ARRL response on medical devices in 70 cm band

The ARRL has responded to the Federal Communication Commission (FCC) proposal to allocate frequencies for Medical Devices in the 70 cm Band

ARRL General Counsel Chris Imlay, W3KD, on behalf of the ARRL, filed comments on August 11 regarding a Notice of Proposed Rule Making (NPRM), ET Docket 09-36, issued by the FCC in March 2009. In the NPRM, the FCC proposed to allocate spectrum and adopt service and technical rules for the utilization of new implanted medical devices that operate on 413-457 MHz (70 cm).

In its comments to the FCC regarding the NPRM, the ARRL said it believes that the choice of frequency bands for Medical Micro-power Networks (MMNs) as proposed is "unfortunate and unnecessary" and that "the Wireless Medical Telemetry Service (WMTS) offers a far more suitable solution than does the 413-457 MHz band for MMNs."

ARRL Chief Executive Officer David Sumner, K1ZZ in his editorial at http://www.arrl.org/news/features/2009/
06/01/10784/ said that the FCC's proposed rules raise two concerns: "First and foremost, the devices would be required to accept interference only from stations authorized to operate on a primary basis. The Mann Foundation has assured us that amateur stations will not cause its system to malfunction, so we see no reason why this cannot be reflected in the rules, even though our allocation is on a secondary basis. Second, while the Mann Foundation researchers appear to have done their homework, others who try to take advantage of the new rules may not be as rigorous."

The ARRL asserts in its comments that due to redundant interference rejection design, the devices developed by the Alfred Mann Foundation "appear to have some reasonable prospect of avoiding the disastrous consequences of RF interference to implanted MMNs."

The ARRL stressed, however, that the FCC should not permit the marketing of MMNs or any similar device in the 420-450 MHz band: "(1) unless and until thorough RF interference susceptibility testing is conducted on the AMF devices relative to high power Amateur Radio equipment; (2) at parameters other than those inherent in the Mann system, which incorporates notably redundant interference rejection design characteristics; and (3) without very specific patient notifications and labeling of the body-worn MCUs [Master Control Units] and other portable components which provide firm assurance that the devices will not malfunction in the presence of RF fields from authorized radio services in the same bands."

Read the full ARRL news item at
http://www.arrl.org/news/stories/2009/08/12/11020/?nc=1

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