Sovereign LPWAN, Part 1: Licensing and Operation of LPWAN Networks in Russia - Old New State Requirements

Hello, Habr!

At the end of last year, the sites, blogs and channels involved in the “Internet of things” stirred up news - supposedly the SCRF decided that the base stations of any LPWAN IoT networks should be only Russian-made, and when installed, they must be registered.


Russian-made LoRaWAN base station

Although for the most popular of open technologies - LoRaWAN - Russian BSs exist for themselves, this, for example, the Novosibirsky Vega BS-2, the news caused serious excitement for many. Firstly, you won’t be full of Vega alone, sometimes you also want Kerlink, Multitech and even Sagemcom. Secondly, well, everyone is building LoRaWAN today, and tomorrow? Such a solution would simply block the way to the Russian market for new standards - foreign equipment cannot be operated, and no one will invest in the development of a similar Russian one until the payback and prospects are somehow understood.

However, in fact, as usual with Russian law, owls are not what they seem to be.

Let's get it right.

Firstly, the notorious decision of the State Committee for Emergencies in the original- here it is necessary to flip immediately to the end, to paragraph 22.

22. In Appendix No. 11 to the decision of the State Committee for Radio Frequencies of 07.05.2007 No. 07-20-03-001, the column “Additional Terms of Use” for the radio frequency bands 864-865 MHz, 866-868 MHz, 868.7-869.2 MHz shall be supplemented with the following conditions:

“The use of base stations in communication networks for the collection and processing of telematic information is subject to:

registration of base stations in the manner established in the Russian Federation;

commissioning communication networks in accordance with the procedure established in the Russian Federation;

from December 1, 2020, it is allowed to use base stations manufactured in the territory of the Russian Federation that are assigned the status of telecommunication equipment of Russian origin (the condition does not apply to base stations registered before December 1, 2020). ”

The SCRC decision of 2007 is a general table on the use of short-range transceivers, to which dozens of additions and clarifications have already been issued: for example, when SCCR decides to give someone in this class of devices a few new frequencies, the decision about this also appears as additions to 07-20-03-001.

The basic decision of the State Committee for Emergencies is valid for 10 years, however, obviously, the 2007 decision in the deadline was simply extended for another ten.

So what do we see here?

Registration of LPWAN base stations

registration of base stations in the manner prescribed in the Russian Federation ;
commissioning communication networks in accordance with the procedure established in the Russian Federation ;

My selection. As it is easy to notice, the State Committee for Emergencies does not indicate a new obligation to license or register anything - the State Committee for Civil Rights and Emergencies indicates that the legislation of the Russian Federation must be respected, that is, in fact, acts as Captain Evidence.

For what purpose this amendment was adopted, it is difficult to understand (it is likely that with a purely political one, “it was necessary to demonstrate the work”), because in essence it does not change anything at all. Someone do not agree that laws should be respected? Can't see your hands?

It is not in the power to change the laws of the State Committee for Emergencies, it is beyond its powers.

Does this mean that base stations do not need to be registered? Wait a minute!

So, as we found out, the laws did not change. But, in fact, what was written in them before?

Firstly, traditionally for the Russian technological legislation, which very often represents a hasty tracing-paper from the international, “there is a word - but no term”. That is, the words "base station" are, and what they mean is not explicitly said anywhere. My home Wi-Fi router, which provides subscriber devices access to the public communications network - is it already a base station or not yet?

Here we can refer to another document called Exemptions from the list of electronic devices and high-frequency devices to be registered , and specifically to paragraph 22:

22. Non-specialized (for any purpose) terminal devices in the radio frequency bands:
26.957 - 27.283 MHz, 40.660 - 40.700 MHz and 433.075 - 434.790 MHz with an equivalent isotropically radiated power of not more than minus 17 dBW;
2400 - 2483.5 MHz with an equivalent isotropically radiated power of not more than minus 20 dBW;
864 - 865 MHz, 868.7 - 869.2 MHz and 5725 - 5875 MHz with a maximum effective radiated power of 25 mW .

Here you can notice three points - firstly, for lawmakers, the SCRC conducted the expansion of the range with a piece of 866-868 MHz passed unnoticed, so, strictly speaking, it is impossible to use any devices in it without registration; but here, as usual, the severity of Russian laws ... In the sense that no one will be fined for this, although they can formally formally - so if legal cleanliness is important to you, do not rush to happily set new frequencies on your network.

Secondly, limited power is 25 mW. In the fall, the SCRF allowed a power of up to 100 mW in the band 868.7-869.2 MHz - and so, such devices must be registered regardless of their purpose.

Thirdly, the term “base station” did not get better, but we came across the term “finished devices” - and we can assume that everything that they are not is a base station. Well, or not a base station, but everything needs to be registered.

Ok, Yandex, what is “terminal devices”? .. Here we are already helped by the third NPA - 126-FZ “ On Communication ”:

user equipment (terminal equipment) - technical means for transmitting and (or) receiving telecommunication signals via communication lines connected to subscriber lines and used by subscribers or intended for such purposes;

Hurray, my home Wi-Fi router does not need to be registered, it is in my use - it is the terminal equipment! The same applies to the smart home controller and other household items.

However, things are a little more complicated with LPWAN base stations - they are obviously usually used by a telecom operator, and accordingly, they are not final equipment.

And here we are smoothly moving on to the next item - “ commissioning communication networks in the manner prescribed in the Russian Federation ”, which is indirectly related to the question of who uses the equipment.

As the very same 126-FZ states, communication networks are of the following types:

• general use - intended for onerous provision of services to an unlimited number of persons
• isolated - intended for onerous provision of services to a limited number of users
• technological - to ensure the production activities of the organization
• special purpose
• postal service

The last two points do not concern us now, but we must deal with the rest again.

Let's start from the end. Technological communication networks are, obviously, communication networks of the scale of one enterprise ; on such networks, paid services are not provided to any third parties. For example, if you are implementing an individual project “digital something” for some industrial customer, and this project has LPWAN base stations in any form, then in essence you are building a technological communication network for this customer.

If you are building a network that several customers can connect to- for example, you cover the industrial zone with LoRaWAN, and on the basis of this LoRaWAN you offer the enterprises located in the industrial zone “digital something” based on your own resources, then you begin to move away from the technological network. However, at the moment you can still show that this network is technological, but not the customer, but yours; the customer does not purchase services from you for access to the data network, but for example, for access to your personal account, in which some information collected through this network is accumulated.

This excuse collapses at the moment when you allow the customer, for example, to put his own server with his own personal accounts, and simply drive data through your LoRaWAN - even if he previously bought this server from you, now he uses your LoRaWAN exclusively only as a data network. In this context, this network no longer provides the functioning of your enterprise, turning into a separate service - a dedicated communications network.

At the same time, you yourself become a telecom operator.

Well, of course, the final nail in the lid of your coffin is the moment when you begin to provide services to the population, for example, in transferring data from water meters and electricity meters. The excuses here you can come up with the same ones - as long as you provide the service in its entirety, this can be called your technological network; as soon as your users start to drive arbitrary data on your network in arbitrary directions - you become a public communication network.

Avoid this if possible.

Firstly, because you yourself at the same time turn into a telecom operator with all associated legal costs (this is, for a second, a licensed scope). Secondly, because the equipment of public communication networks is subject to certification - more precisely, a certificate must be obtained for switching equipment (i.e. base stations), and a declaration of conformity must be registered for terminal equipment.

Guess if there is a technical regulation for the same LoRaWAN, compliance with which could be declared.

So what do we have in simple terms?

1. SCRF decision did not change absolutely nothing
2. LPWAN equipment operating at the end user does not need to be registered if it does not go beyond 864-865 and 868.7-869.2 MHz and 25 mW;
3. Attention! Devices operating in the new 866-868 MHz band or with a power of 100 mW in the upper section of the old band are subject to registration, regardless of their purpose and use!
4. when building a technological communication network for a particular enterprise, you can refer to the fact that all the equipment works with the end user, see above
5. as soon as you take out the base stations from your user's private territory to a pole on the street or unzip them to the now allowed 100 mW power - they need to be registered
6. at the moment when you connect a second client to your network, you begin to claim the transition to the “telecom operator” category, but if you observe some decencies, you can still excuse yourself with the fact that this is your technological network
7. at the moment when your clients get access to transferring arbitrary data in any direction, for example, by redirecting your data from your LoRaWAN NS to a third-party Application Server, you become a communication operator with all the related regalia and obligations

That is, all this order existed before the fresh decision of the State Committee for Emergency Situations, just all of it for the most part ignored it.

It should be noted that as a result of all the drilling , a ILV letter came out explaining what was meant. Why it was impossible to start and end with such a letter, and why was all this fuss with the State Committee for Radio Frequency, changing nothing in the order of things - a mystery of the universe, comparable to other eternal questions of the Universe.



Because.

Base stations of Russian production

From December 1, 2020, base stations manufactured in the Russian Federation that are assigned the status of telecommunication equipment of Russian origin are allowed (the condition does not apply to base stations registered before December 1, 2020)

Although this moment made much more noise, the meaning in it is even less.

Firstly, this is not a prohibitive measure, but a permissive one - you can use base stations of Russian manufacture.

Secondly, it was not possible to find a valid ban on the use of Russian-made base stations, but, just in case, if you want the absolute legal purity of your project, you can before December 1, 2020, i.e. the entry into force of a permit to refuse to use Russian base stations that have been assigned a status hereinafter.

Suddenly, there is still a ban somewhere — otherwise why would it be necessary to allow something that was not forbidden?

Instead of a conclusion

Although all this seems like some incredible nonsense, in the medium term a more sad thing may come to light - that these “decisions about nothing” were the result of an undecided struggle in government bodies, in which some wanted to push the option “this leg - who needs a leg, but it’s time to ban other legs altogether, ”while others did not want to agree to it.

As a result, such a compromise was born - it seems that something has been done, but nothing has been done.

If this conspiracy theory seems too unbelievable to you - wait for the second part, in it we will discuss the process of the birth of national standards.

And if you want to talk about this, come to our InoThings ++ conference on April 4:



Something tells me that there will be plenty of reports and discussions on the sidelines this year.

PS Read more about InoThings ++ and last year's reports here .