff" Excerpt the Directive "whereas" In order to ensure that radio equipment uses the radio spectrum effectively and supports the efficient use of radio spectrum, radio equipment should be constructed so that: in the case of a transmitter, when the transmitter is properly installed, maintained and used for its intended purpose it generates radio waves emissions that do not create harmful interference, while unwanted radio waves emissions generated by the transmitter (e.g. in adjacent channels) with a potential negative impact on the goals of radio spectrum policy should be limited to such a level that, according to the state of the art, harmful interference is avoided; and, in the case of a receiver, it has a level of performance that allows it to operate as intended and protects it against the risk of harmful interference, in particular from shared or adjacent channels, and, in so doing, supports improvements in the efficient use of shared or adjacent channels. One example, would be a TV viewer hoping that their TV might still work whilst they're sat 2m away accessing the internet using a 700 MHz band LTE mobile phone. This problem didn't exist in the 1990's when the R&TTE directive was written... Charlie From: John Woodgate [mailto:[email protected]] Sent: 18 September 2016 21:37 To: Charlie Blackham; [email protected] <mailto:[email protected]> Subject: RE: [PSES] FW: Testing to EN 55013 or EN 55032 As I said, nodded through. This 'efficient use' provision is carte blanche for suppression of anything the government doesn't like. With best wishes DESIGN IT IN! OOO - Own Opinions Only <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England Sylvae in aeternum manent. From: Charlie Blackham [mailto:[email protected]] Sent: Sunday, September 18, 2016 9:04 PM To: John Woodgate <[email protected] <mailto:[email protected]> >; [email protected] <mailto:[email protected]> Subject: RE: [PSES] FW: Testing to EN 55013 or EN 55032 John Receiver Sensitivity is an Article 3.2 RF Spectrum matter and not an EMC matter. Article 3.2 of the R&TTE Directive requires: radio equipment shall be so constructed that it effectively uses the spectrum allocated to terrestrial/ space radio communication and orbital resources so as to avoid harmful interference. Article 3.2 of the Radio Equipment Directive has an additional requirement in that it requires: Radio equipment shall be so constructed that it both effectively uses and supports the efficient use of radio spectrum in order to avoid harmful interference. Article 3.2 Harmonised Standards are effective mandatory as any manufacturer not wishing to apply them in full must obtain a Notified Body opinion and the Notified Body should really consider Harmonised Standards where they have been published. Regards Charlie From: John Woodgate [mailto:[email protected]] Sent: 18 September 2016 20:45 To: Charlie Blackham; [email protected] <mailto:[email protected]> Subject: RE: [PSES] FW: Testing to EN 55013 or EN 55032 The draft specifies receiver sensitivity, which is surely not an EMC matter and severely restricts manufacturers' freedom of design and offering of a range of products at different prices. It could even be challenged as a restraint of trade. But I expect it will be nodded through. With best wishes DESIGN IT IN! OOO - Own Opinions Only <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England Sylvae in aeternum manent. From: Charlie Blackham [mailto:[email protected]] Sent: Sunday, September 18, 2016 8:01 PM To: [email protected] <mailto:[email protected]> Subject: Re: [PSES] FW: Testing to EN 55013 or EN 55032 David The other thing to add is that this is within scope of the Radio Equipment Directive, which must be applied from 13th June 2017, so you may wish to look at the receiver performance requirements in Draft ETSI EN 303 345 V1.1.1 <http://www.etsi.org/deliver/etsi_en%5C303300_303399%5C303345%5C01.01.01_20% 5Cen_303345v010101a.pdf> Regards Charlie From: John Woodgate [mailto:[email protected]] Sent: 18 September 2016 08:58 To: [email protected] <mailto:[email protected]> Subject: Re: [PSES] FW: Testing to EN 55013 or EN 55032 EN 55032 is the successor of EN 55013, but 55013 is still valid at present, so you could use either, But if the product will continue in production for a year or two at least, it would be sensible to apply 55032, and EN 55035 rather than EN 55020 for immunity. With best wishes DESIGN IT IN! OOO - Own Opinions Only <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England Sylvae in aeternum manent. From: itl-emc user group [mailto:[email protected]] Sent: Sunday, September 18, 2016 8:31 AM To: [email protected] <mailto:[email protected]> Subject: [PSES] FW: Testing to EN 55013 or EN 55032 Hi Would an FM receiver used in a motorcycle helmet be subject to testing under EN 55013 or EN 55032? Thanks in advance for any opinions. Regards, David Shidlowsky | Technical Reviewer Address 1 Bat-Sheva St. LOD 7120101 Israel Tel 972-8-9186113 Fax 972-8-9153101 Mail : <mailto:[email protected]> [email protected]/[email protected] <mailto:[email protected]> /[email protected] Web <http://www.itl.co.il/> www.itl.co.il <http://app.sqm.co.il/SitePages/Questionnaire.aspx> Fill out Customer Satisfaction Survey Global Certifications You Can Trust This e-mail message may contain privileged or confidential information. 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