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 Previous: Past ARRL President to Commemorate First-Ever DXpedition |  Next: ISS Crew Chief to Chat with Alma Mater During ARISS Contact |
NEWINGTON, CT, Mar 6, 2001--The ARRL is urging the FCC to deny or dismiss a petition that seeks to boost the field strength and duty cycle of RF identification systems deployed as unlicensed Part 15 devices in the 420-450 MHz band. The League filed comments March 1 in a petition by SAVI Technology Inc.
The petition, made public January 30 and designated RM-10051, asks the FCC to change certain Part 15 rules affecting unlicensed, periodic, intentional radiators. SAVI, which markets radiolocation and wireless inventory control products, says it needs the rules changes to satisfy customer demand for increased RFID system capabilities.
The ARRL argues that the field strengths and duty cycles SAVI proposes for its RFID tags "are completely unreasonable and would undoubtedly seriously disrupt amateur communications in one of the most popular of the Amateur Service allocations."
SAVI wants the FCC to permit operation of its devices, centered on 433.9 MHz, at field strengths of 110,000 uV/m measured at three meters to communicate over paths of 100 meters (approximately 328 feet). The company also wants to employ duty cycles of up to 120 seconds with only a 10-second silent period between transmissions.
Current Part 15 rules governing these types of periodic radiators provide for fields strengths at that frequency of less than 5000 uV/m and duty cycles of less than a second.
The League contends that SAVI's method of determining that a signal level of 110,000 uV/m would be permitted under Part 15 rules is flawed. "Signals levels of that order could be heard for kilometers, or more, with even low-gain antennas," the ARRL said, adding that existing Part 15 rules adequately provide for communicating over a range of 100 meters.
The League suggests that, if SAVI cannot get the necessary data throughput without employing extremely high field strengths and lengthy duty cycles, the company ought to explore operation under other sections of Part 15 that don't include the kinds of limits periodic radiators must abide.
The ARRL characterized SAVI's petition as another in a long series in which manufacturers of unlicensed RF devices seek to liberalize rules regarding permitted field strengths for such devices in bands allocated to the Amateur Service. And the League suggested that SAVI would be better off deploying the devices in the 902-928 MHz band. "The frequency band chosen by SAVI was obviously done without interference avoidance in mind," the League said. "It is among the worst choices SAVI could have made from that perspective."
The ARRL said SAVI not only has failed to show that its unlicensed devices could operate at the requested field strengths and duty cycles on an itinerant basis without unduly risking harmful interference to amateurs, it hasn't shown why it needs such extremely high field strengths to communicate over paths of 100 meters.
"Because RFID tags are itinerant and mobile, there is absolutely no chance whatsoever that interference between Amateur stations and RFID tags could be mitigated once the devices are deployed," the ARRL asserted. "The interference potential of these devices is thus completely unpredictable and cannot be remedied easily."
The League pointed out that the Communications Act of 1934 lacks authority to allow unlicensed devices with substantial interference potential. "Such devices must be licensed," the ARRL concluded. Unlicensed Part 15 devices must not interfere with licensed services and must tolerate interference received from licensed radio services in the same band.
The ARRL said limited anecdotal studies by ARRL of noise levels from unlicensed devices in certain metro areas indicate that manmade RF noise "is substantially increasing." The League also pointed to a noise-level study planned by the FCC's Technological Advisory Council. The TAC has suggested that rapid degradation of the noise environment could lie ahead and impact system reliability or even viability. The ARRL warned the FCC to "be extremely careful in evaluating rulemaking petitions proposing substantial departures from present Part 15 rules."
ARRL's comments in RM-10051 is available on the ARRLWeb. A copy of the SAVI Technology Petition is available on the FCC Web site.
For more information on Part 15 devices, visit the ARRL Web page.
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