Indianapolis - Sep 11, 2009 - The Society of Broadcast Engineers submitted reply comments to the Federal Communications Commission in ET Docket 09-36, a notice of proposed rulemaking proposing an allocation for Medical Micro-Power Network (MMN) devices at 413-457MHz. SBE Reply comments supported its stated position that the proposed use of these devices in this band, particularly in the 455-456MHz RPU band, would endanger medical patients using MMN devices due to harmful interference from lawfully-operated RPU mobile stations that would be impossible to predict.
In this respect, SBE articulated its agreement with concerns raised by the Association of Public-Safety Communications Officials-International, Inc. (APCO), by the Land Mobile Communications Council (LMCC) and by the Association for Maximum Service Television, Inc. (MSTV), in their previously-filed comments to the FCC.
SBE noted that the MMN proponent, Alfred Mann Foundation, rejected the use of the UHF TV band, calling it "unsuitable" due to high power, but the proposed RPU band would be subject to similar circumstances, given the location of RPU antennas in potentially close proximity to MMN patients. SBE also noted that it is much more likely to be in closer proximity to a high-power RPU than to a UHF DTV transmitter, and therefore more likely to be exposed to dangerous RF fields in the RPU bands.
Complete text of the SBE's reply comments, as well as its earlier-filed comments in this proceeding can be found at http://sbe.org/gov_fcc.php.