Mr. Robert J. Ungar
Arter & Hadden, Attorneys
for EDAP Technomed
1801 K Street, N.W. / Suite
400K
Washington, DC 20006-1301
Dear Mr. Ungar:
As you are aware the Jupiter Space Station is a radio astronomy research facility which conducts solar and lunar experiments at the 1296 MHz frequency, which is in conflict with the harmful interference produced by your new Prostatron being marketed on the Internet.
This letter is a follow-up to your two letters of May 5 and June 9, 1997. Between these two letters we responded with a proposal to EDAP Technomed to cooperate in a manner so as to share the 1296 MHz frequency with EDAP.
Your response of June 9.
1997 indicates that both you and EDAP Technomed are confused as to our
position on our 1296 MHz objection to the FCC. We wish to now restate our
position and clear up some of your confusion.
Please understand that our
frequency is either 1296 MHz or 1.296 GHz, not the above listed frequency...
let us be sure that the basics are clear.
Based on the initial report
of FCC testing results for the Prostatron there does not exist a "perceived"
problem... the Prostatron generates radio frequency interference (RFI)
or FCC defined harmful interference in excess of FCC allowable limits.
This is not a perception on our part, Mr. Ungar, this is a published fact
in the public domain. Since EDAP is not yet a shared user of the 1296 MHz
FCC frequency allocation, we would appreciate that you refer to the Prostatron
emissions as either "RFI" or FCC defined "harmful interference."
Our research frequency is
in a band where the FAA is the primary user and we in the Amateur Service
are secondary users. We understand that the FAA signal may be received
by our antennas; however our site surveys have yet to see any FAA radar
signal. In any case, if we did have any FAA radar signal, the signal
is clean, precise, well documented, and transmitted in a pulsed mode which
we can easily identify and null out of our research data by using transfer
functions in digital signal processing (DSP). The RFI generated by Prostatron
can not be easily detected and requires a full bandspread analysis
to isolate it, and yes, with extremely expensive equipment. The JSS does
not own or employ spectrum analyzers because we by cooperating with our
primary user, the FAA, have developed compatible microwave systems in their
signal nature and operation. EDAP Technomed in its best light has created
a 1296 Band interference emission source, Prostatron.
Mr. Robert J. Ungar
June 23, 1997
Page 2
In our phone conversation
Mr. Manning seemed baffled by the fact that the CW radio power level of
the Prostatron (60 watts) could be sent by our Link Station in Tulsa to
the moon, bounced back to Earth (a 500,000 mile round trip), and detected
by our Link Station in Pendleton, SC. Obviously no one wants any of this
Prostatron RFI radiation in their noise floor from a moon bounce, much
less from the same section of the country. The Jupiter Space Station is
not assuaged by your technical arguments.
JSS is not concerned with PCS signals entering our microwave system; we are most concerned with hitting one of Bill Gates' proposed 800 "Birds" with our signal. And this is one of the reasons why the FAA respects us: because we show operational prudence and shielded/filtered microwave equipment design so as to be a good partner on 1296 MHz, unlike EDAP Technomed.
In rank order priority, here is our position on your FCC waiver request:
Respectfully Submitted,
John D. Bernard, JSS Project Director
cc: Dr. Michal J. Marcus,
FCC
Steven Butcher,
NTIA
American Radio Relay League
Eric Poincelet,
EDAP Technomed
Thomas N. McCausland,
Siemens AG - Siemens Medical Systems
Nippon Eurotech
US Senator Strom Thurmond (SC)
US Senator Fritz Hollings (SC)
note: This response can also be viewed on the Internet at: http://members.carol.net/~saser