ARRL General Bulletin ARLB013 (2002)

ARLB013 ARRL asks FCC to drop RFID rules proposed for 425-435 MHz

QST de W1AW  
ARRL Bulletin 13  ARLB013
From ARRL Headquarters  
Newington CT  February 14, 2002
To all radio amateurs 

ARLB013 ARRL asks FCC to drop RFID rules proposed for 425-435 MHz

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.'' Among other applications, RFID tags are used to track and
inventory parcel shipments and vehicles.

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.

The ARRL also said that the cost of the tags is a problem for SAVI,
and the choice of frequency band is related only to the cost of
components. The League 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.

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.

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. ARRL's comments in
the proceeding are available on the ARRL Web site
Reply comments are due by March 12, 2002.