Sovereign LPWAN, part 1: licensing and operation of LPWAN networks in Russia - the old new requirements of the GKRCh
Hi, Habr!
At the end of last year, the websites, blogs and channels involved in the “Internet of Things” shook the news - allegedly GKRCh made a decision according to which the base stations of any IoT LPWAN networks should only be Russian-made, and must be registered when they are installed.
Base station LoRaWAN Russian production
Although for the most popular of the open technologies - LoRaWAN - Russian BSs quite exist for themselves, this is, for example, the Novosibirsk-based Vega BS-2, the news caused many serious excitement. First of all, you won't be full of one Vega, Kerlink, Multitech and even Sagemcom also sometimes feel like it. Secondly, well, today, everyone is building LoRaWAN, and tomorrow? Such a solution would simply close 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 until the payback and prospects are somehow clear.
However, in reality, as usual with Russian legislation, owls are not what they seem.
Let's figure it out.
First, the notorious decision of the SCRF in the original - here it is necessary to scroll immediately to the end, to paragraph 22.
The decision of the SCR 2007 is a general table on the use of short-range transceivers, to which dozens of additions and refinements have been issued: for example, when the SCRF decides to give some new frequencies to someone in this class of devices, the decision about this also goes additions to 07-20-03-001.
The duration of the basic decision of the SCRF is 10 years, however, obviously, the 2007 decision on the deadline was simply extended by another ten.
So what we see here?
My selection. As it is easy to notice, the GKRCH does not indicate a newly arisen duty to license or register something - the GKRCH indicates that the legislation of the Russian Federation must be observed, that is, in fact, acts as the Captain Obvious.
The purpose for which this amendment was adopted is difficult to understand (it is likely that from a purely political, “it was necessary to demonstrate the work”), because in fact it does not change anything at all. Someone does not agree with the fact that the laws must be respected? Can't see your hands?
To change the laws of the SCRF is not strong enough; it is beyond its authority.
Does this mean that base stations do not need to be registered? Wait a minute!
So, as we found out, the laws have not changed. But, actually, what was written in them before?
Firstly, traditionally for Russian technological legislation, which very often represents a hasty tracing paper from the international one, “there is a word - and there is no term”. That is, the word "base station" is, and what they mean is not directly stated anywhere. My home Wi-Fi router, which provides subscriber devices with access to a public communication network - is this a base station or not yet?
Here we can refer to another document, called Exemption from the list of radio-electronic means and high-frequency devices to be registered , and specifically to item 22:
Three points can be noticed here - firstly, for the legislators, the expansion of the range of 866-868 MHz by the SCRF went 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 it, although in general they can formally - so if legal purity is important to you, do not rush to tune up new frequencies in your network with joy.
Secondly, the power is limited to 25 mW. In the autumn, the SCRF allowed in the 868.7-869.2 MHz band a power of up to 100 mW - so, such devices must be registered regardless of their purpose.
Thirdly, the term “base station” did not get any better, but on the other hand, we met the term “finished devices” - and we can assume that all that was not they was the base station. Well, or not the base station, but all need to register one.
Ok, Yandex, what are “end devices”? .. Here the third NPA, 126-ФЗ “ About communication ”, helps us out:
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 controller of "smart home" and other household things.
With LPWAN base stations, however, things are a bit more complicated - they are obviously usually in the use of a telecom operator, respectively, and the final equipment is not.
And here we smoothly proceed to the next item - “ commissioning of communication networks in the manner established in the Russian Federation ”, which is indirectly related to the question of whose equipment is in use.
As the same 126-FZ says, we have the following types of communication networks:
The last two points do not concern us now, but we need to deal with the rest again.
Let's start from the end. Technological communication networks are, obviously, communication networks of the scale of a single enterprise ; on such networks the provision of services to any third parties is not carried out. For example, if you implement an individual “digital something” project for an industrial customer, and in this project there are LPWAN base stations in any of its forms - then in essence you are building a technological communications network for this customer.
If you build a network to which several customers can connect - for example, you cover the industrial zone with LoRaWAN, and on the basis of this LoRaWAN you offer enterprises “digital something” based on your own resources, in the industrial zone, then you start moving 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 purchases from you services not for access to the data network, but for example, for access to a personal account in which some information collected through this network is accumulated.
This excuse is collapsing at the moment when you allow the customer, for example, to put his own server with his own personal accounts, and through your LoRaWAN to simply push data to it - even if he previously bought this server from you, he now 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 communication network.
At the same time you yourself become a telecom operator.
Well and, of course, the final nail in the lid of your coffin is the moment when you begin to provide services to the public, for example, to transfer data from water meters and electricity meters. Excuses here can come up with the same - as long as you provide the service entirely, you can call it your technological network; As soon as your users begin to drive arbitrary data on your network in arbitrary directions, you become a public communication network.
If possible, avoid this.
First, because you yourself turn into a telecom operator with all the associated legal costs (this is, for a moment, the licensed scope). Secondly, because the equipment of public communication networks is subject to certification - more precisely, it is necessary to obtain a certificate for switching equipment (i.e., base stations), and to register a declaration of conformity 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 if we speak in simple words?
That is, the whole of this order existed even before the fresh decision of the SCRF, it was just that everyone mostly ignored it.
It should be noted that as a result of all the confusion , a letter from the RKN was issued , explaining what was meant. Why it was impossible to start and finish with such a letter, and why there was all this fuss with the GKRCH, which does not change anything in the order of things - the mystery of the universe, comparable to other eternal questions of the Universe.
Because.
Although this moment has done significantly more noise, the meaning in it turns out to be even less.
Firstly, it is not a prohibitive measure, but a permissive measure - Russian-made base stations can be used.
Secondly, it was not possible to find a valid ban on the use of base stations of Russian production, but just in case you want absolute legal purity of your project, you can until December 1, 2020, i.e. the entry into force of the permit, to refuse from the use of Russian base stations, which have been granted status and hereinafter.
Suddenly, this prohibition is still somewhere somewhere - otherwise why was it necessary to allow something that was not prohibited?
Although all this seems to be some kind of incredible nonsense, in the medium term, the saddest thing may turn out to be that these “decisions about anything” were the result of a cunning struggle in state bodies, in which some wanted to push the option “this leg - who needs a leg, but it would be time to ban other legs ”, while others did not want to agree with him.
As a result, such a compromise was born - something seems to be done, but nothing has been done.
If this conspiracy theory seems too unbelievable to you - wait for the second part, we will discuss the process of the birth of national standards in it.
And if you want to talk about it - come to us at the InoThings ++ conference on April 4:
Something tells me that the reports and discussions on this topic on the sidelines this year will be abundant.
PS Read more about InoThings ++ and last year’s reports here .
At the end of last year, the websites, blogs and channels involved in the “Internet of Things” shook the news - allegedly GKRCh made a decision according to which the base stations of any IoT LPWAN networks should only be Russian-made, and must be registered when they are installed.
Base station LoRaWAN Russian production
Although for the most popular of the open technologies - LoRaWAN - Russian BSs quite exist for themselves, this is, for example, the Novosibirsk-based Vega BS-2, the news caused many serious excitement. First of all, you won't be full of one Vega, Kerlink, Multitech and even Sagemcom also sometimes feel like it. Secondly, well, today, everyone is building LoRaWAN, and tomorrow? Such a solution would simply close 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 until the payback and prospects are somehow clear.
However, in reality, as usual with Russian legislation, owls are not what they seem.
Let's figure it out.
First, the notorious decision of the SCRF in the original - here it is necessary to scroll immediately to the end, to paragraph 22.
22. In Appendix No. 11 to the decision of the State Committee of the Radio frequency Committee dated 07.05.2007 No. 07-20-03-001, the column “Additional conditions of use” for the radio frequency bands 864-865 MHz, 866-868 MHz, 868.7-869.2 MHz shall be added as follows 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 of communication networks in the manner established in the Russian Federation;
From December 1, 2020, it is allowed to use base stations manufactured in the territory of the Russian Federation, which have been assigned the status of telecommunication equipment of Russian origin (the condition does not apply to base stations registered before December 1, 2020). ”.
The decision of the SCR 2007 is a general table on the use of short-range transceivers, to which dozens of additions and refinements have been issued: for example, when the SCRF decides to give some new frequencies to someone in this class of devices, the decision about this also goes additions to 07-20-03-001.
The duration of the basic decision of the SCRF is 10 years, however, obviously, the 2007 decision on the deadline was simply extended by another ten.
So what we see here?
LPWAN base station registration
registration of base stations in the manner established in the Russian Federation ;
commissioning of communication networks in the manner established in the Russian Federation ;
My selection. As it is easy to notice, the GKRCH does not indicate a newly arisen duty to license or register something - the GKRCH indicates that the legislation of the Russian Federation must be observed, that is, in fact, acts as the Captain Obvious.
The purpose for which this amendment was adopted is difficult to understand (it is likely that from a purely political, “it was necessary to demonstrate the work”), because in fact it does not change anything at all. Someone does not agree with the fact that the laws must be respected? Can't see your hands?
To change the laws of the SCRF is not strong enough; it is beyond its authority.
Does this mean that base stations do not need to be registered? Wait a minute!
So, as we found out, the laws have not changed. But, actually, what was written in them before?
Firstly, traditionally for Russian technological legislation, which very often represents a hasty tracing paper from the international one, “there is a word - and there is no term”. That is, the word "base station" is, and what they mean is not directly stated anywhere. My home Wi-Fi router, which provides subscriber devices with access to a public communication network - is this a base station or not yet?
Here we can refer to another document, called Exemption from the list of radio-electronic means and high-frequency devices to be registered , and specifically to item 22:
22. Non-specialized (for any purpose) terminal devices in 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 no more than minus 17 dBW;
2400 - 2483.5 MHz with an equivalent isotropic radiated power of no 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 .
Three points can be noticed here - firstly, for the legislators, the expansion of the range of 866-868 MHz by the SCRF went 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 it, although in general they can formally - so if legal purity is important to you, do not rush to tune up new frequencies in your network with joy.
Secondly, the power is limited to 25 mW. In the autumn, the SCRF allowed in the 868.7-869.2 MHz band a power of up to 100 mW - so, such devices must be registered regardless of their purpose.
Thirdly, the term “base station” did not get any better, but on the other hand, we met the term “finished devices” - and we can assume that all that was not they was the base station. Well, or not the base station, but all need to register one.
Ok, Yandex, what are “end devices”? .. Here the third NPA, 126-ФЗ “ About communication ”, helps us out:
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 controller of "smart home" and other household things.
With LPWAN base stations, however, things are a bit more complicated - they are obviously usually in the use of a telecom operator, respectively, and the final equipment is not.
And here we smoothly proceed to the next item - “ commissioning of communication networks in the manner established in the Russian Federation ”, which is indirectly related to the question of whose equipment is in use.
As the same 126-FZ says, we have the following types of communication networks:
- common use - intended for the provision of services to the unlimited circle of persons
- Dedicated - intended for the 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 need to deal with the rest again.
Let's start from the end. Technological communication networks are, obviously, communication networks of the scale of a single enterprise ; on such networks the provision of services to any third parties is not carried out. For example, if you implement an individual “digital something” project for an industrial customer, and in this project there are LPWAN base stations in any of its forms - then in essence you are building a technological communications network for this customer.
If you build a network to which several customers can connect - for example, you cover the industrial zone with LoRaWAN, and on the basis of this LoRaWAN you offer enterprises “digital something” based on your own resources, in the industrial zone, then you start moving 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 purchases from you services not for access to the data network, but for example, for access to a personal account in which some information collected through this network is accumulated.
This excuse is collapsing at the moment when you allow the customer, for example, to put his own server with his own personal accounts, and through your LoRaWAN to simply push data to it - even if he previously bought this server from you, he now 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 communication network.
At the same time you yourself become a telecom operator.
Well and, of course, the final nail in the lid of your coffin is the moment when you begin to provide services to the public, for example, to transfer data from water meters and electricity meters. Excuses here can come up with the same - as long as you provide the service entirely, you can call it your technological network; As soon as your users begin to drive arbitrary data on your network in arbitrary directions, you become a public communication network.
If possible, avoid this.
First, because you yourself turn into a telecom operator with all the associated legal costs (this is, for a moment, the licensed scope). Secondly, because the equipment of public communication networks is subject to certification - more precisely, it is necessary to obtain a certificate for switching equipment (i.e., base stations), and to register a declaration of conformity 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 if we speak in simple words?
- the decision of GKRCh did not change anything
- LPWAN equipment operating at the end user is not necessary to register, if it does not go beyond 864-865 and 868.7-869.2 MHz and 25 mW;
- Attention! Devices operating in the new 866-868 MHz band or with a power of 100 mW in the upper part of the old band are subject to registration, regardless of their purpose and use!
- when building a technological communications network for a particular enterprise, you can refer to the fact that all equipment is operated by the end user, see above
- as soon as you move the base stations from your user's private territory to a pole on the street, or raze them to the 100 mW of power that is allowed now, they must be registered
- at the moment when you connect a second client to your network, you start claiming to be transferred to the “carrier” category, but with certain decencies you can still otmazyvatsya the fact that this is your technological network
- at the moment when your clients have access to the transfer of arbitrary data in an arbitrary direction, for example, by redirecting your data from your LoRaWAN NS to a third-party Application Server, you become a telecom operator with all the associated regalia and obligations
That is, the whole of this order existed even before the fresh decision of the SCRF, it was just that everyone mostly ignored it.
It should be noted that as a result of all the confusion , a letter from the RKN was issued , explaining what was meant. Why it was impossible to start and finish with such a letter, and why there was all this fuss with the GKRCH, which does not change anything in the order of things - the mystery of the universe, comparable to other eternal questions of the Universe.
Because.
Russian base stations
From December 1, 2020, it is allowed to use base stations produced in the territory of the Russian Federation, which have been assigned the status of telecommunication equipment of Russian origin (the condition does not apply to base stations registered before December 1, 2020)
Although this moment has done significantly more noise, the meaning in it turns out to be even less.
Firstly, it is not a prohibitive measure, but a permissive measure - Russian-made base stations can be used.
Secondly, it was not possible to find a valid ban on the use of base stations of Russian production, but just in case you want absolute legal purity of your project, you can until December 1, 2020, i.e. the entry into force of the permit, to refuse from the use of Russian base stations, which have been granted status and hereinafter.
Suddenly, this prohibition is still somewhere somewhere - otherwise why was it necessary to allow something that was not prohibited?
Instead of conclusion
Although all this seems to be some kind of incredible nonsense, in the medium term, the saddest thing may turn out to be that these “decisions about anything” were the result of a cunning struggle in state bodies, in which some wanted to push the option “this leg - who needs a leg, but it would be time to ban other legs ”, while others did not want to agree with him.
As a result, such a compromise was born - something seems to be done, but nothing has been done.
If this conspiracy theory seems too unbelievable to you - wait for the second part, we will discuss the process of the birth of national standards in it.
And if you want to talk about it - come to us at the InoThings ++ conference on April 4:
Something tells me that the reports and discussions on this topic on the sidelines this year will be abundant.
PS Read more about InoThings ++ and last year’s reports here .
Source: https://habr.com/ru/post/440814/