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ARRL General Bulletin ARLB052 (2001)

ARLB052 Comments due February 12 in "Band Threat" proceeding

QST de W1AW  
ARRL Bulletin 52  ARLB052
From ARRL Headquarters  
Newington CT  November 29, 2001
To all radio amateurs 

ARLB052 Comments due February 12 in ''Band Threat'' proceeding

Comments are due February 12, 2002, in the FCC Notice of Proposed
Rule Making and Order in ET Docket 01-278. Reply comments are due on
March 12, 2002. The proceeding deals in part with a potential band
threat to the popular 70-cm band from Part 15 RF identification
devices proposed for deployment between 425 and 435 MHz.

SAVI Technology, which markets radiolocation and wireless inventory
control products, told the FCC it needs the rules changes to satisfy
customer demand for increased RFID system capabilities. The FCC has
proposed to allow operation of RFIDs as unlicensed Part 15 devices
in the 425-435 MHz band with transmissions of up to two minutes at
field strengths now only permitted for extremely short-duration,
intermittent control signals.

The ARRL has argued that under the Communications Act of 1934 the
FCC lacks authority to permit unlicensed devices with substantial
interference potential and that such devices must be licensed. The
ARRL also is looking into the interference potential posed to 20
meters by a proposal to increase the maximum emission levels
permitted by Part 15 devices operating at 13.56 MHz, as well as the
maximum level of out-of-band emissions.

Commenters are advised to read paragraphs 20-27 of the NPRM&O, which
is available on the ARRL Web site,

Interested parties may file comments using the FCC's Electronic
Comment Filing System, (search
using ''01-278''). Commenters should include full name, US Postal
Service mailing address, and applicable docket or rule making
number--in this case ET 01-278.

It's also possible to e-mail comments via the ECFS. To obtain e-mail
filing instructions, commenters should send an e-mail to and include the words ''get form your e-mail address"
in the body of the message. A sample form and directions will be
sent by reply e-mail.


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