ERMTGSRR(17)029001

Title*: / Collection comments EU on ENs
from Source*: / WG/TG Chairman
Contact: / Michael Mahler
input forCommittee*: / ERM TGSRR
ContributionFor*: / Decision
Discussion / X
Information
Submission date*: / 2017-08-30
Meeting & Allocation: / ERMTGSRR#29-
Relevant WI(s), or deliverable(s):

ABSTRACT:Formless collection of comments received from EU desk officer on ENs

  1. General Feedback on 302 288 and 302 264 assessments

Points shall be taken for all ENs.

Mail from 28th of August 2017

Together with the comments/remarks above, I trust you and the drafters to carefully verify the following in the next version of these standards:

  • The equipment is in the scope of the RED.
  • The standard does not contain text that goes beyond Article 3 of the RED, which is the basis of the Standardization Request. For example, no requirements on the CE marking of equipment.
  • All relevant Commission Decisions and EU laws are respected.
  • Equipment can be operated in at least one Member State.
  • References shall not link to non-publicly available documents and should be the most updated versions. This should also apply to “chains of references”.
  • Harmonised Standards should represent the state of the art. Particular care needs to be taken to references to superseded versions and other related documents to ensure that the new version does not loosen the recognised state of the art. This also applies to “chains of references”.
  • No generic references to standards if the user has to do him/herself the link to the clauses.
  • If there are major changes in the requirements and/or removal of clauses in the annex A of previous standards, these are thoroughly explained (Article 5 of the Standardization Request, or in case you can send me a few lines).
  • Annex A is correct.
  • The Vademecum for Standardization is respected.
  • Care should be taken to minimise “chains” of Normative references as in the Vademecum for Standardization.
  • The tx/rx parameters are present, complete, well-defined and clear.
  • The test method is appropriate and measurement uncertainties are sound.
  1. TG SRR prepared two risk assessment on points raised on 302 288 and 302 264

Link to doc 302 288

Link to doc 302 264

  1. Discussion and Situation until TG SRR#27
  1. ERMTGSRR(17)027001_Agenda_TG_SRR_27.docx including the last received table from EC
  2. ERMTGSRR(17)027002_signal_interferer_handling_concept_analysis.pptx
  3. ERMTGSRR(17)027003_RX-requirements_signal_interferer_concept.docx

Excerpt from Agenda#27

Table from EU desk officer

EN 301 091-1 v2.1.1
(main issues: missing receiver parameters, worsening of previous clauses, unclear statements or requirements) /
  • In clause 4.3.1.3 it is not clear how this band is measured (-1dBc, -40dBc, -100dBc?).
  • Clause 4.3.1.4 worsens of a factor 100 the measurement uncertainty of the previous version of this standard (v1.3.3 of 2006).
  • Can the authors please explain why they limit on purpose the maximum time for averaging the mean power in Table 2, as this requirement was not present in the previous version of this standard (v1.3.3 of 2006)? In this way, the tx power measurements according to Table 3 are distorted. The requirements in v1.3.2 are, on the contrary, consistent.
  • The requirements in Table 5 in bands 790 MHz to 862 MHz worsens of 18dB Table 5 of the previous version of this standard (v1.3.3 of 2006).
  • Clause 4.4.2.3 worsens clause 8.1.3 of the previous version of this standard (v1.3.3 of 2006). This applies to both the first entry of Table 6 and the entire table 7, which has no correspondence in v1.3.3
  • Clause 4.4.3.2 has general requirements. Has the user to establish him/herself how to apply this clause (which gives presumption of conformity)?
  • There is no receiver sensitivity in clause 4.4.4. Please note that receiver parameters are a precise legal requirement.
  • In the same clause, I would expect that the receiver requirements for Doppler radars, imaging radars or detection radars are well defined. Please note that receiver parameters are a legal requirement.
  • As a radar, there is no noise figure, which is another key receiver parameter of radars. Please note that receiver parameters are a precise legal requirement.
  • The signal interfering handling is evaluated only on the central frequency, accounting for approximately 0.0001% of the total bandwidth.

EN 301 091-2 v2.1.1
(main issues: missing receiver parameters, worsening of previous clauses, unclear statements or requirements) /
  • In radars, the wanted performance, as for instance the detectable RCS or the range, is a function, amongst other, of the receiver parameters. It may then be considered whether this clause provides information on the presumption of conformity and, as such, to be referred to in the Annex A.
  • Why are the scanning/fixed parameters of the antennas not defined in clause 4.2.3? For instance, the definition of the main/sidelobes of the antennas or its scan rate (where applicable) can provide requirements for the reduction of interference to devices in the surrounding area. It may then be considered whether this clause provides information on the presumption of conformity and, as such, to be referred to in the Annex A.
  • In clause 4.3.1.3 it is not clear how this band is measured (-1dBc, -40dBc, -100dBc?).
  • Clause 4.3.1.4 worsens of a factor 100 the RF measurement uncertainty of the previous version of this standard (v1.3.2 of 2006).
  • Can the authors please explain why they limit on purpose the maximum time for averaging the mean power in Table 2, as this requirement was not present in the previous version of this standard (v1.3.2 of 2006)? In this way, the tx power measurements according to Table 3 are distorted. The requirements in v1.3.2 are, on the contrary, consistent.
  • The requirements in Table 5 in bands 790 MHz to 862 MHz worsens of 18dB Table 5 of the previous version of this standard (v1.3.3 of 2006).
  • Clause 4.4.2.3 worsens clause 8.1.3 of the previous version of this standard (v1.3.3 of 2006). This applies to both the first entry of Table 6 and the entire table 7, which has no correspondence in v1.3.2.
  • Clause 4.4.3.2 has general requirements. Has the user to establish him/herself how to apply this clause (which gives presumption of conformity)?
  • There is no receiver sensitivity in clause 4.4.4. Please note that receiver parameters are a precise legal requirement.
  • In the same clause, I would expect that the receiver requirements for Doppler radars, imaging radars or detection radars are well defined. Please note that receiver parameters are a precise legal requirement.
  • As a radar, there is no noise figure, which is another key receiver parameter of radars. Please note that receiver parameters are a precise legal requirement.
  • The signal interfering handling is evaluated only on the central frequency, accounting for approximately 0.0001% of the total bandwidth.

EN 301 091-3 v1.1.1
(main issues: missing receiver parameters, worsening of previous clauses, unclear statements or requirements) /
  • In clause 4.3.1.3 it is not clear how this band has to be measured/defined (-1dBc, -40dBc, -100dBc?).
  • Clause 4.3.1.4 worsens of a factor 100 the measurement uncertainty of EN 301 091-1 v1.3.3 (of 2006).
  • Tables 2 and 3 have less requirements and worsen Tables 1 and 2 of EN 301 091-1 v1.3.3. In particular, summing 10 log(D) is an advantage to declared reduced power. In the old standard the peak power was considered in the formula as a fairer form of compensation for summing 10 log(D). In this standard it has been removed. In this way, the tx power measurements according to Table 3 are distorted. The requirements in v1.3.3 are, on the contrary, consistent.
  • The requirements in Table 5 in bands 790 MHz to 862 MHz worsens of 18dB Table 5 of EN 301 091-1 v1.3.3 and they are not in line with the CEPT/ERC/REC 74-01. In addition, I cannot read in [i.3] requirements on the quasi-peak detector type, which is usually less stringent than the peak detector.
  • Clause 4.4.2.3 worsens clause 8.1.3 of EN 301 091-1 v1.3.3 (e.g. erp vs eirp, 25 MHz vs 30 MHz). In addition, I cannot read in [i.3] requirements on the quasi-peak detector type, which is usually less stringent than the peak detector.
  • There is no receiver sensitivity in clause 4.4.4. Please note that receiver parameters are a precise legal requirement.
  • In the same (or some other) clause, I would expect that the receiver requirements for Doppler radars, imaging radars or detection radars are well defined. Please note that receiver parameters are a legal requirement.
  • Receiver blocking is also missing. Please note that receiver parameters are a legal requirement.
  • As a radar, there is no noise figure, which is another basic key receiver parameter of radars. Please note that receiver parameters are a legal requirement.
  • The signal interfering handling is evaluated only on the central frequency, accounting for approximately 0.0001% of the total bandwidth.

EN 302 858 v2.1.1
(main issues: missing receiver parameters, worsening of previous clauses, unclear statements or requirements) /
  • Changes occurred in the definition of far field distance in Section 3.1 and additional tolerances were introduced as in clause 5.3.2.3 in EN 303 396 v1.1.1.
  • The statement "All operating bandwidths of the equipment (see clause 4.3.1) shall be declared by the equipment manufacturer (see clause 4.2 of ETSI EN 303 396 [1])" in clause 4.2.1 clashes with Article 10(8) of the RED.
  • In clause 4.3.4.3, table 6, the parameters for measurement in table 8 of EN 302 858-1 v1.3.1 were removed.
  • In the same table, the quasi-peak detector is used, whilst the peak would be more accurate. Can the authors please clarify?
  • The requirements in 4.6.1.4, referring to Table 2 of 303 396 v1.1.1, worsen the requirements of Table 9 of EN 302 858-1 v1.3.1 and it is not in line with the referenced TR 100 028-2 v1.4.1.

EN 303 360 v1.1.1 /
  • In clause 4.3.1.3 it is not clear how this band has to be measured/defined (-1dBc, -40dBc, -100dBc?).
  • Clause 4.3.1.4 worsens of a factor 100 the measurement uncertainty of EN 301 091-1 v1.3.3 (of 2006).
  • The requirements in Table 3 in bands 790 MHz to 862 MHz worsens of 18dB Table 5 of EN 301 091-1 v1.3.3 and they are not in line with the CEPT/ERC/REC 74-01. In addition, I cannot read in [i.3] requirements on the quasi-peak detector type, which is usually less stringent than the peak detector.
  • Clause 4.4.2.3 worsens clause 8.1.3 of EN 301 091-1 v1.3.3 (e.g. erp vs eirp, 25 MHz vs 30 MHz). In addition, I cannot read in [i.3] requirements on the quasi-peak detector type, which is usually less stringent than the peak detector.
  • There is no receiver sensitivity in clause 4.4.4. Please note that receiver parameters are a precise legal requirement.
  • Receiver blocking is also missing. Please note that receiver parameters are a legal requirement.
  • As a radar, there is no noise figure, which is another basic key receiver parameter of radars. Please note that receiver parameters are a legal requirement.

  1. Summary from Michael Mahler on a call with EC desk officer including notes on the points (17.5.2017)

Mail was distributed via TG SRR reflector

PFS will block all EN under TG SRR.

He requested to rework all.  but to solve his rx-points we need TS because we cannot do it without on justification. And we cannot do it within 1 year completely.

But it could be that Holger could add some more because he has had some correspondence on this points.

But his general statement:

-He cannot trust ETSI because in the past ETSI created a NWI -- > EN was published closed the WI again.

-And revisions take too long, he expected the work within 1 year

I will show his view/points on his comments on 301 091-1 (as one examples) but is for all

My proposal to list the current versions of the EN and prepare a TS (to justify his points) was not accepted, because the legal department has different view.

EN 301 091-1 v2.1.1
(main issues: missing receiver parameters, worsening of previous clauses, unclear statements or requirements) /
  • In clause 4.3.1.3 it is not clear how this band is measured (-1dBc, -40dBc, -100dBc?).
Note Mahler: I explained that 99% rule is equal to -23dBc and will clarify this in a future revision. But as it is in now is correct. Hope he understood and this point shall be clear at the end. But we have to editorial correct it. We did it in other EN, like in TG28 -_> we learned out of this point.
  • Clause 4.3.1.4 worsens of a factor 100 the measurement uncertainty of the previous version of this standard (v1.3.3 of 2006).
Note Mahler: I told him that we have to evaluate because the value he revered to was for low ranges and I told him we can do it.
  • Can the authors please explain why they limit on purpose the maximum time for averaging the mean power in Table 2, as this requirement was not present in the previous version of this standard (v1.3.3 of 2006)? In this way, the tx power measurements according to Table 3 are distorted. The requirements in v1.3.2 are, on the contrary, consistent.
The problem here was: in the past we mixed in one table mean, peak and radar which has had a scanning function. In the new version we separated all this requirements and corrected the related tables. The tables cannot be compared anymore. And in the past the table has had some errors in and therefor if you compare an old/wrong with new/correct. But if you thing that the old was correct than the new is wrong. I explained and hopefully he understood that the new is now the correct solution.
  • The requirements in Table 5 in bands 790 MHz to 862 MHz worsens of 18dB Table 5 of the previous version of this standard (v1.3.3 of 2006).
Note: same: regulation (will) be changed à because 74-01 will be revised and therefore we have a new regulation which (will) be more relaxed. From my understanding in future we shall only take changes in the regulation into account if they are more stringent!
  • Clause 4.4.2.3 worsens clause 8.1.3 of the previous version of this standard (v1.3.3 of 2006). This applies to both the first entry of Table 6 and the entire table 7, which has no correspondence in v1.3.3
The point here is: in the past we measured the Rx spurious from 25MHz now from 30MHz à but in 74-01 is requested from 30MHz. But such devices there will be no re-spurious test because there is no rx only mode. But if I think the requirements in the EN is correct. I also explained that we add a second table:
Limit for narrowband spurious and one for wideband spurious. He didn`t understand because on limit (for wideband spurious) is more relaxed. I told him he shall have a look to the measurement BW à narrowband spurious will be measured with 100kHZ, the wideband with 1MHz. Limits in the table are therefore correct
  • Clause 4.4.3.2 has general requirements. Has the user to establish him/herself how to apply this clause (which gives presumption of conformity)?
Now we are at the point: new rx-concept. He is not accepting this new concept. His view: he would like to see the traditional ones (e.g. sensitivity, noise, blocking,..). And based on that this is a radar: the group shall be able to specify.
Currently his view: no rx-requirement in the EN.
I mentioned:
Radars are high integrated and no way to get this info à but this was no accepted.
And regulation is very generic à lot of use-cases à this would lead to different limits for one requirement --> based on the use – cases –More than one rx-requirement in one EN à this shall be not a problem. ????
I mentioned that our test “signal” interferer is an indirect way to measure Blocking, Sensitivity,..
But this was not accepted
And I mentioned we have rx-requirements in (new concept) in the past there was nothing. à it is an improvement
But as above: the new concept is not an rx-requirement
In addition I mentioned the upcoming STF à no influence in his decision/view
At the end he requested:
We have to evaluate the traditional rx-requirement and we have to add them to the EN (independent if it makes sense or not)
Or we can show that the interfere signal handling concept could be compared with this traditional rx-requirements (action of the new STF).
And if we can show that the signal interfere concept is usable à the interfere signals for the test must reflect the “real” life. The interferer scenarios we need to specify more in detail.
Additional comments from his side.
  • There is no receiver sensitivity in clause 4.4.4. Please note that receiver parameters are a precise legal requirement.
  • In the same clause, I would expect that the receiver requirements for Doppler radars, imaging radars or detection radars are well defined. Please note that receiver parameters are a legal requirement.
  • As a radar, there is no noise figure, which is another key receiver parameter of radars. Please note that receiver parameters are a precise legal requirement.
  • The signal interfering handling is evaluated only on the central frequency, accounting for approximately 0.0001% of the total bandwidth.

  1. Mail from desk officer on “signal interferer handling (24.04.2017)
  1. First mail correspondence beginning April 2017

Answer (final) Mail on 301 091-1

Answer (final) Mail on 301 091-2

ETSI internal discussion / start

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