The wireless-regdb rules for Brazil in wireless-regdb have no comment
indicating where they came from, and haven't been updated in a long
time. There have been some changes to the legislation since then,
including the addition of the 6 GHz and 60 GHz ranges.
The relevant legislation can be found in the following three URLs,
mostly the last one:
https://www.gov.br/anatel/pt-br/regulado/radiofrequencia/radiacao-restrita
https://informacoes.anatel.gov.br/legislacao/resolucoes/2017/936-resolucao-680
https://informacoes.anatel.gov.br/legislacao/atos-de-certificacao-de-produtos/2017/1139-ato-14448
In the last one, the relevant articles are:
* Article 10 is the classic wireless ranges (2.4 GHz, and 5 GHz channels
149 to 165), and the 900 MHz ranges
* Article 11 is the extended 5 GHz and 6 GHz ranges
* Article 22 is the vehicular (V2X) ranges
* Article 23 is the 60 GHz ranges
Here follows my interpretation of these rules from a wireless-regdb
point of view, with the relevant article number in parenthesis:
Other than the article 22 range (5850-5925 MHz), these rules don't
mention a max channel width, so VHT160 or even larger would be allowed
in all ranges except 5850-5925 MHz.
For ranges 902-907.5 MHz, 915-928 MHz, 2400-2483.5 MHz, and 5725-5850
MHz (article 10.1), the maximum power output in the transmitter is 1 W
(30 dBm, article 10.3.2), and the maximum antenna gain is 6 dBi (article
10.5).
For range 5150-5250 MHz (article 11.1), the maximum EIRP would be 4 W
(36 dBm, article 11.1.1), but since the smallest channel size we use in
this range is 20 MHz, and the maximum EIRP spectral density is 50 mW/MHz
(17 dBm/MHz, article 11.1.2), the maximum EIRP is 1 W (30 dBm); this
range is INDOOR-ONLY (article 11.1.3), and requires either TPC (article
11.5) or a reduction of 3 dB (article 11.5.1).
For range 5250-5350 MHz (article 11.1), the maximum EIRP is 1 W (30 dBm,
article 11.1.1); this range is INDOOR-ONLY (article 11.1.3), requires
either TPC (article 11.5) or a reduction of 3 dB (article 11.5.1), and
requires DFS (article 11.6).
For range 5470-5725 MHz (article 11.3), the maximum power output in the
transmitter is 250 mW (24 dBm, article 11.3.1), the maximum EIRP is 1 W
(30 dBm, article 11.3.2), requires either TPC (article 11.5) or a
reduction of 3 dB (article 11.5.1), and requires DFS (article 11.6).
For range 5925-7125 MHz (article 11.7), there are different rules for
APs, clients, and very low power devices. For APs (article 11.7.1), the
maximum EIRP is 30 dBm (article 11.7.1.1), and it's INDOOR-ONLY (article
11.7.1.3); for clients of an indoor AP (article 11.7.2), the maximum
EIRP is 24 dBm (article 11.7.2.1), and it's INDOOR-ONLY (article
11.7.2.3); for very low power devices (article 11.7.3), the maximum EIRP
is 17 dBm (article 11.7.3.1).
For vehicular range 5850-5925 MHz (article 22.1), the base channel width
is 10 MHz but they can be aggregated (article 22.1.1), the maximum EIRP
is 23 dBm (200 mW, article 22.2), and it requires TPC (article 22.3).
For range 57-71 GHz (article 23.1), the maximum EIRP is 40 dBm (article
23.1.1) with maximum peak 43 dBm (article 23.1.2).
I'm unsure as how to correctly represent the rules with a maximum
antenna gain in wireless-regdb. My best guess as to how these rules
would be represented in wireless-regdb, based on the US rules which have
some similar-looking ranges and power limits, would be (ignoring for now
the 900 MHz and vehicular ranges, since I'm unsure about their correct
channel widths):
# Source:
# https://www.gov.br/anatel/pt-br/regulado/radiofrequencia/radiacao-restrita
#
https://informacoes.anatel.gov.br/legislacao/resolucoes/2017/936-resolucao-680
#
https://informacoes.anatel.gov.br/legislacao/atos-de-certificacao-de-produtos/2017/1139-ato-14448
country BR: DFS-FCC
#(902 - 907.5 @ ???), (30)
#(915 - 928 @ ???), (30)
(2400 - 2483.5 @ 40), (30)
# The next three ranges have been reduced by 3dB, could be increased
back to 30dBm if TPC is implemented.
(5150 - 5250 @ 80), (27), NO-OUTDOOR, AUTO-BW
(5250 - 5350 @ 80), (27), NO-OUTDOOR, DFS, AUTO-BW
# This range ends at 5725 MHz, but channel 144 extends to 5730 MHz.
# Since 5725 ~ 5730 MHz belongs to the next range which has looser
# requirements, we can extend the range by 5 MHz to make the kernel
# happy and be able to use channel 144.
(5470 - 5730 @ 160), (27), DFS
(5730 - 5850 @ 80), (30)
# This range requires TPC.
#(5850 - 5925 @ ???), (20)
# AP 30dBm, client 24dBm
(5925 - 7125 @ 320), (24), NO-OUTDOOR
# EIRP=40dBm (43dBm peak)
(57000 - 71000 @ 2160), (40)
On a quick look, the result looks sane and makes sense to me: 1 W (30
dBm) everywhere, reduced by 3 dB on the DFS channels since TPC isn't
implemented; for 6 GHz the client is reduced by 6 dB, which is also the
case at least on the US rules according to the comment there; and 60 GHz
seems to follow everyone else in using 40 dBm.
--
Cesar Eduardo Barros
[email protected]
Em 17/08/2022 20:31, Cesar Eduardo Barros escreveu:
> For range 5925-7125 MHz (article 11.7), there are different rules for
> APs, clients, and very low power devices. For APs (article 11.7.1), the
> maximum EIRP is 30 dBm (article 11.7.1.1), and it's INDOOR-ONLY (article
> 11.7.1.3); for clients of an indoor AP (article 11.7.2), the maximum
> EIRP is 24 dBm (article 11.7.2.1), and it's INDOOR-ONLY (article
> 11.7.2.3); for very low power devices (article 11.7.3), the maximum EIRP
> is 17 dBm (article 11.7.3.1).
Thinking better about it, I might have miscalculated this one. Since the
smallest channel we use is 20 MHz, and the EIRP power density for
clients is limited to -1 dBm/MHz (article 11.7.2.2), if I'm doing the
calculations correctly the limit for clients would be 12 dBm, that is,
(5925 - 7125 @ 320), (12), NO-OUTDOOR
It's unfortunate that we cannot represent that kind of rule in db.txt,
and are forced to artificially limit the power by 12 dB (the full power
of 24 dBm I had calculated would work only for 320 MHz).
I would appreciate if you could look over these power density rules,
especially the ones which are in dBm/MHz instead of mW/MHz, since I
might have miscalculated something else.
--
Cesar Eduardo Barros
[email protected]
Em 17/08/2022 21:07, Cesar Eduardo Barros escreveu:
> Em 17/08/2022 20:31, Cesar Eduardo Barros escreveu:
>> For range 5925-7125 MHz (article 11.7), there are different rules for
>> APs, clients, and very low power devices. For APs (article 11.7.1),
>> the maximum EIRP is 30 dBm (article 11.7.1.1), and it's INDOOR-ONLY
>> (article 11.7.1.3); for clients of an indoor AP (article 11.7.2), the
>> maximum EIRP is 24 dBm (article 11.7.2.1), and it's INDOOR-ONLY
>> (article 11.7.2.3); for very low power devices (article 11.7.3), the
>> maximum EIRP is 17 dBm (article 11.7.3.1).
>
> Thinking better about it, I might have miscalculated this one. Since the
> smallest channel we use is 20 MHz, and the EIRP power density for
> clients is limited to -1 dBm/MHz (article 11.7.2.2), if I'm doing the
> calculations correctly the limit for clients would be 12 dBm, that is,
>
> (5925 - 7125 @ 320), (12), NO-OUTDOOR
>
> It's unfortunate that we cannot represent that kind of rule in db.txt,
> and are forced to artificially limit the power by 12 dB (the full power
> of 24 dBm I had calculated would work only for 320 MHz).
>
> I would appreciate if you could look over these power density rules,
> especially the ones which are in dBm/MHz instead of mW/MHz, since I
> might have miscalculated something else.
>
And thinking even more about it, if I'm understanding article 11.7.10
correctly, a client can transmit only when associated to an AP, except
for the negotiation while joining the AP. I believe this corresponds to
NO-IR, so the correct line for that range would be:
(5925 - 7125 @ 320), (12), NO-OUTDOOR, NO-IR
--
Cesar Eduardo Barros
[email protected]
On Wed, Aug 17, 2022 at 08:31:56PM -0300, Cesar Eduardo Barros wrote:
> The wireless-regdb rules for Brazil in wireless-regdb have no comment
> indicating where they came from, and haven't been updated in a long time.
> There have been some changes to the legislation since then, including the
> addition of the 6 GHz and 60 GHz ranges.
>
> The relevant legislation can be found in the following three URLs, mostly
> the last one:
>
> https://www.gov.br/anatel/pt-br/regulado/radiofrequencia/radiacao-restrita
>
> https://informacoes.anatel.gov.br/legislacao/resolucoes/2017/936-resolucao-680
>
> https://informacoes.anatel.gov.br/legislacao/atos-de-certificacao-de-produtos/2017/1139-ato-14448
Thanks for the information, and sorry for the slow response. I have
limited time to review changes, and this one took a while.
I provide more detailed responses below, but in general I think your
suggested changes look correct.
> In the last one, the relevant articles are:
>
> * Article 10 is the classic wireless ranges (2.4 GHz, and 5 GHz channels 149
> to 165), and the 900 MHz ranges
> * Article 11 is the extended 5 GHz and 6 GHz ranges
> * Article 22 is the vehicular (V2X) ranges
> * Article 23 is the 60 GHz ranges
>
>
> Here follows my interpretation of these rules from a wireless-regdb point of
> view, with the relevant article number in parenthesis:
>
> Other than the article 22 range (5850-5925 MHz), these rules don't mention a
> max channel width, so VHT160 or even larger would be allowed in all ranges
> except 5850-5925 MHz.
>
> For ranges 902-907.5 MHz, 915-928 MHz, 2400-2483.5 MHz, and 5725-5850 MHz
> (article 10.1), the maximum power output in the transmitter is 1 W (30 dBm,
> article 10.3.2), and the maximum antenna gain is 6 dBi (article 10.5).
Seems right.
> For range 5150-5250 MHz (article 11.1), the maximum EIRP would be 4 W (36
> dBm, article 11.1.1), but since the smallest channel size we use in this
> range is 20 MHz, and the maximum EIRP spectral density is 50 mW/MHz (17
> dBm/MHz, article 11.1.2), the maximum EIRP is 1 W (30 dBm); this range is
> INDOOR-ONLY (article 11.1.3), and requires either TPC (article 11.5) or a
> reduction of 3 dB (article 11.5.1).
This also seems right.
> For range 5250-5350 MHz (article 11.1), the maximum EIRP is 1 W (30 dBm,
> article 11.1.1); this range is INDOOR-ONLY (article 11.1.3), requires either
> TPC (article 11.5) or a reduction of 3 dB (article 11.5.1), and requires DFS
> (article 11.6).
Correct.
> For range 5470-5725 MHz (article 11.3), the maximum power output in the
> transmitter is 250 mW (24 dBm, article 11.3.1), the maximum EIRP is 1 W (30
> dBm, article 11.3.2), requires either TPC (article 11.5) or a reduction of 3
> dB (article 11.5.1), and requires DFS (article 11.6).
Correct.
> For range 5925-7125 MHz (article 11.7), there are different rules for APs,
> clients, and very low power devices. For APs (article 11.7.1), the maximum
> EIRP is 30 dBm (article 11.7.1.1), and it's INDOOR-ONLY (article 11.7.1.3);
> for clients of an indoor AP (article 11.7.2), the maximum EIRP is 24 dBm
> (article 11.7.2.1), and it's INDOOR-ONLY (article 11.7.2.3); for very low
> power devices (article 11.7.3), the maximum EIRP is 17 dBm (article
> 11.7.3.1).
Right, so in this case it's possible to use either 24 dBm, NO-OUTDOOR or
17 dBm and allow outdoor use. We've used the higher, indoor-only rule in
the past. But as you note in your replies there is a PSD limit for
clients which limits power to 12 dBm (since PSD limits are not currently
supported) and it needs NO-IR.
> For vehicular range 5850-5925 MHz (article 22.1), the base channel width is
> 10 MHz but they can be aggregated (article 22.1.1), the maximum EIRP is 23
> dBm (200 mW, article 22.2), and it requires TPC (article 22.3).
Looking at the documents you provided and [1], the only allowed use of
this range is for vehicle communication systems and not for WLAN. Unless
I missed something, I think this range should be left out of the
database.
[1] https://informacoes.anatel.gov.br/legislacao/atos-de-certificacao-de-produtos/2020/1467-ato-4776
> For range 57-71 GHz (article 23.1), the maximum EIRP is 40 dBm (article
> 23.1.1) with maximum peak 43 dBm (article 23.1.2).
Correct.
> I'm unsure as how to correctly represent the rules with a maximum antenna
> gain in wireless-regdb. My best guess as to how these rules would be
> represented in wireless-regdb, based on the US rules which have some
> similar-looking ranges and power limits, would be (ignoring for now the 900
> MHz and vehicular ranges, since I'm unsure about their correct channel
> widths):
>
> # Source:
> # https://www.gov.br/anatel/pt-br/regulado/radiofrequencia/radiacao-restrita
> # https://informacoes.anatel.gov.br/legislacao/resolucoes/2017/936-resolucao-680
> # https://informacoes.anatel.gov.br/legislacao/atos-de-certificacao-de-produtos/2017/1139-ato-14448
> country BR: DFS-FCC
> #(902 - 907.5 @ ???), (30)
> #(915 - 928 @ ???), (30)
For these ranges I think you should use the same bandwidth as other
rules in the database, i.e. 2 and 16 MHz.
> (2400 - 2483.5 @ 40), (30)
> # The next three ranges have been reduced by 3dB, could be increased back
> to 30dBm if TPC is implemented.
> (5150 - 5250 @ 80), (27), NO-OUTDOOR, AUTO-BW
> (5250 - 5350 @ 80), (27), NO-OUTDOOR, DFS, AUTO-BW
> # This range ends at 5725 MHz, but channel 144 extends to 5730 MHz.
> # Since 5725 ~ 5730 MHz belongs to the next range which has looser
> # requirements, we can extend the range by 5 MHz to make the kernel
> # happy and be able to use channel 144.
> (5470 - 5730 @ 160), (27), DFS
> (5730 - 5850 @ 80), (30)
> # This range requires TPC.
> #(5850 - 5925 @ ???), (20)
This rule should be omitted.
> # AP 30dBm, client 24dBm
> (5925 - 7125 @ 320), (24), NO-OUTDOOR
This range needs the adjustments from your later emails.
> # EIRP=40dBm (43dBm peak)
> (57000 - 71000 @ 2160), (40)
Otherwise I think these changes look good. If you can send a patch with
the changes I would appreciate it, otherwise let me know and I can send
a patch.
Thanks,
Seth
> On a quick look, the result looks sane and makes sense to me: 1 W (30 dBm)
> everywhere, reduced by 3 dB on the DFS channels since TPC isn't implemented;
> for 6 GHz the client is reduced by 6 dB, which is also the case at least on
> the US rules according to the comment there; and 60 GHz seems to follow
> everyone else in using 40 dBm.
>
> --
> Cesar Eduardo Barros
> [email protected]
>
> _______________________________________________
> wireless-regdb mailing list
> [email protected]
> http://lists.infradead.org/mailman/listinfo/wireless-regdb
Em 30/08/2022 11:18, Seth Forshee escreveu:
> On Wed, Aug 17, 2022 at 08:31:56PM -0300, Cesar Eduardo Barros wrote:
>> #(902 - 907.5 @ ???), (30)
>> #(915 - 928 @ ???), (30)
>
> For these ranges I think you should use the same bandwidth as other
> rules in the database, i.e. 2 and 16 MHz.
I found only two entries in the database with rules for the 900MHz
frequencies: US and "world". I don't think the US rule is a good model
here; it can use 16 MHz because it's a contiguous range, but the range
for Brazil has a hole in the middle.
Since there's nothing that a found in these rules which mention a
maximum channel width, the correct width is probably the maximum which
fits on each piece of the range. That is,
(902 - 907.5 @ 4), (30)
(915 - 928 @ 8), (30)
As far as I could find, the hole between 907.5 and 915 exists because
there are three 2.5 MHz-wide GSM uplink channels there. However, I also
found out that there is a proposal within ANATEL (Consulta Pública 52
from 2021) to expand it with another uplink channel at 905 - 907.5
(there are actually five uplink channels in that proposal, the other one
is at 898.5 - 901). I have no idea when this will become official, or
whether it has already happened (and just wasn't reflected yet in the
restricted radiation rules I had researched), and what effect it would
have on 802.11ah users.
Given the uncertainty from that change, and given that so far there are
rules for the 900 MHz range in wireless-regdb only for the USA, it might
be wise to hold it for now and apply only the rest of the changes,
without these 900 MHz ranges.
> Otherwise I think these changes look good. If you can send a patch with
> the changes I would appreciate it, otherwise let me know and I can send
> a patch.
I will prepare a patch tomorrow.
--
Cesar Eduardo Barros
[email protected]
On Wed, Aug 31, 2022 at 11:44:17PM -0300, Cesar Eduardo Barros wrote:
> Em 30/08/2022 11:18, Seth Forshee escreveu:
> > On Wed, Aug 17, 2022 at 08:31:56PM -0300, Cesar Eduardo Barros wrote:
> > > #(902 - 907.5 @ ???), (30)
> > > #(915 - 928 @ ???), (30)
> >
> > For these ranges I think you should use the same bandwidth as other
> > rules in the database, i.e. 2 and 16 MHz.
>
> I found only two entries in the database with rules for the 900MHz
> frequencies: US and "world". I don't think the US rule is a good model here;
> it can use 16 MHz because it's a contiguous range, but the range for Brazil
> has a hole in the middle.
>
> Since there's nothing that a found in these rules which mention a maximum
> channel width, the correct width is probably the maximum which fits on each
> piece of the range. That is,
>
> (902 - 907.5 @ 4), (30)
> (915 - 928 @ 8), (30)
>
> As far as I could find, the hole between 907.5 and 915 exists because there
> are three 2.5 MHz-wide GSM uplink channels there. However, I also found out
> that there is a proposal within ANATEL (Consulta Pública 52 from 2021) to
> expand it with another uplink channel at 905 - 907.5 (there are actually
> five uplink channels in that proposal, the other one is at 898.5 - 901). I
> have no idea when this will become official, or whether it has already
> happened (and just wasn't reflected yet in the restricted radiation rules I
> had researched), and what effect it would have on 802.11ah users.
>
> Given the uncertainty from that change, and given that so far there are
> rules for the 900 MHz range in wireless-regdb only for the USA, it might be
> wise to hold it for now and apply only the rest of the changes, without
> these 900 MHz ranges.
Sounds good to me.
> > Otherwise I think these changes look good. If you can send a patch with
> > the changes I would appreciate it, otherwise let me know and I can send
> > a patch.
>
> I will prepare a patch tomorrow.
Thanks!
>
> --
> Cesar Eduardo Barros
> [email protected]
>
>
> _______________________________________________
> wireless-regdb mailing list
> [email protected]
> http://lists.infradead.org/mailman/listinfo/wireless-regdb