The maximum power was 100 mW ERP for Passive tags and 4 W for RFID Systems in the 915.2-921 MHz band.

Itron and Ontec propose the deletion of the reference “ECC Report 200” for the band 915.2-921MHz because it provides no more specific information.

Itron and Ontec propose the Passive tags to operate in the band 915.2-915.4 MHz and a maximum power of 100 mW ERP.

Itron and Ontec propose that the Modulating RFID Systems (non-FHSS) operate in the band 915.4-920.9 MHz and a maximum power of 4 W EIRP using the standard EN 302 208.

Itron and Ontec propose that the non-Modulating backscatter RFID Systems operate in the band 919.2-921 MHz and a maximum power of 4 W EIRP using the standard EN 302 208.

Mr. Pretorius proposes the Authority replace frequency ranges 915.2-915.4 M to 919.2-921 M to the new range 915.3-920.9 MHz in line with the ETSI standard EN 302 208 and grandfather for 12 months the frequency range 915.4-919.2 MHz because the FCC standard is inefficient in dense reader mode.

RAIN RFID submits that the Relevant standard for the band 865-868MHz (Channel 5,6,8,9,11,12,14 and 15) is most probably EN 300 220.

RAIN RFID submits that the passive tags band 915.2-915.4MHz be updated to 915.3-916.1 MHz, 916.5-917.3 MHz, 917.7-918.5 MHz, 918.9-919.7 MHz, and 920.1-920.9 MHz according to ETSI Standard EN 302 208 and ECC Report 200.

RAIN RFID proposes the deletion of FHSS and 200 kHz channel spacing in the band 915.4-919.2MHz.

RAIN RFID proposes that reference be made to ERC Rec 70-03 instead of ECC Report 200 only for the bands 915.2-915.4MHz, 915.4-919.2MHz, 919-919.2MHz, and 919.2-921MHz.

The Authority notes the recommendation about the removal of the “ECC Report 200” for the band 915.2-921MHz, however the Authority maintains that the Report is still relevant as it provides vital co-existence

of various applications within the band.

The Authority notes the recommendation regarding operating frequency and maximum power for passive tags, however the Authority resorted to updating the frequency range to 915.3-920.9MHz with a maximum power of -10 dBm for Tags in order to align with the reference materials ECC Report 200 and the standard EN 302 208.

The Authority notes the recommendation regarding operating frequencies and maximum powers for Modulating RFID Systems (non-FHSS) and Non-Modulating backscatter RFID Systems, however the Authority resorted to updating the frequency ranges to 916.1-916.5 MHz, 917.3-917.7 MHz, 918.5-918.9 MHz, and 919.7-920.1 MHz in order to align with the reference materials ECC Report 200 and the standard EN 302 208.

The Authority notes the submission to adopt the ETSI standard in the band 915.3-920.9 MHz and grandfather the FCC standard for 12 Months in the band 915.4-919.2 MHz, however the Authority resolved not to grandfather the frequency band 915.4-919.2 MHz and will accept both FCC and ETSI regimes in their respective frequency bands as supported by the section 7(1) of the Type Approval Regulations in Government Gazette No 36785 (Notice No 578).

The Authority notes the submission about the proposed relevant standard EN 300 220 for RFID application in the band 865-868MHz however the Authority maintains that the standard EN 302 208 is technology-specific and takes precedence over generic standards because the technology-specific standard prescribes additional essential performance requirements which are not included in the generic standards.

The Authority notes the submission about passive tags band 915.2-915.4 MHz; however, the Authority updated the frequency range of the tag to the band 915.3-920.9 MHz to align with the reference materials ECC Report 200 and standard EN 302 208.

The Authority notes the recommendation about the deletion of FHSS and 200 kHz channel spacing in the band 915.4-919.2MHz, however the Authority maintains that those requirements are still relevant as per the prescribed FCC standard requirements.

The Authority notes the recommendation to amend the reference to ERC Rec 70-03, however the Authority maintains that the ECC Report 200 is applicable and supports how the standard EN 302 208 apportion the sub-bands within the frequency range 915.3-920.9 MHz whereas ERC Rec 70-03 frequency allocation (915-921 MHz) coincides with a portion of the licensed IMT band.