The new decision language is basically unchanged from when it was first adopted in 2007 by my reading.
Here’s the language from 2007:
https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32007D0131
The Member States shall, as early as possible and no later than six months following the entry into force of this Decision, allow the use of the radio spectrum on a non-interference and non-protected basis by equipment using ultra-wideband technology provided that such equipment meets the conditions set out in the Annex to this Decision and it is either used indoors or, if it is used outdoors, it is not attached to a fixed installation, a fixed infrastructure, a fixed outdoor antenna, or an automotive or railway vehicle.
Here’s the language from the recent decision you referenced:
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019D0785
Within six months after this Decision takes effect, Member States shall designate and make available the radio spectrum, on a non-interference and non-protected basis, for equipment using ultra-wideband technology provided that such equipment meets the conditions set out in the Annex and it is used indoors or, if it is used outdoors, it is not attached to a fixed installation, a fixed infrastructure or a fixed outdoor antenna. Equipment using ultra-wideband technology which meets the conditions set out in the Annex shall also be allowed in motor and railway vehicles.
The change seems to be allowing use in motor and railway vehicles which was from a decision in 2014 as best I can tell.
I’m no expert in EU law, but whatever mechanism allowed LT2 seems to be unchanged by this new decision. I’m not sure how LT2 is allowed, but it must be by some mechanism separately from these documents.
Here is some background on LT2 systems from 2011:
Somehow that report’s objective to enable LT2 systems became codified in EN 302 065-2. I don’t know how that came to be, but EN 302 065-2 clearly allows fixed outdoor operation of LT2 systems (as well as the also mentioned LAES systems).
My understanding is that you can be compliant under EITHER EN 302-065-1 or EN 302-065-2. It is up to you to select which rule you operate under.
In my opinion, if you fall under EN 302 065-1, generic UWB applications, you should do so. This means indoor, no aviation, 6.0 to 8.5 GHz band. The mere fact your packets create timing that you could use to locate doesn’t negate using EN 302 065-1 which gives no limitation on what the packets are used for.
Indeed, the more unclear question is whether a system under EN 302 065-2 can be allowed to carry non location information such as serial number, sensor data, etc. That use is not specifically allowed under EN 302 065-2, nor specifically disallowed, but it seems logical such use is allowed and I would interpret it that way as well.
Use on road and rail is governed by EN 302 065-3:
My brief reading of it suggests the only real change from LT1 is limiting to -51.3 dBm/MHz strength without LDC, or -41.3 dBm/MHz with LDC. Basically this means road and rail systems have to be low duty cycle to use “full” power.
Mike Ciholas, President, Ciholas, Inc
3700 Bell Road, Newburgh, IN 47630 USA
mikec@ciholas.com
+1 812 962 9408