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 Previous: Inside Your League: The Lab--Part 1The Technical Information Service and Product Testing |  Next: Amateur Radio Volunteers Supporting Olympics |
NEWINGTON, CT, Feb 13, 2002--The ARRL says the FCC "cannot legally proceed with the rules proposed for unlicensed RFID tags at 433 MHz," and it's asked the Commission to not adopt them. The League filed comments February 12 as part of its continued opposition to what it called "this ill-conceived proposal" of SAVI Technology 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. The FCC appears inclined to agree with SAVI's proposal, but FCC staff members have told the ARRL that it's not a "done deal."
"The level of interference from the devices permitted under the proposed rule is intolerable," the ARRL argued, citing its own interference study. The League reiterated its stance that the Communications Act of 1934 "is devoid of any authority to allow unlicensed devices with substantial interference potential; such devices must be licensed."
SAVI, the ARRL argues in its comments, "wants to have its cake and eat it too" by getting high power levels and lengthy duty cycles operating on a band heavily used by a licensed radio service that uses sensitive receivers "and all of the above on an unlicensed basis."
RFIDs are used for what's called "asset tracking." Among other applications, RFID tags could be used to track and inventory parcel shipments and vehicles. Taking issue with an FCC claim that RFIDs typically would operate in commercial zones with few hams, the League said that "ubiquitous, itinerant" RFID systems are bound to operate in the vicinity of amateur operations.
The ARRL said the FCC's inclination to go along with SAVI Technology's proposal "eviscerates the periodic radiator rules, is vague and overbroad," and would permit digital RFIDs to operate "at unsuitable power levels and duty cycles." The result would be unacceptable interference that would "preclude or repeatedly disrupt amateur operation," the ARRL said.
ARRL officials met recently with FCC staff members as part of the League's effort to stave off the 70-cm band threat. ARRL General Counsel Chris Imlay, W3KD, said the League contingent told the FCC that 425 to 435 MHz was the worst possible band for the RFIDs SAVI has proposed, and its choice lacks any technical basis. The ARRL expanded that theme in its comments this week.
"The price of the tags is a problem for SAVI, and the choice of frequency band is related only to the cost of components," the ARRL said. "That commercial issue is not a justification for the Commission to subject the Amateur Service to the inevitable interference from these devices, and it does not justify the Commission's violation of Section 301 of the Communications Act." The ARRL said SAVI chose 433.9 MHz as an operating frequency because of the availability of relatively cheap components in Europe, where the 433.05-434.79 MHz band is available for industrial, scientific and medical uses in at least 10 countries. "The frequency choice has absolutely no technical justification whatsoever, and any contention by SAVI to the contrary is a misrepresentation." the ARRL said.
Given the global direction in this technology, the ARRL pointed out, deploying the proposed RFID tags elsewhere would make much better sense. "SAVI should seriously consider the frequencies around 868 or 915 MHz, which apparently stand at least some reasonable chance of global standardization," the ARRL advised. "No other RFID manufacturer of which ARRL is aware after diligent research is advocating use of the 433 MHz band."
The RFID rules proposed in response to SAVI's Petition for Rule Making last year "are flawed from their inception and should not be adopted under any circumstances," the League concluded. The ARRL has said it will "do whatever it takes" to keep the FCC from permitting the RFID tags on 70 cm. That could include further direct appeals to FCC staffers, Imlay has said.
The FCC included the Part 15 RFID proposals within a larger proceeding, ET-01-278, that's aimed primarily at reviewing and updating portions of its Part 2, 15 and 18 rules. A copy of the ARRL's comments in the proceeding is available on the ARRL Web site. Reply comments are due by March 12, 2002.
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.
A copy of the ARRL Ex Parte Presentation interference study
is available on the ARRL Web site "Band Threats" page.
| Previous: Inside Your League: The Lab--Part 1 The Technical Information Service and Product Testing | Next: Amateur Radio Volunteers Supporting Olympics |
