Each year, ICMA conducts its Card Manufacturing
EXPO to bring together members, media and other individuals interested
in the card manufacturing industry. To maintain interest in the
EXPO, ICMA develops and distributes a series of press announcements
to keep you informed of important EXPO news.
The two major objectives were:
1. Harmonize the regulations with those of Europe and Australia, and
promote adoption by the global community.2
2. Allow higher field strengths to enhance data transfer for a wider
set of applications.
Preparing the technical requirements was rather easy, but nevertheless
to ensure that we followed proper procedures and had the proper documents,
one INCITS B10 member company volunteered the services of a law firm
to draw up the actual petition for the change and to start working it
through the FCC regulatory change process. The petition was initially
submitted in August 1998 and put on public notice October, 1998. It
soon ran into difficulties.
Federal Aviation Administration (FAA) engineers had the responsibility
to evaluate any negative responses to the petition. They were concerned
that the higher limits for spurious emissions beyond the 13.56 MHz +/-
450 kHz frequency band could cause interference problems. There was
also some concern in regards to an astronomy band being adversely affected.
After some meetings with FAA engineers, the petition was modified and
resubmitted to the FCC in December, 1999. The FAA engineers were satisfied
with the revised proposal.
Furthermore, FCC decided to include the INCITS B10 petition with their
own general updating of Part 15 rules which were basically unchanged
since 1989. They also included another petition concerning unlicensed
RFID devices operating at 433 MHz. Of course, doing this added more
delay.
About that time the FCC engineers were distracted by another project
mandated by the U.S. legislature, and so the petition languished in
FCC for about a year.
The final notice was published in November 2001. Seventeen public comments
relating to the B10 petition were received by the due date of February
12, 2002 of which 15 were positive comments and 2 were negative comments.
Public responses are due March 2002. The next step will be for the FCC
engineers to review all the comments and make a final recommendation
to the commissioners, a process that will take from 4 to 6 months under
normal conditions. Any diversion of the engineers' attention will result
in further delays. It is now expected that with the normal processing,
the final rule will be published in the last quarter of 2002.
So, what was originally estimated to take two years, will be finished
over four years after the start of the process in INCITS B10. While
working on a project taking this long is frustrating, it is understood
that making change in such a critical area must be done very carefully
and with full participation by all affected parties. And this, my colleagues,
takes time - just like developing standards.
1 InterNational Committee for Information Technology Standards,
B10 Technical Committee for Cards and Personal Identification
2 Later on, Japan and Canada began efforts to adopt the same rules for
13.56 MHz.