[Scan-DC] Heads up on Petition for Rule Making at the FCC

[Andrew Clegg]

Although this is a scanner newsgroup, I know that there are many hams on
here who may be interested in the following. A scientific research
foundation (the Alfred Mann foundation) has filed a petition for rule making
with the FCC, requesting that four 6-MHz channels in the 413 - 457 MHz
frequency range be allocated on a secondary basis to the "Medical Micropower
Network Service," or MMNS. This service would essentially be implanted
medical devices and ancillary external diagnostic equipment that would
facilitate the use of electronic currents to "activate and monitor nerves
and muscles to restore sensation, mobility, and other functions to paralyzed
limbs and organs." While I am all for the possible benefits of such devices,
my concern is that two of the channels would fall within the 440 ham band,
specifically 426-432 MHz and 438-444 MHz. Since amateur radio is secondary
in the 420 - 450 MHz band, we would essentially be on an equal allocation
basis with the proposed MMNS. This means that if we caused interference to
this service, we would generally be expected to work with the MMNS to
alleviate the interference. It is hard to imagine, for example, how we hams
could come out on the winning side of a coordination battle with a wounded
vet who might rely on these devices to restore motion in a limb mangled by
an IED.

It is unlikely that these devices, as proposed, would cause interference to
ham radio, but the reverse problem (interference from ham radio into MMNS)
is a distinct possibility. The two channels inside the 440 band overlap
exactly with ATV simplex and ATV repeater input channels, as recommended in
the ARRL band plan.

I have posted the petition for rulemaking on my web site. See
http://www.w4je.com/mmns_petition.pdf. The FCC has assigned it RM-11404. At
this point, it is just a petition requesting that the FCC initiate a rule
making. It is not a rule making. The Commission invites comments on the
petition, with the initial deadline apparently November 3 (but you will want
to confirm this). Reply comments on the petition would be due around
December 3 (confirm this as well). Comments can be filed through the FCC's
online Electronic Comment Filing System (ECFS). No money or lawyer needed,
but I recommend that if you do file, rational and thoughtful comments work
much better than emotional off-the-cuff comments.

I am working my way through the petition in detail, but after my first read,
I do have some concerns about the possibility of interference from amateur
radio into MMNS (not to mention the possibility of interference from
government land mobile systems below 420 MHz and from other land mobile
systems above 450 MHz). If you are interested, please take a careful look at
the petition and consider filing comments. If a rule making is initiated
based on this petition, you will have at least one additional opportunity to
comment in the future.

73 to all,
Andy
W4JE