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Andres Teeäär Saatja: Andres Teeäär Saatmisaeg: reede, 25. juuni 2021 06:11 Adressaat: 'Kyle Wesson' Koopia: Maret Ots; Erko Kulu; Veikko Tunnel; Swarm Regulatory Team Teema: RE: FW: Use of 865-870 MHz Band for RFID to Space Dear Kyle, Thank you for your enquiry! Commission implementing decision (EU) 2019/1345 (of 2 August 2019 amending Decision 2006/771/EC updating harmonised technical conditions in the area of radio spectrum use for short-range devices) defines in article 1, subsection (1), point 1 that: “short-range device” means a radio device which provides either unidirectional or bidirectional communication and which receives and/or transmits over a short distance at low power; Standard ETSI EN 302 208 (Radio Frequency Identification Equipment operating in the band 865 MHz to 868 MHz with power levels up to 2 W and in the band 915 MHz to 921 MHz with power levels up to 4 W; Harmonised Standard for access to radio spectrum) defines in point 4.2.5 table 1b: Interrogator categories: Category I is a high performance level of interrogator, typically used where the distance between the RFID interrogator and RFID tags is often greater than 10 m or in challenging RF propagation environments; Satellite communication equipment cannot be considered short range devices and thus I did not find it possible to allow using these without permit. I also checked with my colleagues who deal with frequency authorisation and unfortunately they did not see the possibility to issue frequency authorisation or permit for this application. If you have more questions please do not hesitate to contact us. With Best Regards, Andres Teeäär +372 667 2094 From: Kyle Wesson <[email protected]> Sent: Friday, June 11, 2021 7:16 PM To: Andres Teeäär <[email protected]> Cc: Maret Ots <[email protected]>; Erko Kulu <[email protected]>; Veikko Tunnel <[email protected]>; Swarm Regulatory Team <[email protected]> Subject: Re: FW: Use of 865-870 MHz Band for RFID to Space Dear Andres, Thank you very much for your reply. If I understand correctly, the ground devices are okay provided they follow the various directives and compliance for SRD/RFID. Swarm intends to comply with all of these. As for the MSS component, if the ground devices meet all of the technical requirements and those technical requirements allow reception by a satellite (e.g., 2W at 869,4 MHz), is there a reason why under a license-exempt basis this would be forbidden? The operations would always remain on a non-interference, non-protection basis, so 1 that they would not cause any interference concerns with other license-exempt systems, and they meet all of the existing requirements. Pardon my question as I am still learning about the exact rules. We have now received over 12 EU countries allowing/approving our proposed operations on a NINP basis. So I am trying to figure out the specific concern in Estonia (is it technical or regulatory or other). Attached is the German license with usage conditions (highlight, more in PDF attached): 1. that MSS earth stations (MES) on the uplink can be operated in Germany in line with the existing technical requirements of the general authorisation in Verfügung 133/2019, modified by Verfügung 12/2020, that acts as ‘umbrella/envelope’ general authorisation, as follows: a. At centre frequencies 865.7 MHz, 866.3 MHz, 866.9 MHz and 867.5 MHz with a maximum e.r.p. of 3 dBW (2W) within a maximum bandwidth of 125 kHz and a maximum duty cycle of 10% over 15 min. The smaller channel bandwidth, compared to the EU harmonized use for terrestrial RFID applications (200 kHz), is justified to ensure that there are no negative effects on tag backscatter transmissions in the spectrum in-between the terrestrial RFID interrogator channels. The MES duty cycle shall ensure the possibility of sharing as a safeguard measure taking into account potential other similar use at those frequencies in the future; b. Within 869.4-869.65 MHz with a maximum e.r.p. of -3 dBW (500mW) and maximum transmitter duty cycle of 10% over 15 min; Space-to-Earth links from Swarm Satellites are operated within the same frequencies as under 1) with a maximum PFD on the ground of -130 dBW/4kHz/m2 (peak value) and under an adapted RFID principle with dynamically switching between the MES (uplink) and the satellite (downlink); Thank you for your time already, Kyle On Mon, May 31, 2021 at 11:42 PM Andres Teeäär <[email protected]> wrote: Dear Kyle, Sorry for the delay in getting back to you! We analysed your request concerning the usage of the band 865-870 MHz and concluded that unfortunately the SWARM solution for the usage of RFID does not comply with Estonian regulation for licence exempted SRD applications. Regrettably the regulation (Raadiosageduste kasutamise tingimused ja tehnilised nõuded sagedusloast vabastatud raadioseadmetele – Riigi Teataja) and appendix 15 for RFID (Raadiosageduslikud identifitseerimisseadmed) are only available in Estonian. Information in English can be found in EFIS. Since the band is extensively used by licence exempted SRD applications, at the time being we do not see the possibility to issue frequency authorisation or permit for this application. Nevertheless, we would appreciate, if you could share with us the usage conditions stipulated for SWARM RFID space application in other European countries. It would be helpful for coming back to this issue in the future, when 2 more information concerning co-existence with other applications become available and might lead to the changes in the appropriate Regulations. With Best Regards, Andres Teeäär Chief Specialist of the Frequency Management Division + 372 667 2094 | [email protected] | https://www.ttja.ee Consumer Protection and Technical Regulatory Authority Endla 10A, 10122 Tallinn, Estonia From: Kyle Wesson <[email protected]> Sent: Monday, May 17, 2021 11:00 PM To: Erko Kulu <[email protected]> Cc: Veikko Tunnel <[email protected]>; Andres Teeäär <[email protected]>; Maret Ots <[email protected]> Subject: Re: FW: Use of 865-870 MHz Band for RFID to Space Dear Andres and Veikko, I wanted to follow up on my colleague's earlier request for information. We wanted to share the good news that Switzerland, UK, Germany, Austria, Sweden, New Zealand, and several other countries have approved our request below. With that in mind, we kindly request you to consider our request so that we may help serve IoT customers in your country as well. Please let me know if you have any further questions. We would be happy to set up a call or meeting if you prefer. Best regards, Kyle Kyle Wesson, Ph.D. Lead Regulatory Engineer Swarm Technologies, Inc. 3 [email protected] On Tue, Apr 6, 2021 at 12:00 AM Erko Kulu <[email protected]> wrote: Dear Kyle Thank you for your inquiry. Our SRD and SAT specialist will work through your information and will give you an answer. Andres and Veikko please look at the inquiry. Best Regards Erko Erko Kulu Sagedushalduse talituse juhataja + 372 667 2120| [email protected] www.ttja.ee Tarbijakaitse ja Tehnilise Järelevalve Amet Endla 10A, 10142 Tallinn, Estonia From: Kyle Wesson <[email protected]> Sent: Monday, April 5, 2021 9:30 PM To: Erko Kulu <[email protected]> Cc: Swarm Regulatory Team <[email protected]> Subject: Use of 865-870 MHz Band for RFID to Space Dear Erko, We are writing to seek your guidance about the use of ultra-high frequency (UHF) spectrum, specifically 865-870 MHz, for RFID applications to and from space, using our satellites in Low Earth Orbit (LEO). 4 Swarm Technologies is a company with headquarters in the US, which operates a LEO VHF satellite network for Internet-of-Things (IoT) and Machine-to-Machine (M2M) communications using FCC approved VHF spectrum. We have deployed 72 of 150 commercial satellites to date, and have signed up to launch the remaining satellites before Dec 2021. We have now gone live with our products and data services and are providing services to customers in numerous countries on all continents. In addition to our VHF satellites, Swarm has also launched six UHF satellites and has obtained commercial authorization to provide services in a number of countries in the 865-870 MHz band (including New Zealand, Germany, Austria and the UK, and others). In order to serve customers in Estonia, we seek permissions for future commercial users to buy and use Swarm RFID tags to communicate with Swarm’s LEO satellites on a limited number of channels in the UHF 865-870 MHz band, using a very low (<0.1%) duty cycle. Swarm intends for customers to operate their devices in the RFID band (865-870 MHz) to communicate with Swarm UHF satellites, while guaranteeing that the user devices operate entirely consistent with your national frequency utilization plan (EC Decision 2019 / 1345 or equivalent). The Swarm operation principle considers the satellite being able to work as the RFID reader (from the network perspective) or a tag (from the signal collection perspective). The user devices would be certified to the necessary CE and/or ETSI standard and the entire system would operate on a non-interference, non-protection basis, meaning that the FIXED, MOBILE, and BROADCASTING allocations in the ITU Region 1 table would be protected 100%. Overall, these devices would be low duty cycle, low power, and low bandwidth such that the total contribution to the noise floor and/or PFD limits would remain well under established ITU thresholds. For information purposes I am attaching our application for operations in Germany, and the German UHF grant in case it is of use as a reference point. 1) The Swarm satellite system has a New Zealand based ITU-R filing under the name SNZL-NGSO-1 (CR/C/5115 of BR IFIC 2912). Coordination under RR9.21C is ongoing. 2) The user terminals will operate in accordance with ETSI standard EN 302 208. Their transmissions fall within all of the channel and bandwidth specifications and eirp limits of the existing RFID utilisation limits on the following channels (according to ERC Recommendation 70-03, Annex 2):  865.7000 MHz, max 200 kHz BW, transmit power ≤ 2 W,  866.3000 MHz, max 200 kHz BW, transmit power ≤ 2 W,  866.9000 MHz, max 200 kHz BW, transmit power ≤ 2 W,  867.5000 MHz, max 200 kHz BW, transmit power ≤ 2 W,  869.4 MHz – 869.65 MHz, transmit power ≤ 0.5 W 3) The satellites are able to receive such signals and adaptively set the channel frequency and their transmit power to maintain the appropriate regulatory limits. 5 Thank you in advance for any comments or guidance you can provide. Swarm would be happy to have a call to answer any questions you may have about our proposed operations in the UHF band. Best regards, Kyle Kyle Wesson, Ph.D. Lead Regulatory Engineer Swarm Technologies, Inc. [email protected] 6