FINAL REPORT - Stakeholders - Ofcom

other occupiers of the spectrum could easily stymie any reduction in the allocation and
consideration needs to be taken of the systems employed by other users before it would
be worthwhile to make any changes to maritime radar users.
Regulatory Impact
The reduction in allocation to maritime radar in any of the currently used bands would
have a direct impact upon the specifications of the radars deployed. Many current radars,
though nominally operating on frequencies slightly offset from the centre of the bands,
due to the short pulse-widths and the limitations in frequency control, in effect occupy the
whole of the available band. However, technically there is no need for them to do so. The
application of more modern techniques could reduce the overall bandwidth required. Such
a change would therefore require maritime radars sold in the UK to conform to a UK
specific specification.
To achieve this may be a challenge itself. UK vessels subject to IMO Carriage
Requirements are required to comply with the EU Council Directive on Marine Equipment,
98/85/EC and modifications. In accordance with the provisions of this Directive, radio
equipment installed on board a vessel required to comply with SOLAS, must install
equipment that complies with the standards of those Standardisation Bodies listed in the
relevant Annex to the Directive. This requires that such equipment must comply with
either the relevant ETSI Standard or the International Electro-Technical Commission
(IEC) Standard. The equipment would also have to be marked as compliant with the
standard. However Article 6.1 of the Directive states, ”No Member State shall prohibit the
placing on the market or the placing on board a Community ship of equipment referred to
in Annex A.1 which bears the mark or for other reasons complies with this Directive or
refuse to issue or renew the safety certificates relating thereto.”
These requirements would continue (unless the Directive and IMO Carriage
Requirements were amended) even if the UK introduced a requirement for more
spectrally efficient equipment to be installed on UK vessels since a vessel owner could
still fit any equipment bearing the ships wheel mark. However AIP might be applied to
encourage purchase of equipment which met a UK ‘voluntary national measure’ which
encouraged spectrally efficiency whilst maintaining operational integrity.
A similar situation could arise with non SOLAS vessels where radar equipment is subject
to the R&TTE Directive, 99/5/EC. This ‘new approach Directive’ relies on the use of
harmonised standards (developed as a result of a Commission mandate to CEN,
CENELEC and/or ETSI) to provide a presumption of conformity with the essential
requirements of the Directive, one of which (Article 3.2) requires the effective and efficient
use of the radio spectrum to avoid harmful interference.
Within the R&TTE Directive the concept of harmonised frequency bands has been
introduced. Every frequency band can be considered harmonised throughout the EU if it
satisfies the following:
• it is designated to accommodate radio equipment which can only transmit under
the control of a network; or
• it is allocated to the same radio interface in every Member State in the following
way:
o there is a common frequency allocation; and
o within this allocation, the allotment and/or assignment of radio
frequencies or radio frequency channels follows a common plan or
arrangement; and
o the equipment satisfies common parameters (e.g. frequency, power,
duty cycle, bandwidth, etc.)
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