Band 401-406 Mhz: Medical Implants (MICS)

Band 401-406 MHz: Medical Implants (MICS)

Dear Mr. Rainer,

Coming back on our nice conversation we had on 21st of December 2005, I should like to obtain a written confirmation from WMO on the application of ITU-R SA 1346. The conditions mentioned in this document for the use of MICS in the band 401-406 MHz are quite clear, but our experience learns that some Spectrum Management Authorities (SMA) don’t see the frequency agility requirement as a mandatory requirement for the use of the band by Short Range Devices. The FMWG of CEPT made a liaison statement to ETSI, which confirms this strange interpretation (see annex). On the other hand the Spectrum Authority in Germany also has a deviating interpretation (see annex – BNETZA-in German)

For this reason, I should like a firm position from WMO, so that actions can be taken to guide the SMA’s to apply correctly the ITU-R SA 1346.

We also talked about participation in meeting of WMO concerning this matter. I guess it is the meeting “ WMO-CBS/ISS/SG-RFC: 16 & 17 March 2006 Geneva”

If it should be possible to invite me and Mr. Saad Mezzour to this meeting, than we can discuss and illustrate the matter in detail.

Thanks and best regards,

Cyriel THEYS

Chairman ETSI ERM-TG30 (Wireless Medical Devices) and Managing Director of CETRACOMS bvba/sarl Hector Henneaulaan 97 B-1930 ZAVENTEM Tel. +32(0)2 751 82 36 Fax +32(0)2 751 51 07 e-mail : [email protected] URL : http://www.cetracoms.com T P E C ECC Electronic Communications Committee Mr. Georges de Brito Chairman ETSI ERM RM Working Group FM 650, route des Lucioles 06921 Sophia-Antipolis Cedex France

Email: [email protected]

30 May 2005

REF: Liaison Statement to ETSI ERM RM on ULP-AMI

Dear Georges,

WG FM thanks ETSI for the Liaison Statement and the SRDoc received dealing with ULP- AMI operating in the 402-405 MHz band. WG FM discussed the issue during its May meeting in Vilnius.

WG FM would like to stress that the band 402-405 MHz is Class 1 for ULP-AMI usage under the R&TTE Directive 1999/5/EC and that, as a consequence, it is not suitable to add any additional restriction to ULP-AMI that intend to operate in this band. In particular, WGFM confirms that the current regulation, as given in ERC/REC 70-03, does not impose any restriction on the duty cycle, nor the use of LBT, in the whole band 402-405 MHz.

While the maintenance of Harmonised Standards is the responsibility of ETSI, WGFM is of the view that the low duty cycle technique can also be introduced as a possible option, as for LBT, in the Harmonised Standard for ULP-AMI in the 402-405MHz, but neither the LBT nor the duty cycle restriction should form part of the essential requirements.

Yours sincerely

Jim Connolly Chairman WG FM

Cc: Mr Sigurd Bolt-Soerensen, ETSI liaison officer with ECC-SRD/MG, [email protected] Mr Edgard Vangeel, ETSI liaison officer with ECC-WG FM, [email protected] Mr Fatih Yurdal, ECC-SRD/MG Chairman, [email protected] Ms Gabrielle Owen, Secretary ETSI ERM RM, [email protected]