ARRL General Bulletin ARLB026 (1997)

ARLB026 ARRL comments on petition

ARRL Bulletin 26  ARLB026
From ARRL Headquarters
Newington CT  May 22, 1997
To all radio amateurs

ARLB026 ARRL comments on petition

The ARRL will file comments in response to an FCC Petition for
Rulemaking from Checkpoint Systems Inc--a manufacturer of electronic
article surveillance (EAS) systems that use frequencies in the 1.7
to 10-MHz range. EAS systems are used to deter theft in retail
stores and other locations. Checkpoint has asked the FCC to change
its Part 15 rules to expand the frequency range and power level of
EAS systems.  Checkpoint wants the Commission to permit EAS
operations in the 1.705 to 30-MHz band at a maximum radiated
emission level of 1000 uV per meter (measured at a distance of 30
meters) and a maximum conducted emission level of 3000 uV. Current
rules permit a maximum radiated emission level of 30 uV per meter
(measured at a distance of 30 meters) between 1.705 and 30 MHz, or
100 uV per meter between 1.705 and 10 MHz. The current conducted
emission limit for such devices operating between 1.705 and 10 MHz
is 250 uV.

Checkpoint says its EAS system can detect tags concealed within or
attached to protected articles by using an RF sweep over the
frequency range of operation. Typically, systems are set up so that
customers can only exit via an EAS-equipped gate. Checkpoint's EAS
equipment currently operates within the 1.705 to 10 MHz band and is
regulated as an unlicensed intentional radiator under Subpart C of
Part 15. Under Part 15 rules, such devices may operate without
restrictions on bandwidth, duty cycle, modulation technique or
application, but must comply with specified radiation and emission
limits and protect licensed services from harmful interference.
Checkpoint says it needs the higher power levels to overcome
''increasing levels of ambient RF noise in commercial
establishments.'' The expanded frequency range, the company says,
will allow for greater flexibility in deploying EAS systems and
reduce the potential for false alarms.

The company already holds an experimental authorization to operate
EAS equipment within the 7.4 to 9 MHz and 8.2 to 10-MHz bands at up
to 1000 uV per meter and says it has received no complaints of

Checkpoint's Petition for Rulemaking was received by the FCC on
April 28, 1997.