A GUIDELINE TO ISSUES RAISED IN FCC WT DOCKET NO. 10-119 (GMRS)

By P. Randall Knowles, J.D., KAA 8142; June 21, 2010


	In this Docket, the FCC proposes to make massive and radical
changes to the GMRS, changes which would be more substantive than any
others since the ill-fated "Consumer Radio Service" (PR Docket 86-38)
proposal nearly 25 years ago.  (An avalanche of opposition by the GMRS
user community defeated that earlier proposal. We can and must do it
again!)

	If you are concerned about the damages that the proposals in
this NPRM WT-10-119 would make to your existing or planned GMRS
operations, you should send CONSTRUCTIVELY critical comments to the
FCC. 

	This file discusses what we feel are the basic, most important
issues. The procedures for composing and submitting your comments to
this FCC Docket (including the time deadlines) are covered in a
SEPARATE publication. (See http://www.provide.net/~prsg/whatsnew.htm
for further details.)


	I.	Use Your Own Language.

		A.	When writing your FCC comments, use your own language.
Reflect on your own real experience. Don't merely copy sections of this
Guideline or others' comments.


	II.	Licensing.

		A.	It is critical to explain to the FCC that GMRS users 
WANT licensing.  You might want to describe your experience with
unregulated FRS operations and contrast that to what currently exists
in GMRS. Discuss what users want GMRS to continue to be  - a useful
radio service that fosters reliable communications.  It's vital to
show the FCC that GMRS is NOT a TOY radio service, and that it should
remain something that users can rely upon over a reasonable range. 

		B.	We think it's important to make clear to the FCC
that responsible users WANT FCC enforcement to keep the service from
falling into chaos, and are willing to pay a modest fee with a license
application to assure that continues.

		C.	The proposal as it stands not only would eliminate
licenses, but any age limits as well.  Any experience you have with
unsupervised small children playing with FRS radios and how that
would destroy what GMRS now is would be helpful.

		D.	No licensing also would mean the end of the limits
on commercial businesses usurping or taking over GMRS for business
band use.  If you had experience with interference or takeovers of
GMRS by commercial users before the rules that prohibited this were
adopted in 1987, discuss this problem.

		E.	No licensing would also result in the end of any
meaningful way to regulate or limit who uses a repeater.  If you
operate a repeater, or if you are part of a group that sponsors a
repeater, this could destroy your ability to control who uses your
system.  It's vital to make the FCC aware of the absolute necessity
for licensing for shared use of repeaters.

		F.	Both call signs and any identification would be
eliminated under the proposed new rules.  But the FCC would still
expect GMRS users to "cooperate in the selection and use of
channels, including limiting communications to the minimum
practicable time, to reduce interference, and to make the most
effective use of the facilities."  [Proposed rule 95.103(a).]  
You need to explain to the Commission that coordinating with
others in the absence of any identification is completely
unworkable and totally impractical.  (Note that in paragraphs
19 and 20, the FCC recognizes the importance of facilitating user
cooperation by proposing to continue specifically disallowing
voice scrambling.) 


	III.	Repeater Systems.

		A,	While the new rules as now proposed do not
eliminate repeaters in GMRS, the discussion portion of the
Notice (at paragraph 34) questions if repeaters and even base
stations unduly use up too much of the limited spectrum
(frequencies) for GMRS.  It's vital to explain to the FCC how
necessary repeaters and base stations are to the service, and how
limited GMRS would be without them.  Again a contrast to FRS and
how each service serves different communications needs is
important.  

		B.	If you have any experience or knowledge with
any public service activities on GMRS that could NOT be
accomplished without repeaters, please mention this to the
FCC.  Public service activities are clearly in the "public
interest," a standard that the US Congress has charged the FCC
to follow.

		C.	You might want to describe typical
communications that you carry on in GMRS that could NOT be
accomplished in FRS (or in GMRS without repeaters).  It's vital
to show the Commission that removing repeaters would not only
completely transform the service, but make it into another FRS.
This would not be in the public interest. It would remove and
deprive the public of an existing useful communications
capability, and it would merely duplicate capabilities already
provided by FRS. 

		D.	There is some indirect suggestion in the
Docket 10-119 discussion that the development of cellular
telephone has lessened the need for GMRS.  You need to explain
to the FCC the types of communications that you use GMRS for,
and can not carry out with cellular. (For example
communications between 3 or more units at a time or in areas
where cellular coverage is poor or non existent.)  

		E.	If you have experience using direct
("talk-around", sometimes called "simplex") and can describe
the extremely limited range and reliability, please do so.

		F.	The discussion portion of WT Docket No.
10-119 also suggests that business use of GMRS should be
routinely permissible.  This flies in the face of the language
about limited spectrum for repeaters.  How can it be there is
plenty of spectrum for businesses (who have literally hundreds
of frequencies in various different Part 90 services) if there
is such a potential shortage for repeaters?  You need to
emphasize that GMRS now is configured to serve users and
needs not provided for elsewhere, and that business needs are
well met elsewhere (including FRS for very short range).


	IV.	Technology Changes.

		A.	The FCC claims that it is revising the rules
"to reflect more accurately current technologies and the ways in
which services are being used today." [Paragraph 4.]  Clearly
they do not understand the ways in which GMRS is being used.  
Your experience as a GMRS user is the best way to refute this.
You as a user are in the best position to tell the FCC that
the proposed rules changes for GMRS are NOT "needed to account
for technological developments and changes in how [GMRS] is
being used by the public."  [Notice, paragraph 9.]

	V.	Organization of the Rules.

		A.	Ever since the first FCC Rules were adopted
in 1948, each different service has been covered in a separate
Subpart.  (The original GMRS, called Class A Citizens' Radio in
Subpart A, later the low power UHF in Subpart B, radio remote
control [for model airplanes, etc.] in Subpart C, and CB in
Subpart D, etc.)  While it is true that this resulted in some
duplication in the various different Subparts where rules were
the same or similar for different services (CB and GMRS, for
example), the Commission specifically requests comments on
whether its reorganization scheme would be easier for you as
a user to read. Or (as we believe instead) would keeping each
service separate (all GMRS rules in one place) be easier?  We
believe strongly that it makes more sense for each service to
have all of its rules in one place where users can easily find
them, instead of having to hop around to different places in
Part 95. [Notice, paragraph 10.]

		B.	Would you also prefer GMRS technical rules
to be in the same place, together with all other GMRS rules?
Rule collocation should make it easier to find which rules
actually apply to the service.

		C.	Is the FCC correct that GMRS users refer to
frequencies by channel number? In practice, most GMRS users
refer to frequencies by the last three digits, such as "675."
[Notice, paragraph 12.] The FCC has not established any defense
for this proposed change in common nomenclature for GMRS. Such
a change would merely move the GMRS rules closer to CB, which
most GMRS users would resist.

		D.	Do you need the question-and-answer format
of the CB Rules to avoid confusion?  Or do you understand the
GMRS Rules the way they are now written?  [Notice, paragraph
11.]


	VI.	Power Limits.

		A.	In paragraphs 31 to 35, the FCC questions
what new power limits should be adopted.  You should make
the Commission aware of typical sources of radio equipment
for GMRS users.  To facilitate the widest availability of
equipment to the public, both used and new "land mobile"
equipment should be available for GMRS users.  GMRS is merely
a submarket of land mobile, and any rules that restrict or
prevent certain land mobile radios (with a 50-watt maximum
transmitter output) from being used in GMRS are not in the
public interest or the original intent of the service that
it be as widely available to the public as possible.

		B.	As a practical matter, do you encounter
any portable radios that have more than 5 watts?  Are you
aware of any problems with existing 5-watt gear as far as
safety for people using such radios, the same as in other
services (police, fire, business band, etc.)?

		C.	Do most users use a high/low power switch
to extend battery life whenever possible?  Is 5 watts
sometimes necessary to obtain penetration in buildings,
etc.?  How about connecting portable units to external
antennas, is that commonplace in your experience in GMRS?
Do you understand why the FCC needs to or is proposing to
change the current rule?

		D.	Would reducing the power allowed for
mobile or base stations reduce the variety and number of
land mobile radios one could buy to use in GMRS?

		E.	The FCC proposal [Notice, paragraph 32]
to limit GMRS portable radios to just 2 watts ERP (effective
radiated power) has been misunderstood or misrepresented by
several commenters already. Even a 5-watt portable radio
produces little more than 2 watts ERP, considering the loss
of most rubber duckie-type antennas. The FCC did NOT propose
to apply a 2-watt ERP limit to standard mobile (vehicular-
mounted) radios, on which the current 50-watt limit would
still generally apply.

		F.	For those who live or operate north of
Line A or east of Line C (within 60 to 100 miles of the US/
Canadian border), the FCC has proposed (Notice, new paragraph
95.35, on page 53) that ALL GMRS stations would be restricted
to not more than 5 watts ERP. (For a description of Line A,
see http://www.provide.net/~prsg/line-a.htm ) The current GMRS
rules have already long restricted small control stations to
just 5 watts ERP when operated north of Line A or east of Line
C. The proposed change would impose this limit on ALL other
classes of GMRS stations (including mobile/vehicular radios,
base stations, and repeaters) as well. Would such a change
impact or restrict your operations?


	VII.	Narrow Banding.

		A.	In paragraph 36 the FCC makes reference
to "GMRS manufacturers."  You should explain to the
Commission that except for the combo FRS/GMRS market, there
are not any GMRS manufacturers, but rather land mobile radio
manufacturers who certify their equipment for BOTH Parts
95 and 90.  It's also important to make the Commission aware
that a large number of GMRS users buy USED land mobile
equipment and that by allowing continued 25 kHz operation
as long as possible, there is a significant advantage in
making equipment available at reasonable prices to a wide
segment of the public, even as the use of such equipment is
being phased out in those Part 90 (etc.) services.

		B.	How severe a burden would it be to
replace all of your GMRS radios to go "narrow band"?  Is
the cost burden greater on you as an individual than on
business band users or governmental entities with tax
funds?

		C.	Where would new "narrow band" repeaters
come from?  Would such a rule essentially require all GMRS
repeater owners to replace existing equipment with
expensive brand new gear?

		D.	GMRS migration eventually to “narrowband”
operation is probably inevitable, but it is likely to take
a much longer period of time than in the Part 90 services.


	VIII.   Data Communications.

		A.	As most of you know, the "roger-beep" of
FRS radios is very annoying and distracting.  Many users
will not listen to such non-voice noise for long.  Those of
you who have experience listening to MDC(R) and other similar
data formats no doubt have similar observations.  Your
comments regarding the Garmin GPS and text proposal should
discuss your experience of data burst sound impact on user
willingness to continue to monitor.  Any constructive
suggestion that you can make to lessen this negative impact
would be very useful.


	IX.	Other issues.

		A.	There are a number of other issues raised
in the Notice in WT Docket 10-119.  We have covered here
only what we consider to be the most significant ones. That
does not mean you should not comment on any other issues
that you may have relevant observations to point out.  
Good luck, and let us know if we here at the Personal
Radio Steering Group can be of any help!


	X.	Other Opportunities to Discuss These Issues.

		A. 	PRSG would like to encourage a widely
based discussion of these issues. You might consider
joining a special Yahoo Group that we have created for
this purpose. To register and participate, send an email
to: WT-10-119-subscribe@yahoogroups.com

		B.	Also, check in regularly to the PRSG's
own Internet Web page: http://www.provide.net/~prsg

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