Ofcom BRIG: RED's implications
Written by: Sam Fenwick | Published:
Ofcom’s Vaughan John (pictured) was appointed head of business radio in July, as Paul Jarvis has become head of technical systems at Ofcom’s Baldock Radio Station. John retains responsibility for PMSE and TV White Space

The latest Ofcom BRIG meeting, which took place on 28 July, touched on many different issues: spectrum licensing and enforcement, LTE in UHF, Brexit, a light licence survey and the Radio Equipment Directive. Sam Fenwick brings you the highlights

Sidiqur Rahman, spectrum assignment and co-ordination team manager at Ofcom, started the meeting, saying the new customer records management system has gone live internally. “We’re going to go live with the web portal for ships and amateur licences in the next few days. You’ll be able to view your licences, make changes to them and to contact details and pay for [them].” Rahman says Business Radio light licences will be in the next phase. Once they have been migrated to the online portal, “you’ll be able to instantly apply for all the light licences and get them issued at the same time”. It will also allow users to see all their licences including technically assigned, but it won’t be possible to apply for the latter via the portal. This next phase “should be live by the end of this year, with the final release for the technically assigned licences next year”.

FM54: LTE and GSM-R
Kuha Sithamparanathan, spectrum policy manager – emergency services and FM54 chairman, gave an update on the project team’s recent work. As part of its work to improve the use of PMR and systems in the 400 MHz range, FM54 has asked ETSI to support it in creating better spectrum management mechanisms. Sithamparanathan says Nigel Wilson, chair of ETSI TGDMR, has said it’s a case of clarifying what FM54 is seeking to achieve; FM54 will be working during its meeting in September to specify what it wants from ETSI in more detail.

“France has publicly stated they are intending to introduce a 2 x 3 MHz type LTE system for PPDR in the 400 MHz range. As such, they are keen to find other spectrum to house future PMR systems... They have asked to look at bands such as the 2.6 GHz and the 3.4-3.6 GHz for PMR or broadband PMR... It will be interesting to see where this goes. If it’s in those bands, it feels to me like mobile, so do we really need to call it PMR?” he asks. Nick Woollard, senior project engineer at the Joint Radio Company (JRC), says: “The mobile industry is trying to redefine everything. They think by calling 200kHz narrowband that it’s narrowband. They were gobsmacked when I referred to broadband as a 1.25 MHz CDMA system – ‘oh, that’s not broadband’ – well, it was a year ago. We have to be careful. ‘Let’s call 2.6 and 3.4 GHz PMR’? Well, then suddenly mobile becomes PMR.”

Kevin Delaney, spectrum policy and planning manager at Ofcom, responded, saying: “There’s been no indication from the mobile operators that they’re interested in spectrum below 470 MHz for mobile. ECC Recommendation T/R 25-08, Planning criteria and coordination of frequencies for land mobile systems in the range 29.7-470 MHz, provides details on coordination between narrowband and broadband systems, so if France does roll out broadband in the 400 MHz band we would look to T/R 25-08 to agree coordination thresholds.

Malika Greene, spectrum policy manager at Ofcom, added that Recommendation T/R 25-08 includes narrowband to broadband co- ordination, but not broadband to broadband. “There are conditions for if France rolls out LTE and we have narrowband here, we know how to work what the threshold values are and then we’ll have to take a step further in terms of having some sort of bilateral agreement with France.”

Vaughan John, who has replaced Paul Jarvis as Ofcom’s head of business radio, encouraged the Business Radio community to participate in CEPT meetings. “You can register with these groups and then receive the documents, you can provide contributions; it’s always beneficial if you can be part of the decision- making process. We’ve seen the benefit of getting the PMSE industry more engaged in CEPT.”

Sithamparanathan says FM54 also covers GSM-R and has focused on the coexistence issues surrounding its use in large hub stations. Now that ECC Report 229 has given recommendations on how to deal with this, FM54’s focus has shifted to collecting information on how these measures are working in practice.

He adds that while some countries are starting to enable systems to use that band to support GSM-R activities, “there are lots of other [CEPT] administrations who would like to see this band used more for [licence- exempt] short-range devices (SRDs),” as the GSM-R take-up has been very poor. The band already caters for SRDs. The successor to GSM-R, MCS, might not be deployed until 2030, increasing the amount of time in which “this valuable spectrum is sitting fallow”.

Sithamparanathan says it’s the 400 MHz band’s propagation characteristics that make it so attractive to critical communications and PPDR, and its relatively large cell sizes mean less infrastructure has to be deployed while still enabling “fancy video apps” and broadband data. “If LTE spectrum is made available in this band, my opinion is there will be take-up. If you build it, they will come.”

One attendee said a lot of power companies are planning massive upgrades to their communications systems. He explained that while spending tens of millions on upgrading existing UHF scanning telemetry systems might seem the obvious choice, it doesn’t provide the throughput or the future- proofing needed to support smart grids, and narrowband LTE available in the 400 MHz band could solve a lot of these issues.

Keith Smale, branch director at 2CL, noted that many manufacturers produce radios that work well above 470 MHz and asked if there was any possibility in obtaining spectrum in these bands for areas where licences in the 400 MHz band are hard to come by.

“We now have a Dynamic Spectrum Access framework in place in the band 470 to 790 MHz for services to get access to the white spaces between TV broadcasts,” says John. “There is a requirement for these services to protect TV reception and PMSE use, but PMSE use is generally temporary in nature and tends to be focused in urban areas, so for something like monitoring remote locations, TV white space could be an option.”

“You’d gain opportunistic access to spectrum above 470 MHz, if they did decide to make All Creatures Great and Small outside your power station and use all the spectrum for wireless microphones, you’d have to move to a different channel. There is scope to do that but not on an allocated basis...”

Jarvis, now head of technical systems at Ofcom’s Baldock Radio Station, says: “One of the difficulties is Ofcom doesn’t seem to know what [the utilities’] coherent strategy is.... For us to make a sensible decision around how the spectrum should be used, we need a coherent

requirement... If it turns out the industry thinks LTE can bring all these things together and deliver it, that’s quite a strong case for making spectrum available on a private LTE- type arrangement. Whether we have spectrum is another question we’d have to then answer.”

Sithamparanathan says this is why Ofcom is having the UHF review now. “It’s about working out what is best for UK plc and not being tied to what’s already there.”

Tim Cull, head of business radio at FCS, raised his concerns about the introduction of LTE into UHF. “The concern is not to introduce something that will wreck systems that are already in place or spoil other opportunities in a way that is overall destructive... LTE... is an aggressive technology... and it does require large side bands at high data rates for guard band purposes.”

He adds that the industry does not have access to a “mission-critical reasonable data rate solution”, instead only having a best- effort one in which clients use MNOs for some data services.

“We’re seeing more and more dissatisfaction with that kind of solution because many users want high resilience for some of their data communications,” Cull says. He suggests a dual-band approach might be the best solution.

Cull has his doubts about the use of mission-critical data services in TV white spaces due to the guard band issue and the tenure of the link. Returning to the potential impact of LTE in UHF, he says: “What it isn’t is ‘take an LTE system, drop it into the UHF2 band and do a Pontius Pilate and walk away’. France are going to clear the band and that’s a very different story. We don’t have that option and we won’t for decades. In the UK you’d have to be completely insane to do that without control. That’s a big problem for the Business Radio [industry] because we need to supply the customer demand for better data services than they can get from someone else.”

Iain Sharratt, director at CarTel Communications, asked about the impact of Brexit on regulation and whether it could lead to France introducing LTE in the UHF without consultation about interference on the south coast.

Jarvis replied: “The physics doesn’t change if we’re in the EU or not. Even if existing directives are dissolved, in virtually all cases we’ll have to have something equivalent in place... We would want to know whether there is a benefit from the mass-market opportunities of keeping a ‘use the same’, or is it more beneficial to be different? That’s exactly what we do at the moment... it’s just that it won’t have European directives in the framework, it will be something else... I don’t think we need worry that it’s all going to be a big free-for-fall. In time there will be equivalent control documents.”

JRC’s Woollard says: “If you propose a system that may cause interference to your neighbour, you have to notify [the ITU]; that will still apply regardless of whether we’re in or out of the EU. If we want to sell equipment within the EU we must meet what the directives are.”

The future of spectrum enforcement"
Jarvis says Ofcom is currently doing a mobile broadband survey and will report back on how the different MNOs perform. “We’ve got several of our field engineers and some of our Baldock staff moving around the country, mainly in cities but also along railway lines with a purpose-built back-pack which has four handsets in it. Each one on a major operator’s network, and those handsets constantly make voice and data calls and send texts. There’s [also] software that’s doing quality assessments of the traffic.” The survey will continue to late autumn.

He then gave an update on the Baldock monitoring station. Ofcom has a pilot system it developed in-house that constantly compares what it is monitoring with what Ofcom’s licensing database is saying what should be there, and this is being refined as “it isn’t quite perfect”.

Jarvis adds Ofcom is also developing a much cheaper monitoring system: a Raspberry Pi computer that controls two “relatively cheap” receivers – a ALR (wide-band) scanning receiver and a broadcast band and Band 3 receiver that can decode RDS and text. Field engineers will be issued with at least one of these to better detect intermittent interference and pirate transmissions. Each system takes just over a day and around £500 to build in-house.

“We’ve got four drones at the moment which we can use to do site surveys in particularly difficult locations. We’re about halfway through a project where we’re trying to validate the broadcast propagation tools... we’re doing quite a lot of flying around the Building Research Establishment’s (BRE) property where they have 30, 40, different houses so we can [determine] the effects of difficult build, [etc.], and the drones are beginning to get more and more work.”

Light licence survey
Delaney then went through the results of a light licence survey; 64 per cent of respondents use licence-exempt spectrum (458.5-459.5 MHz) to meet a business requirement.

When asked why they use radio communications, the top answer was the “ability to get a call or message through” (58 per cent), followed by health and safety requirements (49 per cent); 41 per cent use analogue, compared with 17 per cent using digital; 49 per cent are not planning to migrate to digital equipment within the next five years; 80 per cent don’t expect the number of channels they use to increase.

One perplexing find was 46 per cent saying their network availability requirement is always on, when “they’re using a light licence where the chances are they don’t know who else is using the same frequency in their area”. Delaney notes this result might be due to the paging sector.

Erika Forsberg, senior policy advisor at Ofcom, says the UHF Strategic Review consultation is still scheduled for this autumn and encouraged respondents to focus on their anticipated requirements for 10 years’ time. John adds that “because we want to... come up with a strategic view for the next 10 years [for UHF]”, Ofcom won’t consider the ad hoc requests it has received for some of the spectrum that will soon be released by the emergency services, “until we fully understand what we can do to support the industry over that longer period of time”.

Ofcom’s light licence survey shed a great deal of light on this growing sector

The Radio Equipment Directive
Craig Scott, senior spectrum technology analyst, and Andrew Cutting, spectrum enforcement policy adviser, at Ofcom discussed the implications of the Radio Equipment Directive, which came into force on 13 June. On 13 June 2017, manufacturers will no longer be able to place equipment onto the European market under the R&TTE.

Cull stressed the importance of enforcement to FCS members, as they include the larger companies that tend to comply and incur all the costs associated with compliance. “Unfortunately the level of enforcement in this country... means it’s relatively safe to ignore all these rules, [so] the people doing the right thing are trading at a considerable disadvantage... The choice is either [enforcement] increases or we forget [getting] the whole thing to level the playing field.”

Cutting says that all the answers Ofcom can provide at this stage are under the caveat of there not being regulations as RED has yet to be transposed into UK law. He notes the transposition deadline was 13 June 2016 and that if the regulations are a direct copy of RED then installers will need to sign a form saying the installation still meets RED’s requirements. He adds there will be a commission guide to RED produced in September. Another attendee praised an Ofcom webpage that contains advice on R&TTE, and Cutting says it will be updated for RED once the regulations have arrived.

There was some discussion about whether installations containing legacy equipment might be affected by the RED, such as when old components need to be replaced.

Cull says: “If you’ve got an active product and it’s working in conjunction with another active product and one of them breaks and you don’t replace it with an exact equivalent, you enter into a grey zone. This is frequently the case when they no longer make a replacement... If you have to check it and one of the components is legacy equipment, 20-30 years old and it can’t meet the new regulations, you could be talking about a major swap-out instead of a little thing.”

One attendee said when the R&TTE directive came in, many fixed-links operators were worried if they had to replace a link it had to be with new equipment... It was agreed by Ofcom that you can’t put any new links in using your old equipment, but if any of your old links go wrong, but if you’ve equipment that you’ve uninstalled you can use that old equipment to replace faulty old equipment... that was a good compromise.”

Smale notes that if the repairs were done professionally with the right spare parts, no-one would know, while stressing that he wasn’t advocating breaching the regulations.

Cutting says: “As a manufacturer, you can place on the market under R&TTE or RED; after June 2017, it has to be only RED, so the Commission has given industry a year to get rid of old stock.” Scott added that fixed installations are not covered by the RED but “putting into service” could be if it is... “the first use of radio equipment in the Union by its end-user” (see http://ec.europa.eu/DocsRoom/ documents/18027 for details).

Smale notes that “there’s a lot of manufacturers who are heavily discounting equipment, because it’s either that or they’re going to have to put it back through RED”.

Smale requested an update to MPT1368, the code of practice for the inspection of a Land Mobile Radio system, which was last updated in 1998, because “there are always those who brush it to one side and say ‘Oh, we’re a huge company, Ofcom won’t bother us’”.

Cutting says that Ofcom is calling for the industry to put forward revisions to MPT1368. Cull notes there is some confusion about “when and at what stage items are placed on the market”, adding: “One of the big differences between the R&TTE and RED is that under the RED, if the text remains the same in the UK as the directive... every transaction through an economic operator is an economic action undertaken by the operator, who will be required to take on the obligations for conformity for that action.”Cull argues ‘placing on the market’ “is the point at which the final stage in the distribution scheme offloads into onto the end use, because the economic operators in the latter parts of the value chain are no longer economic operators for the purposes of the directive because it’s already been placed on the market and therefore has passed out of scope of the directive... When things are placed on the market it has to be towards the end [of the chain] – the opposite end to [that specified by] the R&TTE directive. This is something that is going to make a big, big impact to industry.”

Richard Russell, business development manager and product specialist – EMEA at Motorola Solutions, says his company puts a lot of effort and money into ensuring compliance “as a solution” and tests for it using the most complicated combinations of equipment.

Cull adds: “Most FCS members would like a much faster turnaround between a customer saying ‘I can find a product at a fraction of the cost’ and that customer being stopped from doing that by some mechanism because the level playing scale would only act in a five-year time scale and they [FCS members] would suffer significant commercial damage in the interim...”

He notes the dangers caused by people supplying ATEX equipment with the wrong, but significantly cheaper, batteries; both in terms of risk to the user, as it could be they rely on their ATEX radio to call for back-up, and the resulting damage to the radio manufacturer’s brand. “It would be really nice to have some recourse to the purchasing operator who saved on batteries by putting the wrong one in.”

Cutting says Ofcom is “undertaking a project” to educate the industry about RED because, as part of the regulator’s proportionate approach, “we would like to ensure everyone knows what their responsibilities are”.

“There are a number of large manufacturers, electronic suppliers, out there and a lot of their products are non-compliant, and we’ll be looking to take them to task under RED and trying to educate them before June next year.”

Russell says: “I’ve been trying to educate our channel partners about the value of compliant solutions for four years. Some take it on board. Some know full well Ofcom won’t do anything about it... What would make people stop and reflect on their business practices would be an example of [enforcement] that is relevant to the business radio industry.”

Cull explains if an end-user buys equipment under the R&TTE and installs it when the RED is in effect, there is no issue as the equipment was compliant with the regulations at the time of the transaction. Scott agrees but notes that if anyone were to install products, put them into service and sell on the site or installation, that would be different.

Scott says that ETSI is updating the Harmonised Standards as those from the R&TTE are not fit for purpose under the RED, mainly because they don’t include receiver parameters... Of the 200+ Harmonised Standards, Scotts says that around 180 will be probably be ready for 13 June 2017. He also said new Harmonised Standards may be needed as the RED explicitly includes, receivers and radiodetermination (ie GNSS). While standards have to be cited in the official journal of the EU, before they are officially harmonised standards, “a final draft that can be taken to a notified body with your product, that can sometimes be good enough to get a positive opinion.”

Clearly with RED yet to be transposed in UK law, there are no firm conclusions, but it’s clear manufacturers, distributors and end-users all need to pay attention to its potential implications.

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