PCIA Urges Aggressive Approach on Part 90 Rules
The FCC should amend its Part 90 rules so more use is made of bands below 470 MHz, PCIA said in reply comments at the commission in docket 07-100. PCIA said it’s an active member of the Land Mobile Communications Council (LMCC), but the council’s proposed rules in this area “represent an overly conservative approach.” Various commenters continue to disagree about whether the FCC should allow secondary access for medical telemetry devices in 2.5 MHz of the 1427-1432 MHz band (CD May 18 p7), assigned to nonmedical telemetry use.
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"While a conservative approach was warranted when LMCC initially addressed this issue several years ago, it was always agreed that the issue should be revisited as experience was gained,” PCIA said. “Given the success of the implementation of narrowband (and very narrowband) systems thus far, PCIA believes that it is now an appropriate to take a more aggressive approach in implementing additional narrowband systems and achieve the Commission’s original goal of providing for greater spectral density in these bands.”
PCIA urged the FCC to require the use of more-accurate coverage prediction methods in the bands. “While R-6602 curves and related methodologies have served the industry well over the past decades, it is recognized that advances in computer technology make it possible to utilize newer techniques without sacrificing coordination speed of service and without causing a significant amount of engineering litigation,” the group said. “As it is acknowledged that these tools and criteria yield more accurate results, PCIA proposes to utilize similar criteria for systems below 470 MHz. Because this proceeding involves adopting protection criteria which will continue after narrowbanding has been completed, it makes sense to take the opportunity now to maximize spectrum availability while increasing prediction accuracy."
On a key issue, Philips Healthcare Systems urged the FCC to allow Wireless Medical Telemetry Service (WMTS) use of the nonmedical portion of the 1427-1432 MHz band on a secondary basis. Philips made the original request that medical devices be allowed to use this spectrum, which was opposed by the LMMC. “Demand for wireless devices in hospitals continues to increase due to the now widespread recognition that monitoring patients leads to statistically improved outcomes, the data from multiple sensors can be statistically analyzed by software embedded in the system to detect trends that otherwise might go unnoticed, and the data can be ported seamlessly to the patients’ electronic health records that are strongly encouraged by recent Congressional enactments,” Philips said.
The American Society for Healthcare Engineering of the American Hospital Association agreed: “As technology has advanced, and manufacturers of WMTS systems have developed a variety of approaches for serving this critical health care need, the opportunity for WMTS to utilize spectrum in which the WMTS is only a secondary permitted use has also improved.”
But Itron said the record provides no new evidence that secondary use of the 1427-1432 MHz band won’t cause problems for incumbents of the band. “Only one comment has been filed in favor of allowing WMTS secondary operations,” Itron said. “Given the unresolved concerns about the impact of secondary operations on patient safety, the Commission should not grant WMTS secondary status on the non-medical portion of the band.”