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 Previous: FCC Clarifies Details of CORES Amateur Implementation |  Next: ARRL to FCC: No Commercial Users at 2390-2400 MHz! |
By David Sumner, K1ZZ
ARRL Executive Vice President
October 29, 2001
Editor's note: Typically, only ARRL members get to read the "It Seems to Us ..." editorials that run each month in QST. We're posting this editorial by ARRL Executive Vice President David Sumner, K1ZZ, that appears in the December 2001 issue of QST in the hope that both ARRL members and nonmembers might appreciate it and find it informative.
Every so often we are forced to use page 9 to issue a "call to arms" to ARRL members to defend amateur spectrum. This is one of those times. We face a grave threat that could kill much of the usefulness of the 70-cm amateur band. Here's the story.
A few years ago Congress required the FCC to conduct a "biennial review" of some of its rules to determine whether they should be modified or eliminated. The FCC decided to go even farther and reviewed them all, not just those parts mandated by Congress. Included in the FCC's non-mandatory review was Part 15, governing unlicensed devices that emit RF energy. Part 15 covers a wide range of emitters, from devices that are not intended to emit RF energy such as computers and receivers to short-range communications devices such as garage-door openers and cordless telephones.
In January 2001 the FCC released an "Updated Staff Report" that recommended, among other things, consideration of several modest changes in the Part 15 rules--for example, removing a prohibition on data transmissions by certain remote control devices. These do not pose much of an interference threat to licensed services because they are operated infrequently and the rules require their transmissions to be short. Also recommended was a review of the emission standards above 2 GHz, a timely suggestion in view of the rapid growth in the use of this spectrum by both licensed and unlicensed devices. So far so good.
In October 2001 the FCC adopted and released a Notice of Proposed Rule Making (NPRM), OET Docket No. 01-278, to implement the staff recommendations--and more besides. If the NPRM had stopped with the staff recommendations we would not be sounding the alarm. Unfortunately, grafted onto the document are two proposals for far more radical changes to Part 15, at least one of which should never have seen the light of day in its present form. It represents a grave threat to amateur operation in the 425-435 MHz band.
In November 2000 SAVI Technology, Inc. filed a petition, RM-10051, seeking to legitimize a product that it had already developed, inappropriately, for operation on 433.9 MHz. Let's be clear about this: there is no technical justification whatsoever for the selection of that frequency. Its selection results only from the fact that 433.92 MHz ± 870 kHz is designated for industrial, scientific and medical (ISM) applications in ten European countries (half of them being the former Yugoslavia and one of the other five being Liechtenstein). Because licensed radiocommunication services must tolerate a certain amount of interference in the so-called ISM bands, it is not unusual for these bands to be designated for use by unlicensed devices with power levels and duty cycles that would be inappropriate elsewhere. So it has come to pass that unlicensed devices have sprung up on 433.92 MHz, with or without regulatory authorization. This has caused nightmares for our amateur colleagues in Europe and Australia and has led numerous administrations to prohibit unlicensed devices with high duty cycles from operating on this frequency.
The product that SAVI wants to legitimize is a RF identification (RFID) tag. There is certainly nothing wrong with the concept; it is easy to see why shipping and warehousing operations would like to identify the contents of a container simply by "reading" such a tag. Had SAVI's designers (dare we say they lacked savvy?) chosen a more appropriate frequency we might have devoted this page to the 80th anniversary of the first successful amateur transatlantic transmissions. Had the FCC staff considered our well-reasoned opposition to the SAVI petition you might be reading here about the 40th anniversary of the first amateur satellite. Instead, we must ask you to join the battle against this potential disruption of the 70-cm band.
How serious is the interference potential? The proposed rules would permit an average field strength of 11,000 microvolts per meter measured at 3 meters, for continuous periods of two minutes. In the event of a transmission error a retransmission could be initiated immediately; otherwise a silent period of at least 10 seconds would be required. As a practical matter that amounts to continuous operation of a device that could obliterate weak-signal receivers a mile away and cause significant interference to amateur television, FM, and other modes. Among the supporters of the SAVI petition is UPS. Picture RFID in every brown panel truck in the country; nothing in the proposed rules would prevent it.
It's true that in the event of harmful interference to a licensed station the operator of a Part 15 device is required to eliminate the interference, including ceasing operation if that is the only remedy. However, this presupposes that the source of the interference can be easily located and the operator of the offending device understands this obligation.
In the FCC's own words taken from the NPRM, "The limits are intended to minimize the possibility of unlicensed Part 15 devices causing interference to licensed radio services." The proposal to permit RFID tags in the 70-cm amateur band clearly fails to meet this standard.
If you care about this band here's what you must do. (1) Read the original. (2) Read the ARRL opposition. (3) Read the relevant parts of the NPRM in ET Docket 01-278. All three documents can be found on the ARRL Web site's "Threats to our Amateur Bands" page. (4) File comments opposing the addition of proposed Section 15.240 by following the instructions in paragraphs 51-54 of the NPRM.
And (5) Be as generous as you can in supporting the ARRL Fund for the Defense of Amateur Radio Frequencies. A request was just mailed and should reach every member in the United States about the same time as this issue of QST. If you prefer, visit the ARRL Web site's Spectrum Defense Sponsor 2002 page to make your gift.
The mailing was prepared before
the FCC released this NPRM, so its focus is on WRC-03. The NPRM
is an unfortunate reminder--as if we needed one right now--that defense also
requires action closer to home.--David Sumner, K1ZZ
| Previous: FCC Clarifies Details of CORES Amateur Implementation | Next: ARRL to FCC: No Commercial Users at 2390-2400 MHz! |
