Medical Body Area Network Service

This is provided as support of the proposal by General Electric Corporation which has found support with IEEE P802.15 TG6 (Body Area Networks), IEEE P802.15-08-0069-01-0006.  Please see Ex Parte of GE Healthcare in ET Docket No. 06-135 (December 27, 2007) (citing the potential benefits of a new Medical Body Area Network Service (“MBANS”), spectrum allocation and proposing MBANS under Part 95 of the Commission’s rules), (“GE Healthcare Ex Parte”). The need to support the technical requirements of a Medical Body Area Network is vital to improve the process re-engineering of healthcare delivery surrounding the patient.  This additionally reduces risk mitigation in the reduction of the cabling infrastructure surrounding the patient and lowers overall patient use cost models both in the ambulatory and critical care delivery models. To accomplish this it is important to consider the overall spectrum that will decrease any potential for EMI, (electromagnetic interference), and also provide the highest level quality of service. Quality of service being defined as bandwidth dedicated to the MBANS and not a shared medium with other unlicensed services and/or frequencies. This cannot be accomplished by sharing the traditional 802.11a/b/g/n (2412MHz-2484MHz/5180MHz-5805MHz) WLAN (Wireless LAN) model or even WMTS (Wireless Medical Telemetry Services (608-614MHz/1395-1400MHz/1427-1432MHz).  Dedicating the use of 40MHz from 2360MHz to 2400MHz will ensure peaceful co-existence and non-interference for this medical application. As a life critical spectrum space and design, there will be a requirement and strict parameters for the use.  For example all stations will need to employ an unrestricted contention based protocol, the maximum emission bandwidth will be 1MHz, the maximum EIRP (Equivalent Isotropically Radiated Power) will not exceed the lesser of 1mW or 10 log BW _{20db MHz} dBm and the same out of band (more than 500 kHz outside of band), field strength limits as applies to MICS (Medical Implant Communication Services 402-405MHz).   Since this is not proprietary to a specific company but driven as an industry standard as a whole, all respective patient monitoring companies and ultimately the end user in the integrated delivery network will benefit from its adoption. Time to market and NRE (Non-Recurring Engineering), will be much lower as there will be industry collaborative efforts and ultra low power Bluetooth, (2400-2483.5MHz) Zigbee/802.15.4 (2400-2483.5MHz) and/or other GFSK (Gaussian Frequency Shift Keying) transceivers radio chipsets from Intel and/or Texas Instruments or similar like companies can be easily modified.  The use of 802.11a/b/g/n is not recommended due to power consumption for a mobile device as well the stated aforementioned shared medium (bandwidth) concerns.   It will be important to engage 802.18 TAG to convey objectives of 802.15.6 and benefit this overall proposal. It is highly encouraged that the FCC continue toward a notice of proposed rule making