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 Previous: A Visit to the 17th Annual Microwave Update 2002 and the 28th Eastern VHF/UHF Conference |  Next: ARRL Resurrects Frequency Measuring Test |
NEWINGTON, CT, Oct 30, 2002--A National Telecommunications and Information Administration (NTIA) study supports the ARRL's position that the FCC would be making a mistake to permit SAVI Technology to deploy RF identification (RFID) tag devices at 433 MHz at much greater duty cycles than current Part 15 rules permit for such devices. RFID tags are used for tracking shipments and packages, among other applications.
"NTIA has grave concerns about the Commission's proposal to amend its Part 15 rules to permit the operation of RFID tags in the band 425-435 MHz at increased power levels and increased duty factor (or activity factor) and data transmission by remote control devices," wrote Fredrick R. Wentland, the NTIA's acting associate administrator in the Office of Spectrum Management. "Given the likelihood of interference to critical government radars, NTIA is unable to support the Commission's proposal."
The NTIA filed initial comments in the proceeding, ET Docket 01-278, last March but requested additional time to document an NTIA staff study with respect to field strength limits for RFID tags in the band.
ARRL Chief Executive Officer David Sumner, K1ZZ, said the NTIA staff study bears out what the League has been saying all along. "RFID tags represent a significant source of potential interference to sensitive receivers," Sumner said, adding that use of the 425-435 MHz band would be incompatible with ongoing requirements of incumbent services--military and amateur. "We trust that the FCC will now terminate this portion of the proceeding and that the RFID proponents will focus their attention on other, more appropriate parts of the radio spectrum."
That's exactly what the NTIA advised. It recommended that the FCC "explore other bands that might be able to accommodate the technology without causing unacceptable interference to critical incumbent users." Among the suggestions was 450 to 470 MHz, which provides nearly the same propagation characteristics as the band SAVI picked. The NTIA also noted that 902 to 928 MHz--an amateur allocation--or 2400 to 2483.5 MHz--which includes part of an amateur microwave allocation--might accommodate the proposed RFID tags as spread spectrum devices.
Calling the potential level of degradation to government radars in the band "unacceptable," Wentland said the NTIA "stands ready" to work with the FCC to explore other potential options to deploy "promising RFID technology."
Accompanying Wentland's letter was a six-page NTIA technical analysis. The study asserts that the FCC's proposal to permit increased duty cycles and field strengths for the 425-435 MHz RFID emitters "would result in received power levels in excess of the required interference-to-noise ratio" that could adversely affect "critical government radar systems." The transient nature of the RFID tags would make it "virtually impossible" to prevent their operation near government radar operations, NTIA said.
SAVI this week filed its own detailed study that rebuts the NTIA's position. SAVI suggested it would be willing to have the FCC limit the available band for "advanced RFID" products to 433 to 435 MHz, lower the peak-to-average ratio to 14 dB, strengthen the definition of RFID products to add language forbidding voice transmissions and limit use of RFIDs to "commercial or industrial locations."
"The NTIA analysis, if followed, would demonstrate that Amateur systems (operating at 56 to 86 dB higher than RFID systems) are causing cataclysmic interference to government radar systems," SAVI said in its cover letter to its rebuttal study.
More than 130 amateurs filed comments in
opposition to SAVI Technology's RFID tags proposal, and most supported the
ARRL's position that the proposed rules are flawed and should not be adopted. A
copy of the NTIA letter and study and SAVI's rebuttal study in ET Docket 01-278
are available via the FCC
Electronic Comment Filing System page. Click on "Search for Filed Comments"
and enter "01-278" in the "Proceeding" field.
| Previous: A Visit to the 17th Annual Microwave Update 2002 and the 28th Eastern VHF/UHF Conference | Next: ARRL Resurrects Frequency Measuring Test |
