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NEWINGTON, CT, Apr 15, 2004--The FCC has adopted a somewhat limited proposal to permit deployment of RF Identification (RFID) tags in a segment of the 70-cm band at much greater duty cycles than current Part 15 rules permit for such devices. Among other applications, RFID tags are used to track shipments and packing containers. A Third Report and Order (R&O) in ET Docket 01-278 follows a 2000 petition by SAVI Technology to revise FCC Part 15 rules to accommodate such devices in the vicinity of 433 MHz. The ARRL has consistently opposed the proposal, but FCC just as unfailingly has gone along with it. FCC Office of Engineering and Technology (OET) Chief Ed Thomas said RFIDs provide important public benefits.
"This device is designed to increase homeland security at ports, rail yards and warehouses," Thomas told the FCC open meeting. "It will foster the development of more powerful and advanced RFID systems that can identify the contents of shipping containers and determine whether tampering has occurred during shipment." Thomas said the devices also would increase efficiency in shipping operations and inventory control.
In requesting Commission adoption, OET's Hugh van Tuyl provided the broad strokes of the Part 15 rule changes, which, he said, would apply specifically to commercial shipping containers "in commercial and industrial areas." In certain cases, he asserted, current Part 15 requirements aimed at preventing interference to licensed services "may unnecessarily constrain the operational range of RFID systems as well as the speed and quantity of data that can be transmitted."
The Third R&O not only would increase the maximum radiated field strength permitted for such devices but their maximum permissible transmission period as well--from one second to one minute. "While the maximum [emission] level would be greater than currently allowed," van Tuyl said, "it would still be only one-half of the level permitted for devices such as garage door openers, which also operate in this band." The longer authorized transmission period would allowing an RFID to transmit the contents of an entire shipping container, he pointed out.
"We therefore believe there will be no significant increase in the potential for interference to authorized services," van Tuyl concluded. "Improved RFID systems will help to ensure homeland security by allowing rapid identification of the origin and contents of a shipping container coming into the country and whether tampering with the contents had occurred during shipment."
The FCC made peace with the National Telecommunications and Information Administration (NTIA) on the RFID tag issue. Citing the likelihood of interference to critical government radars, the NTIA in 2002 had expressed "grave concerns" about the FCC's proposal to amend Part 15 and permit their deployment.
The Third R&O reflects certain accommodations that SAVI had offered in response to the 2002 NTIA study. To accommodate federal government users, it limits the operating band for such RFID tags to 433.5 to 434.5 MHz, instead of the 425 to 435 MHz SAVI originally had proposed. It further would prohibit operation of RFID tag systems within 40 km (about 25 miles) of five government radar sites, van Tuyl explained. Manufacturers of 433 MHz RFID systems would have to register the locations of their system base stations "to assist in resolving any interference cases that may arise."
Since SAVI first approached the FCC in 2000, ARRL has maintained that the RFID tags the company proposed would represent a significant source of potential interference to sensitive receivers and be incompatible with ongoing requirements of incumbent services. "There are also large numbers of co-channel Amateur Television repeater inputs at 434 MHz in areas immediately proximate to warehouses and dock areas where the SAVI devices may be expected to be used," the League said in its March 2002 reply comments in the proceeding. Operating near-continuous duty Part 15 in the vicinity of 433 MHz "is fundamentally incompatible with incumbent amateur operation," the ARRL told the FCC.
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 were flawed and should not be adopted.
FCC Chairman Michael Powell was highly supportive of the Third R&O. "A little tag can make a big difference on our ability to secure ports and containers," he said, "and I think it's also increasingly being understood as a very powerful tool in inventory management and increased economic productivity."
For additional information and background, see "ARRL Asks FCC to Drop RFID Rules Proposed for 425-435 MHz."