Which rules, which limits
The rules that set YERKON's power, its route to market and its maintenance cost, with their official sources. Every limit on power, maintenance and rent written here is the one the model uses; the frequency rules for the prototype devices are for the field trials.
How much power at 2,4 GHz
The town and open country units work in the 2400-2483,5 MHz band as a wideband data transmission system: BTK, Technical Criteria for Radio Equipment and Systems Exempt from Frequency Assignment, Article 5, Table 3, row 3 (Board decision 23.09.2022, 2022/İK-SYD/245; the BTK's page). At most 100 mW e.i.r.p. (20 dBm); an adequate spectrum sharing mechanism is required (for example LBT, DAA); the reference standard is TS EN 300 328. With frequency hopping spread spectrum (FHSS) the e.i.r.p. density is at most 100 mW/100 kHz; with other wideband modulations at most 10 mW/MHz.
The power limits in the table are the regulation's; the channel check, the durations and the thresholds are TS EN 300 328's (ETSI EN 300 328 V2.2.2, 4.3.1). The regulation requires spectrum access and interference mitigation techniques at least equivalent to those of the reference standard (Article 2).
| Mode | Limit | What it means for YERKON |
|---|---|---|
| Without FHSS (other wideband modulation) | 100 mW e.i.r.p. and at most 10 mW/MHz | The signal is 1,625 MHz wide. The 10 mW a MHz limit holds the total to 16,25 mW (12,1 dBm), so the 100 mW limit is never reached. |
| FHSS without LBT or DAA (non-adaptive equipment in TS EN 300 328) | 100 mW e.i.r.p.; transmissions at most 5 ms with gaps of at least 5 ms; at most 15 ms on one frequency in 15 ms × N; medium utilisation at most 10 % | Does not fit: one ranging frame lasts about 15 ms at SF10 and a vehicle polls continuously. |
| FHSS with listen before talk (LBT) (adaptive equipment in TS EN 300 328) | 100 mW e.i.r.p. and at most 100 mW/100 kHz; a channel check before each use of a channel, threshold -70 dBm/MHz; channel occupancy under 60 ms, then silence of at least 5 % of it; able to use at least 70 % of the band | The mode YERKON uses in town and open country, and the one open road. On a 1,625 MHz signal the density limit does not bind and 100 mW (20 dBm) holds. A ranging exchange is 31,8 ms and fits in 60 ms. The replying pole checks the channel before its own transmission too, which adds under 0,1 ms. It must be certified by a test laboratory. |
Legal power unit by unit, 2,4 GHz
| Unit | E28-2G4M20S output, min / typ / max | Antenna, net gain | E.i.r.p. at full power | Highest setting with FHSS and LBT | Highest setting without FHSS |
|---|---|---|---|---|---|
| Broadcast unit, town and open country | 19 / 20 / 21 dBm | Taoglas GW.22.5151, 4,7 dBi | 234-372 mW, over the limit | 15,3 dBm (34 mW) | 7,4 dBm (5,5 mW) |
| Vehicle receiver | 19 / 20 / 21 dBm | Taoglas GW.22.5151, 4,7 dBi | 234-372 mW, over the limit | 15,3 dBm (34 mW) | 7,4 dBm (5,5 mW) |
| Pedestrian receiver | 19 / 20 / 21 dBm | on-board, 3,2 dBi (the model's figure; EBYTE gives none) | 166-263 mW, over the limit | 16,8 dBm (48 mW) | 8,9 dBm (7,8 mW) |
The module's power is from EBYTE's E28-2G4M20S datasheet: 100 mW, at least 19, typically 20, at most 21 dBm; that is the power fed to the antenna. The limit is on the power leaving the antenna: 100 mW e.i.r.p. (20 dBm) with FHSS and LBT, 16,25 mW (12,1 dBm) without FHSS on a 1,625 MHz signal. The highest setting is the conducted power at which even the module's highest output stays within the limit: the limit less the antenna's net gain. The typical output stays 1 dB below it. An antenna may be fitted, but TS EN 300 328 has the equipment tested with that antenna and no power setting the software allows may exceed the limit (4.2.4 and 4.3.1.2). The model holds every unit to the limit in its antenna's strongest direction; the results use that power.
The UWB units (DWM3000) run at -41,3 dBm/MHz on their own antennas; the tunnel and pedestrian units fit the table below as they are, the vehicle receiver has to control its power (TPC) and keep to the exterior limit upward.
UWB in the tunnel, 6-8,5 GHz
| Use | Limit (e.i.r.p.) | What it means for YERKON |
|---|---|---|
| General purpose UWB (Article 18(1), Table 16) | Mean -41,3 dBm/MHz, peak 0 dBm/50 MHz | Devices fixed outdoors or on a fixed outdoor antenna, and those in road vehicles, are outside this article. The pedestrian receiver is in this row. |
| Location tracking type 1, LT1 (Article 18(4), Table 19) | Mean -41,3 dBm/MHz, peak 0 dBm; TS EN 302 065-2 | For systems that track where people and objects are. The tunnel units are in this row: -14,3 dBm e.i.r.p. over a 499,2 MHz channel, which is what the model uses. |
| Road and rail vehicles (Article 18(2), Table 17) | Mean -53,3 dBm/MHz, peak -13,3 dBm/50 MHz. With LDC or TPC, mean -41,3 dBm/MHz and peak 0 dBm/50 MHz, with an exterior limit of -53,3 dBm/MHz at elevation angles above 0°. TS EN 302 065-3 | The vehicle receiver is in this row and has to control its power (TPC). The vehicle's device may send less power above its own height (-53,3 dBm/MHz); below it -41,3 dBm/MHz holds (EN 302 065-3, 4.3.4.2 and table 4). Tunnel units below the vehicle's antenna, 1,2 m above the road, stay clear of that limit, and the model works it out that way. There is no automatic exemption for enclosed spaces; Annex C.1 allows equivalent protection to be demonstrated. |
Definitions in the regulation
- Frequency hopping spread spectrum (FHSS): the receiver and transmitter hopping together from one frequency to another.
- Listen before talk (LBT): the device senses whether its band is busy and waits until it is free or it has moved to a free one.
- Detect and avoid (DAA): the device checks the channels before sending, avoids those other systems are using and sends on one it finds free.
- e.i.r.p. (effective isotropic radiated power): the power fed to the antenna times the antenna's gain in that direction over an isotropic antenna. 100 mW is 20 dBm, 10 mW is 10 dBm.
- Low duty cycle (LDC): all transmissions together under 5 % of every second and under 0,5 % of every hour, no single transmission over 5 ms.
- Transmit power control (TPC): the device's ability to control its output power to reduce interference with other systems.
- Source: BTK, Technical Criteria for Radio Equipment and Systems Exempt from Frequency Assignment, Article 1.
Antenna gain
- The limit is on radiated power, antenna gain included. A device transmitting through a stronger antenna has to turn its power down by as much.
- There is no limit on receiving: a stronger antenna hears a weak signal better. Every range goes both ways, so the gain is needed at both ends.
- The E28-2G4M20S already gives 20 dBm, so the 5 dBi antenna adds nothing on transmit: the module is turned down to 15,3 dBm and 100 mW still leaves the antenna. The gain is on receive: each end hears the other 4,7 dB better. The module's on-board antenna stays inside the box and EBYTE gives no gain for it; with it the covered area shrinks and the cost per km² rises (ADR-0100).
- The power limit is applied in the direction the antenna sends strongest; in other directions less power reaches the receiver.
Going to market
- Since 5 February 2021 the BTK takes no notification before a product is placed on the market. Under the Radio Equipment Regulation there is no separate BTK application or fee.
- The manufacturer is responsible for the CE mark, the EU declaration of conformity and the essential requirements; the box carries the short or the full declaration.
- Tests needed: EN 300 328 (radio; FHSS and LBT are tested here), EN 301 489-1 and -17 (electromagnetic compatibility), EN 62368-1 (safety) and EN 62311 (human exposure to electromagnetic fields). Laboratories work by quotation. A published market indication puts the four together at 2500-8000 € before tax, once (LCAS v1.0, Multicert, June 2026). The unit is connected to the centre, so the RED Article 3(3) cybersecurity requirement (EN 18031) may apply as well; that evidence costs extra. The tunnel unit and the pedestrian and vehicle receivers carry UWB (Qorvo DWM3000) and also need EN 302 065: -1 for general purpose UWB in the pedestrian receiver, -2 for location tracking in the tunnel unit and -3 for vehicles in the vehicle receiver. The LCAS range does not cover that test. Accredited laboratories in Türkiye run these tests, for instance Ege Test Center and the TSE Electrotechnical Laboratory; none publishes a price, so the cost will come from a quotation.
- Where the harmonised standards are applied, a notified body is not required: Article 17(3) of RED 2014/53/EU allows internal production control under Annex II. That does not make conformity free; the manufacturer still has to show it with a technical file and measurement results.
Frequency for the prototype devices
- The prototype's Meshtastic devices work at 868 or 915 MHz. The 902-928 MHz band is not licence-exempt in Turkey; only narrow sub-bands such as 917,4-919,4 MHz are, under conditions.
- Most 863-870 MHz sub-bands allow 25 mW e.r.p. at a 0,1 to 1 % duty cycle; 869,4-869,65 MHz allows 500 mW at 10 %. The prototypes should be set to these.
The rules installation and cost rest on
The rules so far were for the radio itself and for putting it on the market. Those below are about where and how a unit is fitted, and which rules the cost of fitting and maintaining it rests on.
Per diem
- A per diem is the daily allowance paid, with the fare, to a worker sent on a temporary duty outside the place of duty (Travel Allowance Law 6245). The law is for public servants; a private employer sets its own, but the tax-exempt part is the allowance of a civil servant on the same salary level (Income Tax Law 193, Article 24(2)). The model uses the public schedule for that reason.
- How much: Schedule H of the 2026 Central Government Budget Law (7567), grades 5-15, domestic allowance 850 TL a day. A field technician's salary falls in this range.
- Where: in a metropolitan province the place of duty is the district the worker belongs to and the built-up area that continues it (Article 3(g)). A crew based in Çankaya is at its place of duty in Kızılay and away from it in Polatlı or Kızılcahamam. No allowance is paid inside the place of duty (Article 39).
- On a day trip: a third of the allowance for being away over one of the lunch (13.00) or dinner (19.00) times, two thirds for both, all of it for a night (Article 39). A maintenance visit leaves in the morning and is back in the afternoon: 283,33 TL a person, 566,67 TL a day for a crew of two. The crew calls at several units that day, so this is shared among the visits: four poles a day in open country, 141,67 TL a visit.
- Zero in YERKON today: in town the crew is in its own district; in open country and the tunnel a local firm in that district does the maintenance, so nobody leaves the place of duty. Were it done from central Ankara, each crew day would add 566,67 TL; that is why the rule stays in the model.
Regulation in the maintenance cost
- Depreciation (Revenue Administration list): radio devices and systems 10 years (3.49.4), batteries 5 years (3.14.7), solar power plant 10 years (45.1.9). The replacement line divides each part by its own life.
The rules that set pole heights and where the unit goes
- Lighting column: TEDAŞ's rules for LED road lighting design (August 2022, annex 1) tie the column height to the road class: 12 to 14 m on M1 roads, 10 to 12 m on M2 and M3, 8 to 10 m on M4, 8 m on M5, 6 to 8 m on footways (P2, P3). What these heights cost is on the Cost page.
- Distribution pole: TEDAŞ-MLZ/99-34, the specification for spun concrete poles, lists lengths from 9,3 m to 25 m (9,3-10-11 m, 12-13-14 m, 15-16 m and up). A line 4 m above the base marks where the buried length is checked.
- Distance from the conductors: the table of least vertical distances in the Regulation on Electrical Power Installations gives the least vertical distance from overhead conductors to communication lines as 1 m at low voltage and 2,5 m at 1 to 36 kV medium voltage. A unit therefore goes at least 2,5 m below medium-voltage conductors. The same table wants medium-voltage conductors at least 7 m above village and town roads and 6 m above fields.
Using space on public structures
- Zoning Law 3194, Additional Article 9(7): the yearly fee a public body charges an electronic communications station for space may not exceed five times the Ministry of Transport's site selection fee in a metropolitan municipality and three times elsewhere. The 2025 site selection fee is 27503,44 TL, so the cap is 137517,20 TL a year in a metropolitan municipality and 82510,32 TL elsewhere (Ministry of Agriculture and Forestry, 2025 rates). Istanbul's municipal tariff is built on this rule. YERKON units go up under a public agreement, so the model charges no pole rent.
- General Lighting Regulation: no energy may be taken from a public lighting connection for anything but public lighting, and the lighting installations belong to TEDAŞ. A unit is therefore a separately metered subscriber and pays the commercial tariff.
Maps and imagery
- The place picker uses OpenStreetMap's tiles and credits it. The imagery is Esri World Imagery, credited to Esri, Maxar, Earthstar Geographics and the GIS User Community. It paints the ground and enters no calculation.
Official sources
- ETSI EN 300 328 V2.2.2 (2019-07)
- BTK: the Class 2 notification has ended
- ETSI EN 302 065-3 V2.1.1 (2016-11), UWB in vehicles
- RED 2014/53/EU (EUR-Lex)
- BTK: market surveillance, frequently asked questions
- BTK: technical criteria for licence-exempt radio devices
- Travel Allowance Law 6245 (Articles 3(g) and 39)
- Income Tax Law 193 (Article 24)
- SBB: 2026 Schedule H
- Regulation on Electrical Power Installations
- TEDAŞ: rules for LED road lighting design (August 2022)
- TEDAŞ-MLZ/99-34: spun concrete pole specification
- Ministry of Agriculture and Forestry: 2025 base station rent rates (Law 3194, Additional Article 9(7))
- General Lighting Regulation
- Revenue Administration: depreciation rates