[ARRL-ODV:8121] Re: FCC proposes additional bands for Part 15 devices

In a message dated 12/20/2002 5:58:13 PM Eastern Standard Time, frenaye@pcnet.com writes:
Chris was correct in this one, it looks like they are concentrating on 3.6 GHz and the TV broadcast bands. The full NOI is now available:
Actually, there are two problems with this NOI. First of all, it asks the ugly, open ended question about what OTHER bands would be good for expanded Part 15 operation (a subject about which FCC has asked us in the past individually). Thus, our soft underbelly remains exposed. Second, and worse, this NOI takes the part 15 concept and stands it on its head. It asks about separation distances and D/U ratios for unlicensed devices! Absurd! Not to mention that it assumes unlimited jurisdiction to authorized high power Part 15 devices, a subject about which we are in the middle of a serious challenge at FCC, and perhaps, the courts. So, though the bands specifically mentioned are not directly threatening to us, the NOI has some conceptual flaws that we shouldn't allow to go unchallenged. 73, Chris W3KD
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