Following on from my comment today at ECC SE45 relating to the regulatory status of UWB may I suggest we quote exactly “recommends” 1 and 2 from ITU-R Recommendation ITU-R SM.1756 “Framework for the introduction of devices using ultra-wideband technology” in Section 9.3 “[SUMMARY OF THE COMPATIBILITY BETWEEN RLAN AND UWB]” of the draft ECC Report. I believe that this is important since it clearly represents the current regulatory environment in which UWB are able to operate.
If there are concerns from the UWB community on the regulatory status of UWB then this is not a discussion for ECC SE45, or even ECC FM57. It would seem to me that if there are attempts to elevate the status of UWB within the Radio Regulations that this needs to be initiated under WRC-19 Agenda Item 10 to secure approval for work to be undertaken in the context of WRC-2023. That said, I suspect there will be sustained opposition if such a proposal was made.
Of course I have no objection for material to be included under “9.1 [INTERFERENCE FROM RLAN INTO UWB]” and/or “9.2 [INTERFERENCE FROM UWB INTO RLAN]” which would be for information only and should not be used to justify a revision of the regulatory status of UWB. It is the current global regulatory conditions for UWB that are important to reference and, as stated previously, I believe we should reflect this in Section 9.3 “[SUMMARY OF THE COMPATIBILITY BETWEEN RLAN AND UWB]”.
Please also note that within CEPT, UWB is regarded as a short-range device and consequently cannot claim protection from any other service operating in the same frequency range as the UWB devices and shall not cause interference to any other service operating in the same frequency band. Attention is further drawn to the European Commission Decision (2007/131/EC) which states in whereas -
“The use of radio spectrum by equipment using ultrawideband technology under this Decision is to be allowed on a non-interference and non-protected basis and therefore should be subject to Article 5(1) of Directive 2002/20/EC of the European Parliament and of the Council of 7 March 2002 on the authorisation of electronic communications networks and services”
and in article 2(2):-
“non-interference and non-protected basis’ means that no harmful interference may be caused to any radiocommunication service and that no claim may be made for protection of these devices against harmful interference originating from radiocommunication services”
The text from ITU-R Recommendation ITU-R SM.1756 “Framework for the introduction of devices using ultra-wideband technology” is as follows -
recommends
1 that the framework contained in Annex 1 to this Recommendation should be used as a guide by administrations when considering the introduction of devices using UWB technology and their impact on radiocommunication services;
2 that the following Notes will be considered as part of this Recommendation.
NOTE 1 – Administrations authorizing or licensing devices using UWB technology should ensure, pursuant to the provisions of the RR, that these devices do not cause interference to and do not claim protection from, or place constraints on, the radiocommunication services of other administrations as defined in the RR and operating in accordance with those Regulations.
NOTE 2 – Upon receipt of a notice of interference to the radiocommunication services referred to in Note 1, above, from devices using UWB technology, administrations should take immediate action(s) to eliminate such interference.
I propose that the following text is included in Section 9.3 “[SUMMARY OF THE COMPATIBILITY BETWEEN RLAN AND UWB]” –
Within CEPT, UWB is regarded as a short-range device and consequently cannot claim protection from any other service operating in the same frequency range as the UWB devices and shall not cause interference to any other service operating in the same frequency band. The European Commission Decision (2007/131/EC) states -
“The use of radio spectrum by equipment using ultrawideband technology under this Decision is to be allowed on a non-interference and non-protected basis and therefore should be subject to Article 5(1) of Directive 2002/20/EC of the European Parliament and of the Council of 7 March 2002 on the authorisation of electronic communications networks and services”
and in article 2(2):-
“non-interference and non-protected basis’ means that no harmful interference may be caused to any radiocommunication service and that no claim may be made for protection of these devices against harmful interference originating from radiocommunication services”
At a global level within the Radio Regulations the ITU-R Recommendation ITU-R SM.1756 “Framework for the introduction of devices using ultra-wideband technology” in “recommends 2” states -
2 that the following Notes will be considered as part of this Recommendation.
NOTE 1 – Administrations authorizing or licensing devices using UWB technology should ensure, pursuant to the provisions of the RR, that these devices do not cause interference to and do not claim protection from, or place constraints on, the radiocommunication services of other administrations as defined in the RR and operating in accordance with those Regulations.
NOTE 2 – Upon receipt of a notice of interference to the radiocommunication services referred to in Note 1, above, from devices using UWB technology, administrations should take immediate action(s) to eliminate such interference.
Material included under “9.1 [INTERFERENCE FROM RLAN INTO UWB]” and/or “9.2 [INTERFERENCE FROM UWB INTO RLAN]” would be for information only and should not be used to justify a revision of the regulatory status of UWB.
………………………………………………..
