Canadian Regulations for Devices using UWB technology

[color=#333333][font=Helvetica, Arial, sans-serif][size=small]Hello Everyone,[/size][/font][/color]

[color=#333333][font=Helvetica, Arial, sans-serif][size=small]This thread is in regards to the Canadian regulations for devices using UWB technology as part of the Canadian Radio Standards Specification. The document RSS-220 can be found in its entirety at the the following address: https://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf09347.html[/size][/font][/color]

[color=#333333][font=Helvetica, Arial, sans-serif][size=small]I can not attach the pdf doc as the government link is currently broken.[/size][/font][/color]

[color=#333333][font=Helvetica, Arial, sans-serif][size=small]The document was recently amended in the section of vehicular radar devices and released this past month, July 2018.[/size][/font][/color]

[color=#333333][font=Helvetica, Arial, sans-serif][size=small]Pardon my ignorance but section 5 is what caught my attention and raised my concern that these regs may be cause for serious concern when planning to implement UWB tech in any system.[/size][/font][/color]

[color=#333333][font=Helvetica, Arial, sans-serif][size=small]As I understand Decawave is currently in the process of trying to certify their modules with the FCC and are also learning as they go. I am not very well versed in such affairs as obtaining certs etc. from government orgs. However, maybe some of you are or have a much better understanding as to the ‘meaning’ of the Canadian regs and what appears to be very limiting regs as read in my layman’s terms, specifically in regards to section 5 (copied and pasted below). [/size][/font][/color]

[color=#333333][font=Helvetica, Arial, sans-serif][size=small]Section 5.1.1 states: The -10 dB bandwidth of the device shall be totally contained in the band 3.1-10.6 GHz.[/size][/font][/color]

[color=#333333][font=Helvetica, Arial, sans-serif][size=small] I believe both DWM1000 and DWM1001 modules fall within the spec. However, please correct me if I am wrong.[/size][/font][/color]

[color=#333333][font=Helvetica, Arial, sans-serif][size=small]Section 5.1.2 states: The antenna of the UWB device shall be factory-installed and shall not be made modifiable by users. [/size][/font][/color]

[color=#333333][font=Helvetica, Arial, sans-serif][size=small] This seems straightforward enough but then we get into…[/size][/font][/color]

[color=#333333][font=Helvetica, Arial, sans-serif][size=small]Section 5.2.1.1 states: Indoor UWB communications devices, by the nature of their design, shall be capable of operation only indoors or in locations completely enclosed by walls and a ceiling. The necessity to operate within a fixed indoor infrastructure (e.g., a transmitter that must be connected to the AC power lines, an enclosure that is not weatherproof, etc.) may be considered sufficient to meet this requirement.[/size][/font][/color]

[color=#333333][font=Helvetica, Arial, sans-serif][size=small] …OK, then,[/size][/font][/color]

[color=#333333][font=Helvetica, Arial, sans-serif][size=small]Section 5.3.1 for hand-held communication devices goes onto state:[/size][/font][/color]

[list=1]
[*]The device shall be designed so as to prevent its connection to antennas mounted on outdoor structures, e.g., antennas mounted on the outside of a building or on a telephone pole, or any fixed outdoors infrastructure.

[*]The device is to transmit only when it is sending information to an associated receiver. The device shall cease transmission of information within 10 seconds unless it receives an acknowledgement from the associated receiver that its transmission is being received. An acknowledgment of reception must continue to be received by the UWB device at least every 10 seconds or the UWB device shall cease transmitting any information other than periodic signals used for the establishment or re-establishment of a communication link with an associated receiver.
[/list]

Again, pardon my ignorance, but if these regulations are as I understand them, devices using UWB technology in Canada will have severe limitations especially in regards to developing any RTLS system for any OUTSIDE use if tags are not allowed to connect to anchor nodes mounted on any fixed outdoor structures???

Maybe I misunderstand, but appreciate any and all comments especially from anyone from Decawave. Thanks.

Section 5 in its entirety is pasted below:

[color=#333333][size=x-large][font=Helvetica, Arial, sans-serif]5. Communication Devices Using UWB Technology[/font][/size][/color]
[color=#333333][size=large][font=Helvetica, Arial, sans-serif]5.1 General Requirements and Specifications[/font][/size][/color]
[color=#333333][size=medium][font=Helvetica, Arial, sans-serif]The following general provisions apply to both indoor and hand-held communication devices.[/font][/size][/color]
[list=1]

[*]The -10 dB bandwidth of the device shall be totally contained in the band 3.1-10.6 GHz.

[*]The antenna of the UWB device shall be factory-installed and shall not be made modifiable by users.
[/list][color=#333333][size=large][font=Helvetica, Arial, sans-serif]5.2 Indoor Communication Devices[/font][/size][/color]
[color=#333333][size=medium][font=Helvetica, Arial, sans-serif]Indoor communications device: a device designed to transfer voice or data information, to detect the location of tags, or to serve as an underground field disturbance sensor.[/font][/size][/color]
[color=#333333][size=large][font=Helvetica, Arial, sans-serif]5.2.1 Standard Specifications[/font][/size][/color]
[list=1]

[*]Indoor UWB communications devices, by the nature of their design, shall be capable of operation only indoors or in locations completely enclosed by walls and a ceiling. The necessity to operate within a fixed indoor infrastructure (e.g., a transmitter that must be connected to the AC power lines, an enclosure that is not weatherproof, etc.) may be considered sufficient to meet this requirement.

[*]AC line-conducted emissions from the device shall comply with the limits for AC line-conducted emissions set out in RSS-Gen.

[*]Radiated emissions at or below 960 MHz from a device shall not exceed the limits in section 3.4.

[*]Radiated emissions above 960 MHz from a device shall not exceed the following average limits when measured using a resolution bandwidth of 1 MHz.

[size=small]Indoor Communication, Measurement, Location Sensing and Tracking DevicesFrequency
E.i.r.p. in a Resolution Bandwidth of 1 MHz960-1 610 MHz
-75.3 dBm
1.61-4.75 GHz
-70.0 dBm
4.75-10.6 GHz
-41.3 dBm
Above 10.6 GHz
-51.3 dBm[/size]

[*]In addition to the limits specified in paragraph (d) of this section, radiated emissions shall not exceed the following average limits when measured using a resolution bandwidth greater than or equal to 1 kHz. The measurements shall demonstrate compliance with the stated limits at whatever resolution bandwidth is used.

[size=small]Indoor Communication Devices - Standard SpecificationsFrequency
E.i.r.p. in a Resolution Bandwidth of no less than 1 kHz1 164-1 240 MHz
-85.3 dBm
1 559-1 610 MHz
-85.3 dBm[/size]

[*]Within the tables in paragraphs (d) and (e) above, the tighter emission limit applies at the band edges.

[*]The peak level of the transmissions shall not exceed the peak equivalent of the average limit contained within any 50 MHz bandwidth, as defined in section 4 of the Annex.
[/list][color=#333333][size=large][font=Helvetica, Arial, sans-serif]5.3 Hand-held Communication Devices[/font][/size][/color]
[color=#333333][size=medium][font=Helvetica, Arial, sans-serif]Hand-held communications device: a device used to transfer voice or data information or designed to detect the location of tags.[/font][/size][/color]
[color=#333333][size=large][font=Helvetica, Arial, sans-serif]5.3.1 Standard Specifications[/font][/size][/color]
[list=1]

[*]The device shall be designed so as to prevent its connection to antennas mounted on outdoor structures, e.g., antennas mounted on the outside of a building or on a telephone pole, or any fixed outdoors infrastructure.

[*]The device is to transmit only when it is sending information to an associated receiver. The device shall cease transmission of information within 10 seconds unless it receives an acknowledgement from the associated receiver that its transmission is being received. An acknowledgment of reception must continue to be received by the UWB device at least every 10 seconds or the UWB device shall cease transmitting any information other than periodic signals used for the establishment or re-establishment of a communication link with an associated receiver.

[*]Radiated emissions at or below 960 MHz from a device shall not exceed the limits in section 3.4.

[*]Radiated emissions above 960 MHz from a device shall not exceed the following average limits when measured using a resolution bandwidth of 1 MHz.

[size=small]Hand-held (Outdoor) Communication, Measurement, Location Sensing, and Tracking DevicesFrequency
E.i.r.p. in a Resolution Bandwidth of 1 MHz960-1 610 MHz
-75.3 dBm
1.61-4.75 GHz
-70.0 dBm
4.75-10.6 GHz
-41.3 dBm
Above 10.6 GHz
-61.3 dBm[/size]

[*]In addition to the limits specified in paragraph (d) of this section, radiated emissions shall not exceed the following average limits when measured using a resolution bandwidth greater than or equal to 1 kHz. The measurements shall demonstrate compliance with the stated limits at whatever resolution bandwidth is used.

[size=small]Hand-held Communication Devices - Standard SpecificationsFrequency
E.i.r.p. in a Resolution Bandwidth of no less than 1 kHz1 164-1 240 MHz
-85.3 dBm
1 559-1 610 MHz
-85.3 dBm[/size]

[*]Within the tables in paragraphs (d) and (e) above, the tighter emission limit applies at the band edges.

[*]The peak level of the transmissions shall not exceed the peak equivalent of the average limit contained within any 50 MHz bandwidth, as defined in section 4 of the Annex.
[/list]

The standard makes sense as far as it goes.
Devices classed as handheld can not be permanently mounted to poles.
Devices classed as indoor are for indoor use only.

The issue looks to be that the standard has a big hole in it, it doesn’t appear to cover tracking systems for outdoor use. It doesn’t even mention the possibility that one could exist.

I don’t know much about this either, but it sounds similar to the FCC rules in the US.

From my understanding, an outdoor UWB network must operate without a fixed infrastructure. Meaning you couldn’t permanently mount UWB transceivers in fixed positions outdoors to set up an RTLS system for an open field, for example.

I don’t know why… Can anyone clarify this?

Likely has to do with spectrum licensing, I believe there is licensing considerations for both indoor / outdoor and there seems to be some reserved range for satellites around 6.5 Ghz. Likely easier for them to get the indoor regulations passed.