Regulatory domain issue on Costa Rica?

[caleiton]

Hello Helium staff. I would like to ask you about an issue we are having overall in my country Costa Rica when deploying the Helium miners here.

Apparently, we have been categorized as AS923-1, which is mainly used for Asia countries, but we are in America.

Investigating the regulatory domain and LoRa documents (maybe the source of your document) states that here we can only use 433.05 - 434.79 MHz (EU433) and 920.5 - 928 MHz (AS923-1), according to this: https://lora-alliance.org/wp-content/uploads/2020/11/rp_2-1.0.1.pdf

Other documents show my country as US902-928, here: https://www.thethingsnetwork.org/docs/lorawan/frequencies-by-country/ There is already s small community in Costa Rica already using the US902-928 domain as stated by The Things Network: https://www.thethingsnetwork.org/community/sanjose/

From the government perspective, it looks like Costa Rica regulatory domain allows the ISM band, free to use, this is from 902Mhz to 928Mhz, as stated on this document: https://www.micit.go.cr/sites/default/files/micitt-derrt-daer-inf-190-2020_banda900-y-bandas-uso-libre-esc_v2jp.pdf You can refer to pages 32, 33, and 35, when it even specify the 902-928 as free to use with a maximum EIRP as 30dBm, and not 16dBm as the AS923 dictates.

If this is correct, this might solve the problem we are having overall in the country. However, if this is not the root cause of the problem, then I will ask you please to help me to try to identify what could be the possible cause of the Helium miners not working properly in my country.

[Vagabond]

Poc11 is not active yet, so that should not be related to your problems.

[bitlite]

Check your antenna connection between Miner and cable. It may have gotten loose and needs to be tightened up. Please power off miner before doing this.

[caleiton]

Hey, let's get rid of POC11 in the middle. I thought that might be the cause. However, it is not a 1 person issue, it is overall in the country. Several people are affected!

Can we review the regulatory domain issue? I have an email from Bobcat saying that their hotspots are not going to work here as we are AS923_1. I have made very good points on my initial statement, could you please take a look at that?

[cdkeensd]

Hi we are having the same problem in Tinidad and Tobago where they have us incorreclty classified as AU915. However according to ITU-R we are Region 2. LoRa Alliance has alot of the Americas classified as AU915 for some strange reason and I think that is where Helium is basing their regions from . However the Americas are region 2 which is US915

https://www.itu.int/en/ITU-R/terrestrial/broadcast/PublishingImages/bcd%20images/ITU%20regions.jpg

[bitlite]

Hi we are having the same problem in Tinidad and Tobago where they have us incorreclty classified as AU915. However according to ITU-R we are Region 2. LoRa Alliance has alot of the Americas classified as AU915 for some strange reason and I think that is where Helium is basing their regions from . However the Americas are region 2 which is US915

The ITU Region MAY NOT apply if the local governments have changed the rules for these frequencies. Please verify with your government telecommunications laws pertaining to the 900-928MHz frequency range. If this is an error, you may need to engage your government to post a ruling for this technology.

[cdkeensd]

Hi we are having the same problem in Tinidad and Tobago where they have us incorreclty classified as AU915. However according to ITU-R we are Region 2. LoRa Alliance has alot of the Americas classified as AU915 for some strange reason and I think that is where Helium is basing their regions from . However the Americas are region 2 which is US915

The ITU Region MAY NOT apply if the local governments have changed the rules for these frequencies. Please verify with your government telecommunications laws pertaining to the 900-928MHz frequency range. If this is an error, you may need to engage your government to post a ruling for this technology.

The government has confirmed that Trinidad & Tobago complies with Region 2

(See Page 4) https://tatt.org.tt/Portals/0/Documents/Frequency%20Allocation%20Table%20(9kHz%20to%201000%20GHz).pdf

[shawaj]

Costa Rica is AS923-1

See the LoRa Alliance spec here RP002-1.0.3-FINAL-1 (3).pdf

[caleiton]

Hello, I would like to retry this post. Answering to @shawaj, I know the LoRa alliance has this classification in Costa Rica. But AS923-1 is commonly used in Australia, New Zealand, Japan, Singapore, and Taiwan among other countries.

I have sent emails to the LoRa alliance but it looks like they only listen to your requests if you are a member of the LoRaWan with a paid subscription.

But there is documentation that proves this qualification is incorrect. Official documentation from Costa Rica government: http://www.pgrweb.go.cr/scij/Busqueda/Normativa/Normas/nrm_texto_completo.aspx?nValor1=1&nValor2=79712 https://www.micitt.go.cr/sites/default/files/micitt-derrt-daer-inf-190-2020_banda900-y-bandas-uso-libre-esc_v2jp.pdf

They will be considered telecommunications networks constituted through the use of frequencies of the radioelectric spectrum of free use, the following: • 902 MHz a 940 MHz

Now, some hotspots in the country are working properly. Mainly RAKwireless and Calchip technologies. Other brands like Bobcat are not working when witnessing or witnessing beacons. So I am not sure how the restrictions are being applied by the different vendors.

My main question here is, how if this configuration is incorrect, the qualification about the country region can be modified? I know this is not going to be changed because one person, but with enough evidence, and a little bit of research, the things can be corrected if they are incorrect. There are many more people in the country that is being affected by this incorrect qualification.

For example, The Things Network, which deploys LoRaWAn devices and projects, have classified Costa Rica properly, as 902-928 https://www.thethingsnetwork.org/docs/lorawan/frequencies-by-country/

Could you please check this carefully and assist?

[shawaj]

AS923-1 is within the range of 902 to 928 ... It uses:

'AS923_1' => [923.2, 923.4, 923.6, 923.8, 924.0, 924.2, 924.4, 924.6],

Whereas USA uses:

'US915' => [903.9, 904.1, 904.3, 904.5, 904.7, 904.9, 905.1, 905.3],

The LoRa Alliance technical committee that decides these things is the only place this can be changed, but it doesn't seem that it needs to be changed.

The LoRa Alliance document suggests that the valid frequency is 920.5 to 928 MHz so perhaps you have missed something in the regulations?

[shawaj]

It seems to come from here:

"CR 061A Within the segment from 915 MHz to 940 MHz, the sub-segment from 920.5 MHz to 934.5 MHz can be used in fixed and mobile systems, disabling the use of the segments from 915 MHz to 920.5 MHz and from 934.5 MHz to 940 MHz for the protection of IMT systems described in footnote CR 061."

[caleiton]

The problem comes when Geographical restrictions are in place. Remember we are talking about LoRaWan for use with Helium hotspots. If we can use the range from 902 to 928 this means that we could legally use the 915 frequency on our country as you state [903.9, 904.1, 904.3, 904.5, 904.7, 904.9, 905.1, 905.3] which are allowed by CR 061 and by its update CR 081. However, we are limited to only using 920.5 to 928 by our "region" instead of the full possible spectrum, which includes the US915 channels. With this being said, even when our regulatory domain allows it, and currently we, for example, cannot use US915 Helium hotspots in our country, which is not accurate. It is not illegal to use those frequencies in our country, therefore we should be allowed to use them for mining HNT.

[shawaj]

@caleiton my above message has the part that restricts it for use with lora. Presumably that's what lora alliance are going on

[caleiton]

@shawaj, I am not sure we are reading the same document. I do not see any restrictions as you are describing.

CR061A has been amended, and CR081 (which replaces it) clearly states that these frequencies are designated as free to use. I cannot read where it says that are restricted.

[caleiton]

[caleiton]

So for the same reason, some Helium hotspots work properly in the country, while other hotspots do not work at all. I do not know why. This is totally unfair, depending on the hotspot manufacturer you can or cannot mine HNT in the country.

@shawaj , Please tell me where do you see the restrictions that you mention.

[shawaj]

I read it in your link http://www.pgrweb.go.cr/scij/Busqueda/Normativa/Normas/nrm_texto_completo.aspx?nValor1=1&nValor2=79712

But also that amendment doc is not an amended regulation it's a proposal.

It's seems like maybe the proposal has not been ratified yet