Here is one person's opinion on the frequency harmonization situation in
Europe. If his understanding is correct, I still don't know what is
necessary and sufficient to create a harmonized frequency band under the
R&TTE Directive. Comments?
Confusing, isn't it.................. The R&TTE Directive
has made a fundamental change in the way the EU deals with Radio. The
problem is that we know what we've changed from.. but not what we've changed
to....................................
OK here's my impression of life the universe and everything.
For European harmonization of a frequency band it always
previously needed an ERC Decision adopted by the EC members of CEPT/ERC
(CEPT/ERC being bigger than the EU). 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. A
Recommendation was used when a Decision would be difficult to implement or
they wanted to "try out a Decision". The presence, or not, of EU Standards
was irrelevant to the process.
It is important to understand that CEPT/ERC is a joint
committee(s) of National Radio Regulators designed to provide a common view
across Europe. It predates the EU and has a wider membership. There was
friction caused after the creation of ETSI because CEPT/ERC believed that
ETSI was encroaching into the CEPT/ERC mandate. This was true and became
more true as ETSI Standards were implemented by many Countries (including
CEPT/ERC Members outside the EU!). In order to solve the conflict, CEPT/ERC
and ETSI set up a "Memorandum of Understanding" and they worked closer
together. CEPT/ERC Administrations were ETSI Members anyway...... (Members
not Controllers)
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. In this way the Decision changed its function a little, as
it no longer required the creation of a National Standard. The ETSI
Standards changed also: ETS (and IETS) Standards became EN (and, I guess,
ENV) Standards adopted by National Weighted Voting, as before. The National
Radio Agencies have a strong input into the Vote (in a lot of cases,
controlling the response). EN Standards are the European Standards which
form the basis for harmonization (although they do not cause the
harmonization themselves). To be a harmonized Standard they must be
published in the Official Journal of the EU and be associated with a
Directive.
Now life has changed....... It looks as if CEPT has
suspended the creation of some Decisions now that the R&TTE Directive
exists, although it is continuing with its Recommendations. Unfortunately,
CEPT is as unsure as we are about how the future looks with the R&TTE
Directive. Their role has become unclear. Within the EU a CEPT Decision
cannot provide the legal instrument for National Requirements as this
function has been taken by the EU Directive. CEPT/ERC Decisions may well
have become redundant, although even CEPT/ERC is unclear about this (I
think). The ETSI EN Standards will be "associated" with the R&TTE Directive
as some already are with the EMC Directive. Unfortunately the R&TTE
Directive is a "New Approach Directive" (which leaves most of the detail up
to the Standards) but is unclear in the detail of harmonized bands. In most
cases it is clear as the radio systems are operating on common frequencies
anyway. Short Range Devices is less clear as there are only a few bands
which are "common".
The CEPT/ERC Recommendation 70-03 does clarify the situation
further and we are hoping that this will be sufficient to show
harmonization. It has no legal standing, however, on its own (but then
neither will a Decision after April 2000).
Clear as mud....
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