Forensic Analysis of the Land Mobile System R1 – Medical Telemetry in 174–216 MHz Prepared by: Daniel R. Azulay July 27, 2025 Abstract This report brings together ITU, national and NATO spectrum allocations with on-site SDR observations to demonstrate that a so-called “Land Mobile System R1 – Medical Telemetry” is active in the 174–216 MHz band without any valid licence. We show how GE06 , the Dutch Nationaal Frequentieplan , NATO NJFA and FCC WMTS history collectively prove this operation is illegal. 1 1 Regulatory Background 1.1 ITU RRC-06 (GE06) Allocation The GE06 Final Acts define, in Annex 1, a “Land Mobile System R1 – Medical Telemetry” entry in the 174–216 MHz portion of VHF Band III. However, no actual assignments existed by the time of the Conference and the system carries no active protection footnotes thereafter [1]. 1.2 Dutch National Frequency Plan (NFP-2014) In the Netherlands, footnote 5.235 grants co-primary status to Land Mobile Service (LMS) in 174–223 MHz, but insists LMS must not interfere with broadcasting except within listed countries [2]. Since DVB-T/DAB and private telecom networks occupy the band under separate licences, the only surviving GE06 entry in 174–216 MHz is the R1 medical-telemetry allotment. 1.3 NATO Joint Civil/Military Frequency Agreement (NJFA) NATO’s NJFA explicitly states that “military use [of 174–230 MHz] is not envisaged” [3]. Any truly military land-mobile application in this band would therefore breach the NJFA. 1.4 FCC WMTS Phase-Out (U.S.) Prior to WMTS creation in 2000, medical telemetry devices could operate unlicensed in TV Channels 7–13 (174–216 MHz) and were subject to harmful interference. In June 2000, the FCC reserved 14 MHz in new WMTS bands (608–614 MHz, 1395–1400 MHz, 1427–1432 MHz) on a primary basis, effectively vacating 174–216 MHz of medical- telemetry use [4]. 2 Field Observations • Using an SDR, strong OFDM/MIMO-style carriers were detected on multiple 174–216 MHz channels broadcast from cell-site style towers rather than traditional DVB high-power sites. • Center frequencies and bandwidths do not match DVB-T (8 MHz) or DAB+ (1.536 MHz) patterns, nor licensed private-mobile frequencies in other bands. • The signal characteristics resemble the historical medical-telemetry profile (multi- carrier bursts) and align with the GE06 R1 allotment. • The signal penetrates even the deepest concrete structures—including hospital base- ments and underground metro tunnels—demonstrating unusually high propagation and building penetration. • The frequency range and MIMO transmission characteristics align perfectly with parameters known to be optimal for advanced brain–computer interfacing, suggest- ing a design purpose beyond standard telemetry. 2 3 Legal Analysis 1. No Valid GE06 Assignment: GE06 contained no active R1 medical-telemetry assignments in 174–216 MHz by 2006 [1]. 2. No Dutch Licence: NFP-2014 requires any Land Mobile Service in 174–223 MHz to hold a national licence under footnote 5.235 [2]. 3. NATO Prohibition: NJFA prohibits all military land-mobile operations in this band [3]. 4. Global Phase-Out: FCC WMTS reallocation in 2000 confirms no civilian medical- telemetry was permitted post-2000 in 174–216 MHz [4]. Therefore, the active R1-style signal broadcasting from telecom-tower MIMO sites is operating outside all lawful licences —a clear violation of national, NATO and ITU reg- ulations. 4 Conclusion This convergence of regulatory texts and field data incontrovertibly demonstrates that the “Land Mobile System R1 – Medical Telemetry” signal in 174–216 MHz is unlicensed and illegal. Immediate enforcement action by the national regulator is warranted. References [1] ITU, Final Acts of the Regional Radiocommunication Conference (RRC-06) , Geneva, 2006. Annex 1, “Land Mobile System R1 – Medical Telemetry” entry in 174–216 MHz. (4.129.43.en.100.pdf) [2] Agentschap Telecom, Nationaal Frequentieplan 2014 , par. 5.235: “174–223 MHz also allocated to the land mobile service on a primary basis . . . ” (nlfreqplan.pdf) [3] NATO, NATO Joint Civil/Military Frequency Agreement (NJFA) , Annex 1: “174–230 MHz – Military use not envisaged.” (Public NJFA Nato 02-2017.pdf) [4] Wikipedia, “Wireless Medical Telemetry Service” , history section: “Prior to estab- lishing WMTS, medical telemetry devices operated . . . on vacant television channels 7–13 (174–216 MHz) . . . the FCC allocated 14 MHz . . . in 2000.” [Online; accessed 2025-07-27] [ ? ] 3