1. 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 : theys@cetracoms.com
URL : http://www.cetracoms.com

2. ECCElectronic Communications Committee
CEPT
Mr. Georges de Brito
Chairman ETSI ERM RM
650, route des Lucioles
06921 Sophia-Antipolis Cedex
France
Email: georges.debrito@francetelecom.com
Working Group FM
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,
boltconsult@inet.uni2.dk
Mr Edgard Vangeel, ETSI liaison officer with ECC-WG FM, evangeel@cisco.com
Mr Fatih Yurdal, ECC-SRD/MG Chairman, yurdal@ero.dk
Ms Gabrielle Owen, Secretary ETSI ERM RM, gabrielle.owen@at-ez.nl