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 simulation 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 2.400-2.483,5 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).

A device within these criteria is used without a licence: no radio licence, no permit to set up and use it, no frequency assignment or registration (Regulation on Radio Equipment and Systems Exempt from Frequency Assignment, Article 5). It may not cause harmful interference to other radio systems and may not claim protection from theirs (Article 5(3)). Use outside the exemption and against the rules is dealt with under Article 63 of the Electronic Communications Law (Article 7).

An open question: Article 8 of the Technical Criteria deals separately with radiodetermination devices, those that find an object's position by radio; at 2.400-2.483,5 MHz the limit is 25 mW e.i.r.p. and the reference standard TS EN 300 440. The same article leaves out point-to-point and point-to-multipoint radio communication. YERKON finds position through packets exchanged between units, so it can be read under either article. The site and the simulation rest on Article 5. Were Article 8 to apply, the transmit power would fall to a quarter (6 dB), the range would shrink (roughly by half without obstacles), more units would be needed and the cost per km² would rise. The definitive answer will come from asking the BTK for its opinion.

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, with FHSS and LBT	Highest, 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 figure used in the calculation; the maker 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 simulation 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 simulation 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 simulation 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.
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 2.500-8.000 € before tax, once (LCAS v1.0, Multicert, June 2026). The unit is connected to the centre, so the requirements of Article 5(3) of Türkiye's Radio Equipment Regulation (2014/53/AB) on harm to the network, personal data and fraud (EN 18031) may apply as well; under Article 5(4) the BTK brings them into force by its own rules. For this the BTK opened the draft communiqué on the additional essential requirements for internet-connected radio equipment for comment by Board decision 2025/İK-TED/128 of 6 May 2025 (deadline 3 July 2025); its EU counterpart is Regulation 2022/30. No notice was found that it has come into force (1 October 2026). 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 20(3) of Türkiye's Radio Equipment Regulation (2014/53/AB) allows internal production control under Annex 2. 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 Türkiye; 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 simulation 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 simulation.

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 27.503,44 TL, so the cap is 137.517,20 TL a year in a metropolitan municipality and 82.510,32 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 simulation 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.

Safety certificate

The Regulation on Safety Certificates for Electronic Communications Devices governs where fixed transmitters go, how they are installed and inspected, and their safety certificate, with regard to electromagnetic fields. Its Article 2 leaves out, cellular systems aside, end-user terminal devices and devices with an output power of 5 W or less. YERKON's broadcast units put out at most 100 mW and the receivers are end-user devices, so none of them needs a safety certificate.

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.