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 Previous: QRP Community: The QRP Community |  Next: FCC Amateur Radio Enforcement Letters for the Periods Ending January 12 & 26, 2002 |
NEWINGTON, CT, Jan 28, 2002--ARRL officials have met with FCC staff members as part of the League's effort to stave off a band threat on 70 cm. ARRL General Counsel Chris Imlay, W3KD, and Technical Relations Manager Paul Rinaldo, W4RI, delivered an ex parte presentation to Hugh van Tuyl and Karen Rackley of the FCC's Office of Engineering and Technology staff on January 14. At issue was SAVI Technology's plan--already tentatively agreed to by the FCC--to deploy unlicensed transient RF identification devices between 425 and 435 MHz at much higher field strengths and duty cycles than Part 15 rules now permit for such devices.
"We told them that this was the worst possible choice of bands for these RFIDs," Imlay said. "Besides, there's no technical justification for that choice of frequencies." The request to use 70 cm has more to do with economics than technology, he said, because SAVI needs to bring down the cost of RFIDs in order to make a profit. United Parcel Service (UPS) has supported SAVI's proposal in comments, although the company is not yet using the technology.
Imlay added that the ARRL would "do whatever it takes" to stave off the threat, and that could include further direct appeals to FCC staffers. The ARRL plans to file "strongly worded" comments on the SAVI petition by the February 12 comment deadline. Reply comments are due by March 12, 2002. Imlay said that van Tuyl and Rackley assured him that SAVI's request "was not a done deal."
RFIDs are used for what's called "asset tracking." Among other applications, the RFID tags could be used to track and inventory parcel shipments and vehicles. The US Department of Defense already uses SAVI's RFID tags to identify what's in shipping containers.
The FCC acted on the SAVI request last October in an FCC Notice of Proposed Rule Making and Order (ET Docket 01-278) aimed primarily at reviewing and updating portions of its Part 2, 15 and 18 rules. The ARRL argued in comments filed last March that the field strengths and duty cycles SAVI proposed for its RFID tags as Part 15 "periodic radiators" were unreasonable and "would undoubtedly seriously disrupt amateur communications in one of the most popular of the Amateur Service allocations," particularly for weak-signal enthusiasts.
The RFID tags are interrogated by a hand-held device. "You can imagine, in a warehouse, there might be multiple interrogation devices, and these RFIDs could be going off all the time," Imlay said. "It could be constant." Not only that but RFID tags on the move could generate interference that could be impossible to pinpoint.
The ARRL's January 14 ex parte presentation was complemented by an interference study prepared by ARRL Lab Supervisor Ed Hare, W1RFI, and ARRL Senior Engineer Zack Lau, W1VT. The presentation supported the ARRL's assertion that "the signal levels proposed for RFID systems at the duty cycles proposed to be permitted in this proceeding will cause substantial interference to amateur stations in excess of 1000 meters from the RFID transmitter."
The League not only maintains that the RFID tags could result in significant interference to amateurs, it believes the FCC lacks the statutory authority to permit them under its Part 15 rules in the configuration SAVI has requested. At the field strengths requested--a maximum field strength of 11,000 uV/m and a peak level of 110,000 uV/m at a distance of three meters--current FCC rules permit only very short data bursts with significant time out between subsequent transmissions. SAVI has proposed permitting continuous transmissions of up to two minutes plus retransmission in the case of an error. The ARRL argues that under the Communications Act of 1934, such devices with substantial interference potential must be licensed.
"There's no exclusion for Part 15 devices," Imlay said. "What the FCC is proposing is a wholesale abandonment of the rules governing periodic radiators." The ARRL has argued that the FCC does not have the authority to put such Part 15 devices just anywhere and has suggested that SAVI pick one of the Industrial, Scientific and Medical (ISM) bands instead of 425-435 MHz. Imlay says SAVI wants 70 cm, however, because it can most economically obtain devices for that band from Europe, where 433.92 MHz is an ISM band in some countries.
Other financial factors may be involved as well. Imlay pointed to an article about SAVI that appeared in the December issue of American Shipper magazine, a copy of which was supplied to ARRL by Rick Wheeler Jr, N4JGU. The article noted SAVI's long-term relationship with the US Defense Department. It also pointed out that the privately held SAVI--with some 300 employees around the world--has received financial backing from UPS's Strategic Enterprise Fund, as well as from other venture capital investors. The article quotes Strategic Enterprise Fund Director John Wilson as saying that UPS might turn to RFIDs "as the price comes down."
For more information, read the QST "It seems to us . . .Unlicensed to Kill" editorial by ARRL Executive Vice President David Sumner, K1ZZ, and visit the Threats to our Amateur Bands page. Amateurs are invited to comment on this proposal via the FCC's Electronic Comment Filing System (ECFS). When searching, enter "01-278" in the "Proceeding" box in the "Search for Filed Comments" window.
A copy of
the ARRL Ex Parte
Presentation interference study is available on the ARRL Web site "Band
Threats" page.
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