EuroGPR's role in GPR radio licensing and standards

The operators of all type of equipment have the responsibility to ensure that they comply with all relevant legislation. For equipments potentially radiating electromagnetic signals radio licensing and electromagnetic compatibility (EMC) are important. GPR falls into this category but the pulsed nature of the signals employed does not fit any established structure for radio licensing structure. In principle GPR operation in Europe has, and will continue to be unlawful in many countries, until new regulations negotiated by EuroGPR come into effect, anticipated to be at the end of 2005.

In the UK matters came to a head some time ago with Radiocommunications Agency, now Ofcom staff, threatening to seize and destroy equipments, and prosecute users, their managers, directors or Vice Chancellors, as appropriate. Penalties include imprisonment. Fortunately commonsense prevailed and EuroGPR was able to negotiate a way through the situation. The process began with many radars being made available for measurement at the Whyteleafe Laboratories. The results provided some reassurance and a waiver was granted allowing EuroGPR members to continue using equipments generally of the type measured providing that they were used in accordance with EuroGPR’s Code of Practice, that a log was kept of the date, place and time of use and that EuroGPR sought to negotiate effective licensing regulations for GPR.

This waiver was granted only to EuroGPR members; generally all other GPR use is unlawful. Operation is allowed under experimental licenses, but not for commercial purposes, and these are negotiated for one specified location only.

The Code of Practice addresses concerns that GPR systems may be used irresponsibly and cause interference to aircraft, defence and security systems. This remains a concern of licensing authorities and all members are expected to adhere to the Code at all times.

Members are required to keep a log of GPR use; this should include the type of equipment, the geographical location and the date and time of use. The objective is to identify any GPRs that may be in the vicinity of major interference events to aid in finding the source. The first full year of member’s logs was collated and submitted. The data is of a commercially sensitive nature and was integrated independently. EuroGPR retains an independent database person for this purpose. The data was distributed to the licensing authority’s regional offices and correlated with a similar data base of interference events. There was no correlation. For one major interference event at an airport, suspicion had fallen on GPR but detailed investigation based on the log exonerated it and went some way to alleviating concerns.

The third condition of the waiver was that EuroGPR negotiate a longer term licensing regime. Initially this was carried out for the UK, but although national authorities retain some powers, this now has to be done at a European level with the European Telecommunications Standards Institute (ETSI). Their regulations apply to more than forty countries including the twenty five of the European Union, and they are the dominant licensing body in Region 2 of the World, Europe and Africa.

Radio communication has to be coordinated across national borders and the top level body for developing actions is the World Administrative Radio Conference (WARC). It considers the world in three regions, Region 1 The Americas, Region 2 Europe and Africa, Region 3 Asia and the Pacific. Region 1 is dominated by the USA’s FCC licensing body and has taken a different approach to the radio licensing of GPR. There are signs that Region 3 may follow the route set by EuroGPR in the ETSI regulations.

Negotiations with ETSI take time because the documentation is widely circulated for comment to all national radio administrations worldwide but they are now reaching a satisfactory conclusion.

For administrative purposes the radio spectrum is considered in different bands, for GPR the committee structure addressing the frequency range from 30MHz to 12.4GHz is relevant. Below 30MHz, around the world communications becomes feasible, and the bands are considered to be of national and strategic interest; it is unlikely that a generally applicable license for GPR would be granted. GPR users wishing to operate any equipment in which the -10dB lower frequency band limit is below 30MHz must negotiate directly on an individual basis with the relevant national authorities for authorisation for use.

The ETSI regulations negotiated apply for radars operating in the band 30MHz to 12.4GHz.

The difficulty of licensing GPR has been that unlike most radio services that operate in a narrow frequency band and may simply be allocated a narrow frequency assignment GPR radiates a fast rise time pulse. When this is considered in the frequency domain, it spans a large bandwidth already occupied by many different types of radio services. GPR is an Ultra-Wide Bandwidth (UWB) system and no such services had previously been licensed.

In parallel with the EuroGPR negotiations some large companies (Motorola, Intel, Sony) have been negotiating to use UWB communications between computer systems within the office environment. This both delayed and in the end enabled conclusion of the GPR negotiation. The large companies had the resources to implement extensive modelling of various interference scenarios. These models enabled a clear distinction to be drawn between GPR with a projected, for modelling purposes, market penetration of 2 units/sq km and 10,000 units/sq km for the communications systems. The GPR systems are used intermittently as opposed to the communications systems which are operated continuously. The GPR systems are mobile so if interference does occur to a fixed installation it is short lived. By being able to indicate these differences, EuroGPR was able to draw a clear distinction between the two types of system and succeed in negotiating the highest emission levels allowed for GPR to still be treated as a low power device. Operation as a high power device would have been opposed by a number of administrations. By contrast the FCC regulations do not make this distinction and in the USA GPR regulations are much more restrictive as GPR is treated as if it were the computer communication system.

Following negotiations GPR documents were approved by ETSI and issued for public consultation. A number of minor comments were made and a resolution meeting was held in May 2005. The National Vote by the ETSI member countries has taken place and the new documents were approved with no countries voting against the regulations and only two abstaining.

After details of the documents and vote are published in the Official Journal of the European Union manufacturers will have the right to sell equipments meeting the ETSI specifications in countries that are ETSI members. This does not imply that users will have the right to use the equipment in those countries, this is still under national control but coordinated through CEPT. The difference arises because it is recognised that it would be a severe restriction of trade if manufacturers had to make products for specific countries, but access and licensing regimes are different in various countries.

Notification by manufacturers should be given to the national licensing authorities in each country of their intention to offer products for sale. The national authorities still have the right to decide the licensing regime for the users. This is analogous to the issue of television licences in the UK; every household must have one but this does not affect the manufacturer. Some ETSI documents recommend a “light” national licensing regime for GPR. The German authorities have indicated that a general licence will be issued. This will essentially be one piece of paper held by the national authority with details of models on sale in the country.

EuroGPR members throughout Europe should strongly encourage their national authorities to pursue the German licensing model, and inform the association of developments so that information may be coordinated.

EuroGPR is continuing to negotiate the licensing regime for users through CEPT; these negotiations have only acquired an urgency with the administrators since the ETSI documents were approved in the summer of 2005. IT should be noted that the licensing negotiations may impose further restrictions on the use, or the design of equipments.

In the new regime the responsibility for the radio licensing of equipment is placed upon the manufacturer and anyone carrying out any modifications to that equipment, but there are still responsibilities upon the user. Use has only been granted for professional users complying with the EuroGPR Code of Practice. Use which breaks this code will still be unlawful and may attract the full penalties.

It is not clear what will happen to so called “heritage systems”, or systems in use prior to the new regime; different national authorities will take various views. The UK situation is no different in this regard but past performance with a wide range of radio systems suggests that those systems operating under the EuroGPR waiver may be allowed to continue, while those systems that always were unlawful, will remain so, and continue to risk the full penalties.

The new regulations bring a new maturity to GPR, but some authorities remain concerned about interference issues particularly to aircraft, and it is essential that users behave responsibly if further progress is to be made. This sensitivity regarding aircraft may be seen in that the documents refer to Ground- and Wall-Probing radar. The use of the word penetrating implied that the radiation came out the other side of the wall and set regulatory alarm bells ringing. A third class of operation was defined Through Wall Probing Radar but this is specifically not covered by the ETSI regulations. Such operation is attractive for security operations but must at present be licensed via military regulations rather than the commercial applications covered by ETSI.

There are a number of ETSI documents relevant to GPR. Reference should always be made to the latest version; they will be draft until finally issued.

ETSI Technical Report ETSI TR 302 994-2, Electromagnetic compatibility and Radio Spectrum Matters (ERM); Short range devices (SRD); Technical characteristics for SRD equipment using Ultra Wide Band technology (UWB); Part2: Pulsed Ground-, Wall- and Through-Wall Probing Radar applications.

The key document for proving compliance is:

  • ETSI EN 302 066-1 Electromagnetic compatibility and Radio spectrum Matters (ERM); Short Range Devices (SRD); Ground- and Wall-Probing Radar applications; Part 1: Technical characteristics and test methods

The second part of this document necessary for it to be treated as a harmonised standard is:

  • ETSI EN 302 066-2 Electromagnetic compatibility and Radio spectrum Matters (ERM); Short Range Devices (SRD); Ground- and Wall-Probing Radar applications; Part 2: Harmonized EN under article 3.2 of the R&TTE Directive

In addition to meeting the Radio Regulations, GPR must also be compliant with the EMC regulations. The ETSI EMC regulations are drafted with one common document that covers all technical requirements. These are then specialised in additional parts for specific equipments.

To complete the ETSI documentation an EMC standard specifically for GPR has been established, it is:

  • ETSI EN 301 489-32 Electromagnetic compatibility and Radio Spectrum Matters (ERM); Electromagnetic Compatibility (EMC) standard for radio equipment and services; Part 32: Specific conditions for Ground and Wall Probing Radar applications

This should be read with the general EMC document:

  • ETSI EN 301 489-1 Electromagnetic compatibility and Radio Spectrum Matters (ERM); Electromagnetic Compatibility (EMC) standard for radio equipment and services; Part 1: Common technical requirements

The GPR licensing documentation is completed by:

  • “EuroGPR Code of Practice for the use of GPR Systems in Potentially Sensitive Radio Environments”