MEMORANDUM
| To: | Amateur Radio Organizations |
| From: | Chris Imlay, W3KD, ARRL General Counsel |
| Re: | Assistance With Spectrum Threat, SAVI Technology, Inc.; RM-10051; ET Docket No. 01-278 |
| Date: | November 6, 2001 |
Greetings. As Dave, K1ZZ mentioned in the "It Seems to Us..." column on Page 9 of the December issue of QST, it is time for all amateurs to respond to an extremely serious threat to the 420-450 MHz band, and specifically the frequencies around 433 MHz. Though Dave has summarized the issue very well in his editorial, the following will give you some details that you may wish to incorporate in your comments in opposition to a portion of the FCC proceeding, ET Docket No. 01-278.
We will also give you the form for the caption of your comments, which can be filed electronically through the FCC's ECFS, the Electronic Comment Filing System, which is easy to use and very friendly, at the FCC web site. First, some background, then some basic data, and finally some points to note in your comments. Please help with this; it is an extremely dangerous FCC proceeding, exemplifying the very worst in spectrum planning by FCC, and a direct attack by an equipment manufacturer on an important amateur band.
Background
On November 22, 2000, SAVI Technology filed a Petition for Rule Making. The Petition was placed on Public Notice January 30, 2001 by the FCC (Report No. 2462), and given file number RM-10051. The Petition asks FCC for changes in the Part 15 rules governing unlicensed, periodic, intentional radiators so as to permit increased duty cycles and permitted field strengths for radio frequency identification (RFID) systems.
These devices encode data on tags on shipments of goods, initially configured for the Federal Government's shipments, and now expanded to private shipments, such as UPS packages. The tags, programmed with 128 kB of memory, are battery operated and are interrogated by a control transceiver. The tags are affixed to the crates, and the interrogators are good for approximately 100 meters.
SAVI deliberately configured the operation of its RFID tag transmitters to operate in the 420-450 MHz band (specifically centered at 433.9 MHz) and proposes to operate them at field strengths of 110 mV/m, with duty cycles up to two minutes at a time, and only a ten-second silent period between transmissions. The current FCC rules [Section 15.231(e)] for periodic radiators, however, permit field strengths of that magnitude at that frequency (measured at 3 meters), only for devices with duty cycles of less than one second, and which have a silent period between transmissions of at least 30 times the duration of the transmission (and in any case at least ten seconds).
While SAVI is not attempting to increase the permitted power of these devices (their interpretation of the FCC rules on permitted power is somewhat generous, but probably at least arguably correct), they are proposing to allow the devices to transmit for a much longer duty cycle than they do now. Of course, the entire reason why Part 15 devices operating under this rule section are permitted to operate at such high power levels is because the devices only transmit for a very short time relative to their silent periods, and therefore the interference potential is relatively small. If the unlicensed devices operated on a non-periodic basis, (i.e. with unlimited duty cycles) the maximum field strengths permitted by the Commission's Rules now in place, at that frequency, would be on the order of 200 uV/m, not 11,000 uV/m.
There was not anywhere in the petition any analysis that addressed the interference potential of the devices to amateur stations.
SAVI lobbied hard at FCC for this rule change. ARRL filed comments on March 1, 2001, and reply comments on March 16, 2001 firmly opposing the petition. Those filings can be viewed at the FCC's web site. SAVI offered to conduct a demonstration using one of its technical consultants, and did so at the residence of Jim Haynie, W5JBP, recently. SAVI's assumption was that FM repeater interference was the issue to be addressed. Jim noted that the frequencies around 433 MHz were used for weak signal SSB operation, and some tests using Jim's 432 MHz equipment showed significant interference potential.
The real problem here is the frequency choice. There is no reason whatsoever, other than the availability to SAVI of cheap hardware, why that frequency has to be used. Any frequency outside the Amateur 420-450 MHz allocation could be selected as a technical matter. However, as Dave's editorial notes, the 433 MHz frequency is available for Industrial, Scientific and Medical unlicensed devices in Europe, and cheap equipment is available from those sources. Also, the devices can be used in some countries in Europe, and an international market is what SAVI is looking for.
The FCC NPRM
FCC's Notice of Proposed Rule Making and Order in this proceeding was released October 15, 2001. It is FCC Document No. 01-290, and can be read in its entirety on the FCC web site. As of this writing, the NPRM has not been published yet in the Federal Register, and there is thus no comment date established. The comments will be due on or before 75 days after the date of publication of the NPRM in the Federal Register. ARRL will let you know what the comment date is, but don't wait to get your comments filed. Sooner is fine in this case.
The FCC ECFS
The FCC's web site will direct you to the Electronic Comment Filing System. You will need to know the docket number for this proceeding. You will be able to either type in online brief comments, or upload your comments as a file attachment. You will receive a confirmation number of your filed comments, and can read other comments filed in the proceeding as well. While brief comments are fine, and you may prefer to type in your comments directly, if you prepare them with a word processor in advance and upload the file, consider using the following pleading format:
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In the Matter of |
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Review of Part 15 and other Parts |
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ET Docket No. 01-278 |
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of the Commission's Rules |
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RM-9375 |
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RM-10051 |
To: The Commission
COMMENTS OF ________________
IN RESPONSE TO NOTICE OF PROPOSED RULE MAKING
After you write your comments, identifying yourself as the commenter and noting your interest in Amateur Radio, put a mailing address or e-mail address at the bottom and type your name.
Some Arguments to Consider
The NPRM is a proceeding that is broader than just the SAVI issue. The purpose of the docket proceeding is to review and update certain rules governing unlicensed RF emitting devices. The remainder of the issues in the NPRM are not generally a concern to Amateur Radio. The NPRM did not address any of the concerns in the ARRL comments on the SAVI Petition, and those can be restated. The most important argument, however, is that interference will inevitably result to Amateur stations from these mobile devices at unpredictable locations, transmitting at 110,000 uV/m immediately adjacent to the 432 MHz weak-signal band, in a band used extensively by Amateurs for control links for repeaters and other functions.
The other main point is that even if this high-power system is to be allowed to operate with high duty cycles (completely contrary to the basic reason for allowing such high power for periodic radiator devices in the first place) there is no reason whatsoever why 433 MHz should have been chosen for this application, and it should not be allowed between 420 and 450 MHz.
PLEASE PREPARE AND FILE YOUR COMMENTS IN THIS PROCEEDING TODAY!