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

[Jim Worsham]

FYI.  Just a couple of weeks remain to file your comments with the FCC.
This is your chance to make your opinion known in a constructive and useful
manner.

73
Jim W4KXY

----- Original Message -----
From: "ARRL Web site" <memberlist@www.arrl.org>
To: <w4kxy@bellsouth.net>
Cc: <Subscribed ARRL Members:>
Sent: Tuesday, January 29, 2002 3:44 PM
Subject: ARLB008 ARRL going to the mat on 70-cm band threat


> SB QST @ ARL $ARLB008
> ARLB008 ARRL going to the mat on 70-cm band threat
>
> ZCZC AG08
> QST de W1AW
> 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 .
> NNNN
> /EX
>



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