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

[John A. Diefenbach]

The ARRL message (below) is a follow up to my previous message on the same
subject.

I know you guys are busy, but this amateur radio band is very important to
us 'hams'.
We would all (at least the NH hams!) appreciate your effords to keep this
frequency band secure for amateur radio use.

Thank you.

John A. Diefenbach, K1TLV
Mason, NH 03048
----- Original Message -----
From: "ARRL Web site" <memberlist at www.arrl.org>
To: <jdief at tellink.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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