The FCC Proposes to Allocate 20 MHz of Spectrum in 413-456 MHz Band For Implanted Neuromuscular Devices

The FCC has released a Notice of Proposed Rulemaking (NPRM - ET Docket 09-36) seeking
comment on a proposal to allocate 20 MHz of spectrum in the 413-457 MHz band for use by wireless medical devices that could be implanted into the human body and used to restore sensation and mobility to paralyzed limbs and organs. The devices would act as a wireless medical micro-power network (MMN) within the patient. Among the conditions that could be treatable using MMNs include polio, ALS (Lou Gehrig's disease), cerebral palsy, and spinal cord injuries.

The 400 MHz band is targeted because it is optimal for RF propagation through body tissue. The devices would require at least 5 MHz of bandwidth to function and would operate on a low power, secondary non-interference basis. Twenty MHz of spectrum in four band segments are proposed so that the device would have four options in case one
band segment was already in use in a given area. The NPRM seeks comment on the feasibility of four different band segments:

* 413-419 MHz

* 426-432 MHz

* 438-444 MHz

* 451-457 MHz

Comment is also sought on:

* Potential for interference between MMNs and incumbent users

* Service rules (licensed or unlicensed, definitions, permissible communications,
eligibility, etc.)

* Technical rules (power limitations, bandwidth, frequency stability, channelization,
antenna locations, etc.)

Currently, the government is primary... we are secondary. If the new devices are approved on the 70cm band as secondary users, what does that make us? Third-tier users or equal priority to the medical devices?

Does anyone REALLY think that if these devices are approved in the 70cm band, that the FCC will put Amateur Radio as a priority to human lives? If there'd be ANY risk of our (ham) radio's interfering with those devices... any risk at all... you can be sure that we'll lose the 70cm band completely.

The problem is... how can we, as amateur operators, complain about losing a band when our sacrifice may save lives (or at least drastically improve the standard of living for people.)don't get me wrong - I'm not happy that I'd lose UHF repeaters, that my ability to cross-band repeat would disappear, etc. I'd love to write a letter to the FCC giving reasons why those devices shouldn't run on 70cm. My problem is, any time I try to compose something, I feel like a selfish child: whining that something I was given for free is being taken away to further medicine.

The flip side is that the UHF band, used by amateur operators, has already been used to save lives in disasters.