i spoke to our Radio expert, Chris Parry, who used to be secretary of the ETSI RES09 committee, about Richard's summary of the EU/CEPT/RTTE radio and frequency harmonization issues. I attach his comments on Richard's email, which I found to be educational.
Chris Raymont BABT Product Service Ltd email: [email protected] >I still don't know what is necessary and sufficient to create a >harmonized frequency band under the R&TTE Directive. The RTTE is about product conformity for the EU member states (which are a subset of the CEPT membership). It is not about frequency harmonisation. The Directive will not result in unification of frequency bands throughout Europe, because of national frequency planning legacies and non-harmonised military allocations. >For European harmonization of a frequency band it always >previously needed an ERC Decision... It still will. >adopted by the EC members of CEPT/ERC... No, the frequency allocation is adopted only by those administrations that signed up to that particular ERC decision. >The Decision was, in effect, an instruction to the CEPT/ERC >member Countries to put the content of the Decision into National >Law and to create appropriate National Standards. Only partly correct. National standards are NOT always required. >A Recommendation was used when a Decision would be difficult to >implement or they wanted to "try out a Decision". No. Recommendations are used as "agreements in principle" and have a much higher status than Richard implies. For example, CEPT/ERC/REC 70-03 sets out the agreed policy for short range radio devices throughout the CEPT countries. A Decision would be inappropriate, because of the fluidity of frequency allocation in individual territories. >There was friction caused after the creation of ETSI because >CEPT/ERC believed that ETSI was encroaching into the CEPT/ERC mandate. Yes, but this was fixed in BC-T-319, where ERC participated alongside ETSI and CENELEC to work out how Harmonized Standards should be constructed, and how they should be used. It covered all the various cases of applicable or non-applicable ERC Decisions and Recommendations. >In order to solve the conflict, CEPT/ERC and ETSI set up a >"Memorandum of Understanding" and they worked closer together. Yes, but that just identified the problem. It was the later BC-T-319 document ETR 238 (available from the ETSI website) that fixed it in an agreed way. >CEPT/ERC Administrations were ETSI Members anyway...... They can be, and many are. Others choose not to be ETSI members. >More recently the Decisions have been worded so as to provide the formal adoption of EU >Standards with instructions as to how they should be used (frequencies/levels etc) when it is >not specifically defined in the Standard. Yes. This all under Terry Jeacock, the ERC chairman of those working parties that produce these types of ERC Decisions. >The ETSI standards changed also: ETS (and IETS) Standards became >EN (and, I guess, ENV) Standards adopted by National Weighted Voting. Yes, the I-ETSs became ETSs as they became mature, but some remain I-ETSs to this day, for example the popular and long-running I-ETS 300 219. The change to EN came about in response to the Standardization Mandate placed on ETSI by the European Commission, to produce Harmonized Standards under the EMC Directive 89/336/EEC. The RES09 EMC standard each have a special annex linking them to the functional (ie used for National Type Approval) standards. Thus the EMC standards have to become ENs, but so do the related functional ETSs where application for the first time, becomes MANDATORY under a Directive. The ETS documents are of course, voluntary standards, and many will stay that way. All of them in fact, except those related to the RES09 EMC Standards or required by other EC Standardization Mandates. ENVs are just draft ENs with a defined life before adoption as full ENs or abandonment. >The National Radio Agencies have a strong input into the Vote >(in a lot of cases, controlling the response). Yes. But subject to operator and industry pressure. >EN Standards are the European Standards which form the basis for >harmonization (although they do not cause the harmonization... No, this is the wrong way round! >To be a harmonized Standard they must be published in the Official >Journal of the EU and be associated with a Directive. Almost. They must have been produced under an EC Standardization Mandate relating to that Directive, by the Standardization organization who accepted that Mandate. HSs are not just vaguely "associated" with a Directive in the OJEC. > It looks as if CEPT has suspended the creation of some Decisions... Yes. Terry Jeacock is a sensible man and doesn't want to waste his time until the RTTE dust has settled, so he can see what product-related standardization will de facto occur in industry. >CEPT/ERC Decisions may well have become redundant. I do not think so since the ERC as part of CEPT (itself part of ITU) is responsible for frequency co-ordination. They are waiting for clarification of the EG 201 399 process (which is taking place in the ETSI OCG TG6 committee) to see how the RTTE Harmonized Standards may be used as vehicles for future ERC Decisions. >The ETSI EN Standards will be "associated" with the R&TTE Directive >as some already are with the EMC Directive. The RES09 Harmonized Standards were produced under the EC Standardization Mandate in the same way that future HSs will be produced under the RTTE Standardization Mandate. The related functional standards under the EMC Directive are not "associated", they are fully referenced by means of special annexes to form part of the EMC Harmonized Standards. The situation will change for the RTTE HSs because the lesson has been learned that whet is required is COMPLETE standards, so the functional content will be added to the EMC content (and any related safety content) into documents applicable to entire product families. For example, there will be one RTTE HS for PMR, and another for cordless phones etc, as follows: The RTTE PMR HS will cover all relevant performance aspects of analogue PMR with all types of squelch and trunking, voice and/or data, whether of analogue and/or digital technology such as TETRA and TETRAPOL. The RTTE cordless phone HS will cover basestations and user terminals for NMT, GSM, DCS, DECT, CT2 etc Each core RTTE Harmonized Standard will be supported by individual annexes for each subgroup. All much simpler and concise than before. >Unfortunately the R&TTE Directive is... unclear in the detail of harmonized bands. Yes. Because it is deliberately designed not to address that issue. >The CEPT/ERC Recommendation 70-03 does clarify the situation >further and we are hoping that this will be sufficient to show harmonization. Yes, it does do this job, because that is the job is was designed to do. >It has no legal standing, however, on its own (but then neither >will a Decision after April 2000). I am not so sure about this, for example we may well see ERC Decisions referenced in the Licensing conditions for radio products.
