Shrine,s
Hospitals
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December 4, 2006
BY HAND DELIVERY
3551 NorUH 13ROAD STREET
PHILADELPHIA. PA 19140-41J1
TELEPHONE (215) 430-4000
www.shrinershq.org
DEAN 1\. 5HACKLEIT, CHAIRMAN. BOARD OF GOVE:P.NORS
RANDAL It 13 ETZ , M.D., CHIEf OF STAFF
SHARON J. RAJNIC, ADMINISTRATOR
Kevin J. Martin
Chairman
Federal Communications Commission
445 12th Street, SW
Washington, D.C. 20554
Re: Reply Comments
ETDocketNo. 06-135 &RM~1l271
Dear Chainnan Martin:
Researchers at Shriners HospitalS for Children, Philadelphia support the Alfred Mann
Foundation's ("AMP") request that the Comm.ission adopt service rules and allocate up to 20
MHz ofspectrum to accommodate new wireless wideband microstimulator devices on a
secondary basis. At our research center we are investigating how such devices can help children
with spinal cord injl.uies or other neuromuscular disorders to stand, step, use their hands and
anns to eat and drink and to remain physically fit with exercise. In most instances these
activities are only possible with electrical stimulation ofparalyzed muscles using wireless
microstimulators.
The establishment ofa service allocation is vital to the development ofa new generation of
wireless wideband medical devices designed to restore sensation and function to paralyzed limbs
and organs. These devices offer a safer, less invasive, and more effective treatment option than
is available with existing equipment.
The Commission's rules currently do not provide any spectrum to pennit operation ofnew
wireless wideband microstimulator devices. Although the Commission has allocated some
spectrum for medical telemetry operations and for medical implant conununications services,
this spectnun is not suitablefor wideband medical implant devices that require larger bandwidths
to perform more complex functions. Without adequate spectrum and service rules to support the
operation ofthese innovative devices, millions ofAmericans will be deprived ofa safe and
effective medical treatment for their debilitating health conditions.
THe $HIqINeRS HOSPITAL.S FOR CHIL.C:> ...I:"l, PHILADEL.PHIA, IS A'00,",PV"'~l.YPVBLIC; C;HARITY FAC'L.,TY. IT uS: NOY SUPPORTED BY PUBLIC
TAXES AND Rece,ves NO SUPPORT IN ANY FORM FROM THE FEDERAL GOVERNMENT, ,He S ....AT!! OF PENNSYLVANIA OR THe CITY OiS
PHILADELPHIA. 'lNE ACCEpT NO REIMeURSEMENT FOR OUR SERVJCES FROM ANY INSURANCE PROVIOER$ OR PATIENTS. ANY CHILO 'lNHO
SAT1SFIE. ..' ea,. . ADMISSiONS CRITeRIA 1$ TREATED WI" .EED.
The Commission's notice ofinquiry issued in the above-referenced proceeding is an important
first step toward adopting the necessary roles to encourage deployment ofthe next generation of
wireless wideband microstimulator devices. Researchers at Shriners Hospitals for Children,
Philadelphia urge the Commission to continue its efforts in this area by expeditiously granting
AMF's request for commencement ofa separate rulemaking.
1
Randal R. Betz, M.
ChiefofStaffand Director ofResearch
Shriners Hospitals for Children, Philadelphia
cc: Marlene H. Dortch
FCC Secretary
2