UK Comments on Draft ETSI EN 301 091, parts 1, 2 and 3
Comment
number
EN 301
091- part
Clause/
Line
Paragraph
Subclause number (if Figure/
applicable Table
)
Type of
COMMENTS
comment
(General/
Technical/Edito
rial)
Proposed change
OBSERVATIONS
on each comment submitted
UK1
3
Annex A
T
Rx spurious emissions not
referenced
Add text to reference Rx spurious
emissions in the Annex A.
accepted
UK2
3
Annex D
T/G
Annex D contains “essential
requirements”. However, it is not
mentioned in the body of the
standard, and is not called up in
Annex A.
Call up these essential requirements, Accepted, proposal till13th of
set out in Annex D, in both the body Jan, because additional
of standard and in the Annex A.
rearrangement in Annex D
necessary
UK3
3
Annex D
T
There appears to be confusion of
field strength and power flux
density:
Either state the flux density or state
the equivalent field strength
Accepted, proposal till13th of
Jan,
Diagrams and text do not make the Make it clear in D6 whether the
various zones clear.
Supervision area and Protected area
are different, as the figures D2 and
D.6 says: “Within the protected
D3 appear to suggest.
area (supervision area) ….
Accepted, proposal till13th of
Jan,
….field strength of 0,5 W/m2…
UK4
3
Annex D
Figures
D2, D3
and clause
D.6
Supervision area and protected
area are different places in the
Figure D2 and D3.
UK5
3
D.6.
T
What does “mean power level of
50 or 30 dBm (e.i.r.p.)” mean in
this context? Eirp does not vary
with distance.
Define the term, or the means of
measurement.
Accepted, values will be
calculated till 13th of Jan
1
UK6
3
D.6
T
Note +50 dBm eirp is a flux of 0.5 If the limits cannot realistically be
Accepted, proposal till13th of
W/m2 at 4 m.
exceeded, there is no need to state
Jan,
the requirement. See UK 4 comment
It would actually be very difficult on definition of Supervision area and
to exceed these limits.
Protection area.
UK7
1,
7.4.4
T
The use of QP detector is not
appropriate for radar power
measurements.
A test method that permits the true
Rejected,
mean power to be measured needs to
the QP detector is also used for
be substituted for this test
spurious emissions in other EN
measurement.
(e.g. 305550) and in ITU-REC
M1177
UK7
3
7.4.4
T
The use of QP detector is not
appropriate for radar power
measurements.
A test method that permits the true
mean power to be measured needs to
be substituted for this test
measurement.
UK8
All
G
There is an unusual structure of the Review the structure in light of
parts.
imminent change to the RED.
No official new mandate to
prepare HENs for the new RE-D
Parts1 and 2 together make up the
usual ETSI 2 part standard,
necessary for the R&TTE
Directive. However, Part 3 is
written as a one part standard.
UK9
1, 3
7
E
There is a Hanging clause at start,
that cannot be referenced.
Rejected
Renumber as necessary.
Part 1:
Align antenna requirements with rest Accepted,
Note: The clause also specifies the of test procedure.. See comments on
new clause 7.1 introduction
measurement to be at max antenna 7.2.3.2. (comment UK24)
gain. See UK24.
Take over into Part 3
2
UK10
1, 3
7.1
T
7.1 is a “modulation bandwidth”
test. This is no longer needed,
given the new Occupied BW test
in 7.3?
Remove this test as unnecessary,
Part 1: accepted with
given the test now for Occupied BW modification, test converted to
in 7.3.
OBW test
Take over into Part 3
UK11
1, 3
7.1.3
T
The limit makes no sense in
relation to the test. The test is
intended to establish the limits.
See comment on 7.1. (UK10)
Part 1: Resolved see UK10
Take over into Part 3
UK12
1, 3
7.3.1,
7.3.2,
7.3.3
T
There is a conflict in nature of
measurements between;
7.3.1: Out-of-band emissions are
measured as mean power spectral
density (e.i.r.p.)
A single fixed RBW needs to be
defined and all tests need to be
amended accordingly to this fixed
RBW figure.
Part 1: accepted, RBW 1MHz
A single fixed RBW needs to be
defined and all tests need to be
amended accordingly to this fixed
RBW figure.
Part 1: Resolved see UK12
Take over into Part 3
7.3.2: In order to obtain the
required sensitivity a narrower
bandwidth may be necessary
7.3.3: The bandwidth of the
measuring receiver shall be set to a
suitable value
UK13
1, 3
7.3.2
Table 3
Pt1)
T
Table 4
(pt3)
UK14
1, 3
7.3.3,
7.3.4
T
It is unclear why the BW is a
maximum and not a specified
value?
Further, text above should read
“less than or equal to”
Take over into Part 3
These clauses rely on the Occupied Add a test for Occupied BW before
BW of the EUT. However, it is
this clause, stating exactly how
unclear where the OBW is
OBW is defined.
measured. 7.3.1 says it is fH – fL,
but where are these values
established?
Part 1: Resolved see UK10
Take over into Part 3
3
Change definition to read “The
Part 1: accepted
radiated mean power (e.i.r.p) of the
“The radiated mean power (e.i.r.p.) radio device under test, is the product
or equivalent isotropic radiated
of the mean power supplied to the
Take over into Part 3
power (e.i.r.p.)…..”
antenna and the antenna gain in a
given direction relative to an
isotropic antenna.”
UK15
1, 3
7.2.1
T
What does the definition mean?
UK16
1, 3
7.2.1.2
T
The quantity is not actually
defined.
The whole clause should be replaced Part 1: accepted, with
with the following text;
modifications
“The maximum radiated peak
power (e.i.r.p.) is measured in the
permitted range of operating
frequencies and is an value
including antenna gain.”
“The maximum radiated peak power
(e.i.r.p) is the peak power radiated in
Take over into Part 3
the direction of the maximum level
(usually the bore sight of the
antenna) under the specified
conditions of measurement.
The maximum radiated peak power
(e.i.r.p) is measured in the permitted
range of operating frequencies and is
expressed as the total power over the
entire bandwidth of the device. The
value is given in dBm. The test shall
be performed for normal and extreme
test conditions as defined in clauses
5.3 and 5.4”
UK17
1, 3
7.2.2.1
T
The test procedure is only
applicable to certain types of
FMCW radars. It will fail with
very fast sweeps or with
instantaneously wideband signals.
Power can only be measured
correctly with power meter or
sufficiently integrating spectrum
analyser.
Part 1: accepted, with
modifications
The Standard needs to be redrafted to Take over into Part 3
7.2.1.1 says this is “power over the allow for the correct measurement of
entire bandwidth of the device”,
power for all BW devices.
but the measurement is done with
1 MHz BW.
4
UK18
1, 3
7.2.2.1
T
The text for averaging time is
confusing.

See comment (UK17)
Detector mode: RMS
with an averaging time of
minimum one cycle time
per MHz (maximum 100
ms).
Part 1: accepted
Take over into Part 3
Average time (per point on
spectrum analyser scan): 1 ms or
less.
A measurement time (averaging
time) of 1 ms per measurement
point is not sufficient….
UK19
1, 3
7.2.2.1
T
“Frequency Span: Equal to or less
than the number of displayed
samples multiplied by the
resolution bandwidth. The
measurement results shall be
determined and recorded over the
frequency ranges as shown in table
9.”
See comment (UK17)
Part 1: accepted
Unless the whole comments of UK19
are agreed, a Table 9 need to be
Take over into Part 3
added.
There is no Table 9.
UK20
1
7.2.2.1
E/T
(Pt 1) References to Annexes C
and D appear incorrect.
Change to reference Annexes A and Part 1: accepted
B
UK21
1, 3
7.2.2.2
T
Incomplete procedure. It is unclear See comment (UK17)
what is being measured and how
the measurement is performed?
Note: participant shall propose
wording for better description of
the measurement procedure
Take over into Part 3
5
UK22
1, 3
7.2.2.3,
7.2.2.4
T
1.
2.
3.
UK23
3
7.2.2.4
E/T
These clauses seem to
Remove these two clauses.
Proposal: delete both clauses,
both repeat and contradict
everything is covered by new
Rely instead on improved 7.2.2.1 and clause 7.1
material in 7.2.2.1 and
7.2.2.2.
7.2.2.2. Eg., use power
meter instead of spectrum
analyser.
Take over into Part 3
They do not align with the
definitions in 7.2.1.
What is the essential
difference between these
clauses? Why are two
needed.
Reference to Annex A appears to
be wrong.
Reference to Annex C.
accepted
6
UK24
1, 3
7.2.3.2
Table 2
T
Table 2 says that for slow scanning
antennas the limits are the same as
in Table 1 for fixed antennas,
which makes sense.
For fast scanning antennas the
peak power limit is the same,
which also makes sense. But the
mean power limit is adjusted.
The problem is that the limit is
adjusted downwards not upwards.
It is stated in Annex B (part 1) and
Annex C (part 3) and in 7(hanging
clause) that the measurement is
taken with the scanning inhibited
and in the direction of the
maximum. If you then start
scanning, the mean power in any
direction will go down, but the
peak power should stay the same.
So the limit for the mean power
measurement should be bigger, not
smaller.
It needs to be made clear in the body
of the standard, (and not buried in an
Annex), whether the measurement is
with scanning on or with scanning
off.
Then Table 2 needs to be revised
accordingly.
Proposal:
Devices with scanning function
should be measured with a
stopped scanning (see wording
Annex B) and therefore we can
delete “old” 7.2.3.2 completely
Question
All situations covered.
What is with switching between
fixed beams, device with more
than one beam?
Action:
Check Wording AnnexB.1
Final Part 1
Take over into Part 3
It looks as if Table 2 was drafted
on the assumption that the
measurement is taken with the
antenna scanning, therefore the
adjustment is applied in the wrong
direction.
NOTE. Part of the problem is that
it is not properly clear in the body
of the standard whether the
measurement is with scanning on
or off.
7
UK25
1
1 Scope
Notes 1and E
2
Subjective comments, not
appropriate for a EN. Also NCAP
misspelt.
Remove notes. They are not relevant Accepted with modifications
to a standard intended to establish
conformity under the R&TTE / RED.
Definition “ground based
vehicles separated from the
NOTE 1
Note1 and Note2. Notes will be
reworded
UK26
1
1 Scope
E/G
ETSI Guide to drafting
Harmonised Standards, EG 201
399 states: …should be defined
without undue limitation of
application, should be as general
in operating frequencies as
possible, and should not address
national or other regulatory
restrictions.
The standard scope needs to align to Rejected
EC decision and be clear that
infrastructure radar are within scope. Proposal to create a NWI for a
EN 301 091-4 for fixed TTT
There is no expectation of type of
antenna in the EC Decision. Only
the e.i.r.p need be met. Remove this
requirement.
Requirement for an integral
antenna should be removed.
Scope should include fixed
infrastructure radars in line with
[i.3].
UK27
1
Scope
UK28
1
2.2
[i.9]
E
The penultimate paragraph
references i.9. This reference
should be i.3
Change i.9 to i.3
Accepted, done till TGUWB#20
E/G
The reference to i9 is not needed
given there is [i.3].
Remove reference to i.9
Accepted, done till TGUWB#20
8
UK29
1, 3
3.1
The Definitions section does not
contain definitions of
Occupied Bandwidth
And does contain unused ones
such as
Include definitions and remove
unnecessary ones.
Accepted, done till TGUWB#20
Take over into Part 3, but final
check necessary
antenna scan duty factor
assigned frequency band
blanking period
(list not exhaustive)
UK30
3
Annex D
T
Fig D1. Does not appear
technology neutral. Iy appears to
be product specific.
This flow chard needs to be replaced accepted
with the requirement stated in
technology neutral terms.
9