ARRL

ARRL General Bulletin ARLB008 (2002)

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ARLB008 ARRL going to the mat on 70-cm band threat

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ARRL Bulletin 8  ARLB008
From ARRL Headquarters  
Newington CT  January 29, 2002
To all radio amateurs 

SB QST ARL ARLB008
ARLB008 ARRL going to the mat on 70-cm band threat

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 FCC Office of
Engineering and Technology staffers 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 devices configured as such. RFIDs are used
to track and inventory parcel shipments and vehicles.

''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.

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.

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 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 proposed signal levels would cause
''substantial interference to amateur stations in excess of 1000
meters from the RFID transmitter.''

The League also maintains the FCC lacks the statutory authority to
permit the RFIDs as unlicensed devices under Part 15 in the
configuration SAVI has requested. The ARRL argues that under the
Communications Act of 1934, such devices with substantial
interference potential must be licensed. It wants the FCC to move
such RFIDs to another band, such as an Industrial, Medical and
Scientific (ISM) allocation.

A copy of the ARRL Ex Parte Presentation interference study is
available on the ARRL Web site ''Band Threats'' page,
http://www.arrl.org/announce/regulatory/rm-1005/SaviExParte.pdf .
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