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ACB EN 300 328 V1.8.1

ACB EN 300 328 V1.8.1. Michael Derby ACB Europe 9 April 2014. Introduction. American Certification Body TCB, FCB, RCB, Notified Body Notified Body to the R&TTE Directive Michael Derby Regulatory Engineer, TCB, FCB, Notified Body EMC and Radio Test Engineer for many years

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ACB EN 300 328 V1.8.1

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  1. ACBEN 300 328 V1.8.1 Michael Derby ACB Europe 9 April 2014

  2. Introduction • American Certification Body • TCB, FCB, RCB, Notified Body • Notified Body to the R&TTE Directive • Michael Derby • Regulatory Engineer, TCB, FCB, Notified Body • EMC and Radio Test Engineer for many years • Previously on ETSI TG11 (EN 300 328)

  3. Introduction of Presentation • EN 300 328 (primary focus here is V1.8.1) • The standard is used by many people • Quick poll? • Applicable to WLAN, Bluetooth, Zigbee, etc. • Does not exclude other device types or technologies • 2.4 GHz frequency band is very busy • Significant changes observed in the last few years • Sensitive, provocative, controversial topic • Chris is on standby!

  4. Introduction of Presentation • Agenda • Only 45 minutes… don’t expect many numbers! • Deleted text in favour of ‘future’ section • European Regulatory process for R&TTE • Standards, Decisions, Notified Body, Directive • Harmonised Standards, Official Journal, DoC • EN 300 328 • History and technical requirements • Changes to the test methods • The future

  5. European Compliance • Process for authorising radios in Europe • The R&TTE Directive • It’s a ‘Declaration of Conformity’ Directive • The DoC is to the Directive • Not a certification to the standard • Dynamic DoC applies each day to each unit • Harmonised Standards • Simple way to ‘presume’ compliance with Directive • Standards are listed in the Official Journal

  6. European Compliance • Hierarchy within the system:

  7. DoC and HS • Harmonised Standards (HS) • Used to give “presumption of conformity” to the manufacturer (or who placing on market) • Declaration of Conformity (DoC) • Applies on each new day, to each new unit • Helps with technology and interference issues • Notified Body statement of opinion • DoC, when Harmonised Standard not applied • Or does not (fully) comply with HS

  8. Official Journal (OJ) • Official Journal on Europa website • Updated periodically • Perhaps once per year (though request for more) • List of current harmonised standards (and version) • A transition period with superseded standards • OJ explains dates of transition • New standards added without transition • In rare cases, a ‘note’ is added to the OJ • As with EN 300 328 V1.7.1, since 2009

  9. EN 300 328 History • EN 300 328 V1.6.1 (2004-11) • No specific spectrum sharing requirements for non FHSS transmitters • Expired from OJ on 30 June 2008

  10. EN 300 328 History • EN 300 328 V1.7.1 (2006-10) • Medium Access Protocol is mandatory (“U”) • No test methods presented in the HS • If using HS route (Annex III of R&TTE D) • Manufacturer responsible for own decision • If using NB route (Annex IV of R&TTE D) • NB assess spectrum sharing (esp. non-WLAN) • For WLAN, it ‘was’ assumed that 802.11 was ok

  11. EN 300 328 History • EN 300 328 V1.7.1 (2006-10) • Note added to OJ on 15 December 2009 • Spectrum sharing, DAA, LBT is required for HS • Explained that draft V1.8.1 was in progress • Confirmed ‘mandatory’ nature of requirement • Note added to OJ on 23 October 2012 • Spectrum sharing tests of V1.8.1 to be used for HS • Reaffirmed mandatory nature of requirement • V1.7.1 (including additional note) will cease HS on 31 December 2014

  12. EN 300 328 History • EN 300 328 V1.7.1 (2006-10) • Why is spectrum sharing such a surprise? • Manufacturers assumed labs were doing it? • Labs assumed manufacturers were doing it? • Innocent ignorance of the requirements? • Lazy avoidance of the full requirements? • Lack of regulatory knowledge? • Genuine misunderstanding of WLAN technology?

  13. EN 300 328 History • EN 300 328 V1.8.1 (2012-06) • Added to the OJ on 23 October 2012 • Spectrum sharing requirements mandatory • Medium Access Protocol replaced by ‘Adaptivity’ • Test methods introduced for various technologies • (To be clarified on later slides) • Clearer requirements and test methods • As requested by TCAM, European Commission; and Industry

  14. EN 300 328 History • Reasons for change: • Interference in the band • TCAM statement that 2.4 GHz band must be technology neutral • 2.4 GHz is a busy band • Something needed to be done • “Medium Access Protocol” was in the standard • Requirement was mostly ignored • Therefore detailed test methods were required • ETSI instructed to create these test cases • European Commission and TCAM

  15. EN 300 328 History • Reasons for change: • Power measurement challenges • Medium Utilisation (MU) required a test method that captures and stores values for burst power and duration over a long observation period • Noting that power can change from burst to burst • Many existing technologies have variable duty cycle • Regulators and MSA want ‘real life’ test methods • No customised test modes permitted • Cannot use non-realistic test modes

  16. EN 300 328 History • Choice of test methods: • Test methods are written by the attendees at the ETSI meetings • Test labs, manufacturers, regulators • I used to attend as a test lab representative • The ‘various options’ in previous versions • Presently, the TCB Council is not a contributor

  17. EN 300 328 History • Final Draft EN 300 328 V1.8.2 (2014-04) • Download now from ETSI website • Now in the final phase of National vote • Not on the OJ • It’s a draft • Some changes • Discussed at the end of this presentation • It will become EN 300 328 V1.9.1

  18. Essential V1.7.1

  19. Essential V1.8.1

  20. V1.7.1 verses V1.8.1

  21. New Requirements of V1.8.1 • Disclaimer:Read the standard for full details! • We will discuss some of the most significant new additions in EN 300 328 V1.8.1 • There is not enough time to go through each section in detail, of course

  22. New Requirements of V1.8.1 • Equipment Types: Operation of the EUT • Adaptive and non-Adaptive modes, modes of operation, modulations, channel utilisation, number of transmitter chains, antennas, etc. • All to be declared to the test lab, by manufacturer • Testing route will depend on the declaration • Annex E of EN 300 328 V1.8.1 gives sample form • This should be included in the test report • Not appearing in many test lab’s reports!

  23. New Requirements of V1.8.1 • Equipment Types: • Section 4.2.2 – Explanation of “Adaptive Equipment” and “Non-Adaptive Equipment” • Adaptive equipment uses automatic mechanisms for avoiding interference with other radios • Non-adaptive equipment uses alternative means to reduce interference with other radios, such as low duty cycle or low spectrum utilisation • This is common to other ETSI EN standards • Such as EN 300 220, EN 300 440, etc.

  24. New Requirements of V1.8.1 • Extreme Test Conditions: • Section 5.1 – Extreme temperature & voltage • Previously dictated by the standard • Now it is at the declaration of the manufacturer • Note that reasonable guidance does exist • EN 300 019 series of standards • Gives recommended levels for location types

  25. New Requirements of V1.8.1 • General layout of the standard • Split between FHSS and non-FHSS devices • Within each section (FHSS & non-FHSS), there is a split between adaptive and non-adaptive devices • Adaptive FHSS can be silent on occupied channels or jump immediately to next channel • Adaptive non-FHSS choose/avoid channels • Adaptivity or low MU (interference reduction) only applies to devices >10 mW e.i.r.p.

  26. New Requirements of V1.8.1 • Technical: Output Power • Applies to FHSS and non-FHSS • Limit is still 20 dBm (100 mW), e.i.r.p. • Fast Power Sensor of minimum 1 MS/s is needed • Spectrum Analyser or ‘normal’ power meter not used • FHSS equipment tested while hopping during normal operation mode • Non-FHSS tested on three channels (B, M, T) during normal operation mode

  27. New Requirements of V1.8.1 • Technical: Output Power • Test method is quite lengthy and complicated • Duty cycle correction no longer used • Sensor captures data for processing to find burst power • MIMO test synchronised on all ports together • Storage of data and processing • Gating of power sensors • It’s different to the method used before • Signals of varying duty cycle • Linked to MU; a calculation of power and time

  28. New Requirements of V1.8.1 • Technical: Power Spectral Density • Applies to non-FHSS only • Limit is still 10 dBm/MHz, e.i.r.p. • Test method is new • Different RBW and settings • Use 10 kHz RBW to measure multiple 1 MHz segments • Analyse to find the worst one • Post test data processing required

  29. New Requirements of V1.8.1 • Technical: Occupied Channel Bandwidth • Applies to FHSS and non-FHSS • Based on 99% bandwidth • Must fall completely within band (band edge) • Partly replaces the old Frequency Range test • For non-Adaptive FHSS with >10 mW, e.i.r.p. • Limit: <5 MHz • For non-Adaptive non-FHSS with >10 mW, e.i.r.p. • Limit: <20 MHz

  30. New Requirements of V1.8.1 • Technical: Occupied Channel Bandwidth • Top and Bottom channels to be tested • For FHSS, it is a test of an individual hopping channel • Not the whole hopping band • May need to stop the hopping to test

  31. New Requirements of V1.8.1 • Technical: Tx Emissions out-of-band • Applies to FHSS and non-FHSS • This is really a ‘band edge’ type of test

  32. New Requirements of V1.8.1 • Technical: Tx Emissions out-of-band • Measured in the time domain (zero Hz) • Multiple plots for multiple segments • Tested at nominal and extreme conditions • (Only at nominal in EN 300 328 V1.8.2)

  33. New Requirements of V1.8.1 • Technical: Tx Spurious Emissions • Applies to FHSS and non-FHSS • Limits and RBW requirements are new • V1.7.1 was not aligned with other ETSI standards • Based on ERC Recommendation 74-01 • Lower limits in sensitive broadcast bands • New (aligned) resolution bandwidth above 1 GHz • No differentiation between narrow and wide band • Procedure for final measurements is different • In general, requirements are now (correctly) tougher

  34. New Requirements of V1.8.1 • Technical: Tx Spurious Emissions

  35. New Requirements of V1.8.1 • Technical: Tx Spurious Emissions • Test can be done radiated with antenna connected • Test can be done conducted from the antenna port and then additionally from the cabinet with the antenna port terminated

  36. New Requirements of V1.8.1 • Technical: Rx Spurious Emissions • Applies to FHSS and non-FHSS • Limits are the same as V1.7.1 • RBW requirements are different! • V1.7.1 was not aligned with other ETSI standards • New (aligned) resolution bandwidth above 1 GHz • No differentiation between narrow and wide band • Procedure for final measurements is different • In general, requirements are now (correctly) tougher

  37. New Requirements of V1.8.1 • Technical: Rx Spurious Emissions

  38. New Requirements of V1.8.1 • Technical: Spectrum Sharing • Reducing interference within the band • TCAM: “Ensuring equal access to all and in case of congestion, graceful degradation to all” • Two main ways to achieve this: • Adaptivity • Detect and avoid (DAA) • Clear Channel Assessment (CCA) • Listen Before Talk (LBT) • Low medium utilisation (power and time) • Reduce power, or duty cycle, or both

  39. New Requirements of V1.8.1 • Technical: Spectrum Sharing • Adaptive and non-Adaptive modes • It is possible that a device could have both modes • It is not always possible to define the 'Equipment’ • If a device has both modes, then each mode must comply with the requirements for that mode • Example might be Bluetooth with Low Energy mode

  40. New Requirements of V1.8.1 • Technical: Spectrum Sharing (idealistic) e.i.r.p. <10 mW Yes No Adaptive Yes No Yes MU < 10% No Fail Pass

  41. New Requirements of V1.8.1 • Technical: Spectrum Sharing (idealistic) • Note that whilst some devices ‘should’ meet the requirements, the tests exist for a reason • Devices which are supposed to be ‘adaptive’ may fail to meet the tests if the adaptive firmware is not correctly set, or has been disabled, or could be disabled • This needs to be considered with regard to the set-up access an installer might have • User cannot be permitted to cause non-compliance

  42. New Requirements of V1.8.1 • Technical: FHSS Requirement • Dwell Time test and limit • Adaptive Equipment; silent on busy channels • 400 mS in 400 mS x Channels • (e.g., 31.6 seconds for 79 channel Bluetooth) • Requirement is like FCC • Non-Adaptive Equipment; always transmitting while hopping but ‘blacklisting’ is permitted

  43. New Requirements of V1.8.1 • Technical: FHSS Requirements • Hopping Frequency Separation • Adaptive and Non-Adaptive Equipment / Mode • Adaptive Equipment limit: >100 kHz • Non-Adaptive limit: >Occupied Bandwidth with a minimum of 100 kHz

  44. New Requirements of V1.8.1 • Technical: FHSS Requirements • Duty Cycle, Tx Sequence, Tx Gap • Non-Adaptive Equipment or Mode • Only applies to devices with >10 mW, e.i.r.p. • MU approach is used • Tx Sequence is transmission (single or multi channel) • Tx Gap is silent period between transmissions • Tx Sequence <5 mS • Tx Gap >5 mS • Maximum duty cycle is 50%

  45. New Requirements of V1.8.1 • Technical: Non-FHSS Requirements • Duty Cycle, Tx Sequence, Tx Gap • Non-Adaptive Equipment or Mode • Only applies to devices with >10 mW, e.i.r.p. • Tx Sequence is transmission (or burst) • Tx Gap is silent period between transmissions • Maximum duty cycle is 50% • Max Tx Sequence = Min Tx Gap = ‘M’ • ‘M’ must be in range 3.5 mS to 10 mS • Observed over a 1 second period

  46. New Requirements of V1.8.1 • Technical: FHSS / Non-FHSS Requirement • Medium Utilisation Factor (MU) • Non-Adaptive Equipment or Mode only • Only applies to devices with >10 mW, e.i.r.p. • MU(%) = (Pburst/100 mW) x Duty Cyle % • Device may have dynamic MU • Power level and duty cycle varying over time • Less power will allow higher duty cycle • MU limit is 10% • 100 mW power would require 10% duty cycle • 50% duty cycle would require 20 mW power

  47. New Requirements of V1.8.1 • Technical: FHSS Requirements • Adaptivity • Adaptive Equipment or Mode only • Only applies to devices with >10 mW, e.i.r.p. • Uses DAA mechanism to identify used frequencies • May be LBT; check availability before transmission • Or; check availability after transmission (BER or PER) • Detection or reaction thresholds proportional to output power, e.i.r.p.

  48. New Requirements of V1.8.1 • Technical: Non-FHSS Requirements • Adaptivity • Adaptive Equipment or Mode only • Only applies to devices with >10 mW, e.i.r.p. • Uses DAA mechanism to identify used frequencies • May be LBT; check availability before transmission • Or; check availability after transmission (BER or PER) • Clear Channel Assessments • Detection or reaction thresholds proportional to output power, e.i.r.p.

  49. New Requirements of V1.8.1 • Technical: Non-FHSS Adaptivity • Two main types of non-FHSS are described • Frame Based equipment and Load Based equipment • Frame Based equipment • Transmit/Receive structure is not demand driven • Load Based equipment • Transmit/Receive structure is demand driven • Test method looks similar to DFS • Or blocking found with many other radio types, such as Fixed Links or Cellular Base Stations • Includes other than co-channel interference

  50. New Requirements of V1.8.1 • Technical: Receiver Blocking • Applies to FHSS and non-FHSS • Adaptive Equipment or Mode only • Only applies to devices with >10 mW, e.i.r.p. • Uses DAA mechanism to identify used frequencies • May be LBT or may be ‘other’ (such as real interference) • In-band interfering CW signal at -30 dBm • (Change to -35 dBm in EN 300 328 V1.8.2) • Ability to detect and avoid other signals • Or blocking found with Fixed Links or Base Stations

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