Charlie,this comment is not the same note as published now under RTTE 
harmonized section and it did not require testing under 1.8.1 as current Note 
does. it merely mentioned harmonized ways are been developed in draft 1.8.1. 
1.8.1 goes in effect in 2 years, requirement for testing according to 1.8.1 
goes in effect immediately. I'm not sure how anyone can justify this makes any 
sense and seems like going against the spirit of RTTE and any other EU 
Directives, allowing grace period for any requirement to take place. Simple 
mentioning of something been developed does not substitute a legal 
recruitment.Mark

From: char...@sulisconsultants.com
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
Date: Tue, 27 Nov 2012 11:36:26 +0000









There has been a comment in the OJ regarding requirement for spectrum sharing 
since December 2009:
 
This version of the standard gives presumption of conformity with the 
requirements of Article 3(2) of Directive 1999/5/EC under the following 
condition: The equipment shall implement an adequate
 spectrum sharing mechanism, e.g. LBT (Listen Before Talk), DAA (Detect And 
Avoid), etc., in order to comply with the requirement specified in clause 4.3.5 
of this version. Such a mechanism shall facilitate sharing between the various 
technologies and applications
 which currently exist and in case of congestion, users will be ensured equal 
access (and as a consequence a graceful degradation of service to all users). 
Harmonised ways for assessing the efficiency of various sharing mechanisms are 
currently been developed
 by ETSI in draft EN 300328 version 1.8.1.
 
V1.8.1 has brought in some additional requirements, but the draft standard has 
been around for years and the published standard added to the OJ with a 26 
month transition period.
 
Regards
Charlie
 
 
-----Original Message-----

From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 

Sent: 27 November 2012 08:42

To: EMC-PSTC@LISTSERV.IEEE.ORG

Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
 
In message <snt108-w48a92b45f82f55a03910b9ad...@phx.gbl>, dated Mon, 26 Nov 
2012, Mark Gandler <markgand...@hotmail.com>
 writes:
 
>Bill,being struggling with the same question. 1.8.1 goes in effect only

>on 1.1.2015, but current 1.7.1 should be used with an adaptivity

>requirement from 1.8.1.It is very unusual circumstances where the

>requirement is pretty much "dropped" out of nowhere and looks like goes

>in effect immediately.Our test lab posted this question to an alleged

>author of the below note and his answer was "yes, it applies and must

>be tested". not sure how it all makes sense to etsi authors and RTTE

>committee. what about currently shipping equipment which been evaluated

>to 1.7.1 version, but before adaptivity note been posted?
 
It is indeed very unusual for a provision to come into effect without a 
transition period, and is normally not allowed. If it is allowed, there must be 
a safety or other over-riding issue to justify it and it must be explained 
publicly
 (at least according to many Directives).
 
Were manufacturer experts on the relevant ETSI standards committee unaware of 
this unusual development?
--
OOO - Own Opinions Only. See 
www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it 
proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
 
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