leemoore1966 wrote:Marvin wrote:Totally agree, differences of opinion - nothing personal and no malice intended
Thx
Lee
Yes, concur totally, debate is exceptionally useful and forms the basis of peer review
On the reference to ground based activities then my understanding was that 863-870MHz was always for Short Range Devices (SRDs) which are essentially low power radio communications systems. ETSI state that typically, the range of an SRD is a few cm up to 100 metres. Car key fobs and wireless alarms are examples of SRDs, as are Bluetooth and WiFi devices. RFID systems are also SRDs. (
http://www.etsi.org)
Generally SRDs operate licence free in Europe. To be allowed this freedom of use, SRDs must inherently be devices that have a low capacity to cause interference to other radiocommunications. This is ensured by conformance to the relevant ETSI standards.
The low capacity to cause interference allows SRDs to coexist with other radio communications services. Consequently, SRD are permitted to operate in a number of bands across the radio spectrum. (
http://www.etsi.org)
SRDs can be mass market devices or highly specialised technologies. There is a high degree of spectrum harmonisation across Europe for these devices. In most cases, once conformance with the standard has been demonstrated, a device can be used freely throughout Europe, with no need for an end user licence or any paperwork.(
http://www.etsi.org)
The European Commission and the European Conference of Postal and Telecommunications (CEPT) SRD Recommendation categorises SRDs as follows:
• Non-specific Short Range Devices
• Tracking, Tracing and Data Acquisition
• Wideband Data Transmission systems
• Railway applications
• Road Transport and Traffic Telematics (RTTT)
• Radiodetermination applications
• Alarms
• Model Control
• Inductive applications
• Radio microphones and Assistive Listening Devices
• Radio frequency identification applications
• Active Medical Implants and their associated peripherals
• Wireless Audio Applications
Source
http://www.etsi.orgOFCOM describe the 868-870MHz as the ‘high band’ and include a similar list of similar devices.
(
https://www.ofcom.org.uk/__data/assets/ ... report.pdf)
In the ‘mid band’ of 865-868MHz they do include ‘asset tracking’ and I do remember reading somewhere that FLARM had sought to use this definition. I just can’t find that reference! But my understanding of what they meant by asset tracking is the use of RFID tags on high value shop goods?
So in the list above I cannot see airborne collision avoidance and so whilst both FLARM and PAW appear to conform to ETSI EN 300 220, they don’t seem to have fully met the CEPT SRD recommended uses. All of these uses seem to me to be ground based only? Now I’m
not saying that PAW is doing anything against the regulations, but this is where my hunch comes in that using a band not reserved for aviation activities may not be as safe a bet as some might think. Removal of spectrum or change of use does happen from time to time and all I can offer in defence of my point of view is that 1090 is a very established use and would be hard to wrestle away from aviation - ADS-B devices, transponders, secondary RADARs and TCAS would all need to be “booted off” with lots of expensive mods to the global aircraft fleet.
Best
Gaz
PS. Congrats on the 72x OGN-R stations, that is quite some achievement.