Introduction to GPR equipment standards and user's licensing

For many small enterprises there is a mystique regarding the regulations which govern the sale and use of GPR/WPR in many countries throughout the world.

In the European Union (EU) the use of GPR/WPR is  controlled by directives issued by the European Commission (EC) and the Government/National radio administrations, who control the use of GPR/WPR by setting conditions for use through their licensing regulations. Directives are legal instruments used by the EC to regulate/ harmonise and create a more open market in the European Union (EU). The Radio and Telecommunications Terminal Equipment (R&TTE) directive 1999/5/EC applies to GPR/WPR equipment. This directive is known as a new approach directive, which unlike the older type of directives allows self declaration to demonstrate conformity to the essential requirements, which are set out in article 3 of this directive (see GPR equipment standards). Demonstration of compliance to this directive is a legal requirement, which then allows the manufacturer or his authorised representative to place the product on the market for sale. This ruling applies to manufacturers/suppliers both within the EU or external to the EU.

Although the R&TTE directive allows the product to be placed on the market for sale, it does not automatically allow use of the equipment, and a national licence is often required before the equipment can be used (see licensing rules).

In other parts of the world there are many differing approaches, ranging from very formal technical approval and licensing conditions to no specific rules. For example in the USA self declaration is used to demonstrate compliance to the FCC regulations, and in Canada a similar approach is also used for compliance with the DOT regulations.

It is also interesting to note that many other countries around the world accept the technical requirements set out in the Standards produced by the European Telecommunications Standards Institute (ETSI)

Please find below a list of frequently asked questions

1. Why does GPR require regulation?

All types of electrical and electronic equipment sold within European Union countries are subject to regulation. The general principle is that if essential operation requires movement of electrons then the equipment is regulated.

2. Which Regulations should GPR meet?

Different arguments may be advanced concerning, which regulations should apply to GPR. In Europe, RSCOM, a high level committee of the European Commission decides such issues. Their decision was that GPR should conform to the Radio and Telecommunications Terminal Equipment (R&TTE) Directive. This is consistent with prior decisions made by individual Radio Administrations and with the FCC in the USA.

Following this decision they initiated work through the European Telecommunications Standards Institute (ETSI) to establish standards for manufacturers to meet, and work through the European Conference of Postal and Telecommunications Administrations (CEPT) for the requirements to be placed upon users.

The present regulatory position is the result of the negotiations undertaken by EuroGPR in these forums. Although there are now both ETSI standards and a CEPT ECC decision for GPR, RSCOM itself has yet to endorse the latter to turn it into an EC decision, something EuroGPR is lobbying for.

The regulations placed upon manufacturers and users while substantially separate should not be read in isolation. GPR use is approved only for trained professionals, and part of this requirement assumes that users should be aware of all the regulations.

Both manufacturers and users should note that both the R&TTE Directive and associated regulations might apply to them. Other applicable regulation may include the Low Voltage and WEE Directives. If a vehicle or other machinery is involved there are likely to be others.

3. How may a manufacturer show compliance with Directives?

 A manufacturer shows compliance with all relevant directives by CE marking the product; other markings may be required.

4. How does a manufacturer demonstrate compliance with the R&TTE Directive?

The major requirements for the manufacturer are article 3.1a of the Directive covering safety, article 3.1b covering EMC and article 3.2 covering radio matters.

There are many ways that a manufacturer can demonstrate compliance with the directive, but often the simplest way is to demonstrate compliance by using harmonised standards. The major bonus of such conformity is that the resulting demonstration of compliance is accepted in all European Union countries and in many of the other countries subscribing to ETSI, around 40 countries in all.

The harmonised generic safety standard is a CENELEC document EN60950.

For radio matters there are ETSI standards that apply to GPR's and WPR's operating in the frequency range from 30MHz to 12.4GHz. Two standards apply one related to the radio emissions from the antenna and housing of the equipment and the other to the non radio ports of the equipment known as the EMC requirements. Both are in multiple parts.

5. Which ETSI Documents apply?

ETSI EN 302 066-1 and 2 are the ETSI standards that apply to the radio emissions. Part 1 details the “Technical Characteristics and Test Methods” while Part 2 is entitled “Harmonized EN covering essential requirements of article 3.2 of the R&TTE Directive”. Part 1 details all the relevant radio requirements, the test methods and the maximum allowed levels of radiation. Part 2 is more of a legal rather than technical document and details the other requirements associated with meeting the R&TTE Directive.

ETSI EN 301 489-1 and 32 are the ETSI standards which apply to the EMC requirements necessary to demonstrate conformity to article 3.1b of the R&TTE Directive. Part 1 and part 32 of the EMC standard must be used together The technical description and methods of measurement for the EMC tests to be applied are detailed in Part 1 and the specific test conditions applicable to GPR are set out in part 32 ,together with any special requirements.

6. How can I get access to the relevant documents?

Join EuroGPR. EuroGPR was largely responsible for drafting the documents and negotiating their passage through the tortuous route to approval as EU law. Subsequently EuroGPR has become a member of ETSI. Members may obtain access to the documents directly through the website.

7. What do manufacturers need to do to place equipment on the market?

It is a general principle that before placing equipment on the market in a European country, the manufacturer should notify the Radio Administration in that country. Harmonised ETSI standards imply that the target countries should accept equipment compliance made in different countries, with the system backed by the European Commission.

There is an electronic system of Europe wide notification. Details are available from the EuroGPR Secretary.

8. If equipment is approved for sale may users simply use it?

No. In principle all operators should comply with the requirements of CEPT ECC Decision ECC/DEC/(06)08. This should establish a licencing regime for professional users within Europe. Given the very wide bandwidth and usual operating frequency bands for GPR, it is only approved for use by professional trained operators. GPR cannot be sold in the local do-it-yourself store. There are systems that may be sold to the general public but they operate with much lower powers in higher frequency bands that are of little relevance to most GPR users.

In principle the CEPT decision requires the Radio Administrations in all European Countries to establish a national licence for GPR. In practice few have, or plan to.

In practice the only country that has implemented a licence, so far, is the UK. OFCOM issue three year licences to organisations to operate GPRs generally in line with the ETSI specifications. The licence is not completely aligned with the ETSI documents. OFCOM recognise this as an anomaly that they intend to eliminate by bringing the UK system into alignment.

A Europe wide GPR licence would be ideal but at present this is not possible because national Radio Administrations retain control over licencing as they see it as a means of raising revenue, for TV broadcasting and other services.

9. Will the situation change?

Some countries indicate that they are unlikely to introduce a licencing system, but their Radio Administrations acknowledge the existence of GPR and accept that generally it is being used professionally.

EuroGPR continues to press for wider adoption of the licensing approach and an RSCOM EC Decision because there are some countries where there is no official acknowledgement of the technology, creating potential problems for manufacturers and users alike.

10. Are their special requirements that users should observe?

Yes. Radio Administrations are particularly concerned that GPR may interfere with a number of vulnerable radio systems including those on aircraft, defence systems, prison systems and radio astronomy. ETSI document ETSI EG 202 730 “Code of Practice in respect of the control, use and application of Ground Probing Radar(GPR) and Wall Probing Radar (WPR) systems and equipment” details the concerns and the precautions users should observe.

In the UK OFCOM took the view that airfields, defence establishments and prisons, all types of site detailed in the code, should be able to control what is happening in their environs and ignored them in the UK licence. They concluded that radio astronomy sites, the remaining type, required special protection and instituted a 7km radius coordination distance around six such sites. Permission to operate in these circles should be sought in advance. Generally permission will be given but there may be restrictions on operating times to link in with scheduled radio astronomy measurements.

11. How may users be suitably trained?

EuroGPR is developing a series of training courses for professional staff. The first step before the equipment should be switched on is to recognise the requirements of the ETSI Code of Practice. The courses then progressively lead on developing progressively higher skill levels.

12. What about frequencies below 30MHz?

The radio spectrum is administered in three major bands with a division at 30MHz. The EuroGPR negotiations were only concerned with the spectrum above 30MHz. To obtain a similar arrangement below 30MHz would have required a similar extended negotiation with little chance of success because of the increased military interest in the lower band. Given that much of the negotiations were carried out on a voluntary basis supported by members on behalf of EuroGPR and their own organisations, this could not be justified.

In the absence of established standards, the old route to obtain permission for use, prior to ETSI coming into existence, is still available and should be used. This requires negotiation on a case-by-case basis with the Radio Administrations of the target country where use is required.

13. May equipment be modified?

Equipment should never be modified by users because this invalidates all approvals provided by the manufacturer and renders the user liable to all the penalties that apply to the unauthorised use of equipment; confiscation and destruction, a fine and even imprisonment.

Equipment should always be operated in accordance with the manufacturers handbook. If an external test house is used for approval the handbook is a necessary requirement of Type Approval.