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ARRL General Bulletin ARLB013 (2004)

ARLB013 FCC okays RF identification tags at 433.5 to 434.5 MHz

QST de W1AW  
ARRL Bulletin 13  ARLB013
From ARRL Headquarters  
Newington CT  April 16, 2004
To all radio amateurs 

ARLB013 FCC okays RF identification tags at 433.5 to 434.5 MHz

The FCC has adopted a somewhat limited proposal to permit deployment
of RF Identification (RFID) tags on 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--approved April 15 but not yet released--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 the 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 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 would increase the maximum radiated field strength
permitted for such devices as well as the maximum permissible duty
cycle--from one second to one minute. The longer duty cycle would
allow an RFID to transmit the contents of an entire shipping
container, van Tuyl said. "We therefore believe there will be no
significant increase in the potential for interference to authorized
services," he concluded.

The Third R & O reflects certain accommodations to the National
Telecommunications and Information Administration (NTIA), which
expressed "grave concerns" about the proposal in 2002. The R & O
limits the operating band for such RFID tags to 433.5 to 434.5 MHz,
instead of the 425 to 435 MHz SAVI originally asked for. It further
prohibits operation of RFID tag systems within 40 km (about 25
miles) of five government radar sites. Manufacturers of 433 MHz RFID
systems would have to register the locations of their system base
stations to aid in interference resolution.

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.

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


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