<p> Band 401-406 MHz: Medical Implants (MICS)</p><p>Dear Mr. Rainer,</p><p>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)</p><p>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.</p><p>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”</p><p>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.</p><p>Thanks and best regards,</p><p>Cyriel THEYS</p><p>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</p><p>Email: [email protected] </p><p>30 May 2005</p><p>REF: Liaison Statement to ETSI ERM RM on ULP-AMI</p><p>Dear Georges,</p><p>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.</p><p>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.</p><p>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.</p><p>Yours sincerely</p><p>Jim Connolly Chairman WG FM</p><p>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] </p>
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