Here are some of my comments: In paragraphs 26 and 27, the Commission proposes removing the licensing requirement from GMRS, end call signs, and remove station identification. I strongly disagree with the Commission's proposal. I believe in the license requirements of GMRS. Those who do not want to get a license should use FRS, MURS, or another one of the Personal Radio Services that do not require a license. Being that GMRS is the only Personal Radio Service that allows for repeater operations, it makes sense that it requires a license. One of the Commissions arguments for removing the licensing requirement is found in paragraph 25 where the Commissions states that many people who purchase FRS/GMRS combo radios and people who just buy GMRS radios, yet few actually get licenses. There are two flaws with this argument. First, under Commission Rules 47 C.F.R. 95.179, the immediate family of a GMRS licensee is allowed to use their license. I believe that while there are significant unlicensed persons on the GMRS frequencies, there is also a lot of licensed persons who fail to properly identify their license out of lack of knowledge. The second flaw in the Commissions argument is that solely because people are breaking this Federal regulation (having a license and/or failing to identify their license) does not mean that the Commission needs to change the regulation. We do not, as a nation, regularly change laws to make those who operate outside of the law suddenly inside the law.
In paragraph 28, the Commission proposes changing the licensing term of GMRS from 5-years to 10-years. I believe the cost is too high presently however. I believe $85.00 for 10-years would be a good improvement and, as the cost per year would go down, I believe the license compliance would increase. In paragraph 29, the Commission proposes removing age requirement of being 18-years of age or older. I'm fine with removing this age requirement, as I believe anyone who wants to get a license and is willing to abide by the Commission's rules should be entitled to be granted a license. I agree with the Commissions finding that there is little benefit of maintaining this age requirement. I do support the continued allowance of a Licensees immediate family to use their license. In paragraph 30, the Commission asks about Businesses being able to use GMRS frequencies if the licensing requirement is dropped. I do not support the dropping of licensing requirements. However, if the Commission ends up dropping the license requirements, I still do not support businesses using the GMRS frequencies for the very reason the Commission pointed to. Small Business can currently use FRS, MURS, and CB radio. Larger businesses need to be encouraged to use the Business Radio service, as that is the reason the Commission set these frequencies apart. If the Commission allows businesses to use the GMRS frequencies, then businesses will setup GMRS repeaters and will effectively turn GMRS into an unlicensed Business Radio service, preventing families and individuals from using the service as envisioned. In paragraph 15, the Commission says that each of the part 95 services have different power outputs. In paragraph 16, the Commission acknowledges that they can't use the same power output for all part 95 services. Yet, in paragraph 32, the Commission proposes setting up portable GMRS devices with a maximum ERP of 2-watts. Yet the Commission is proposing the same power requirements that the VHF Multi-Use Radio Service (MURS) currently has. In the "urban canyons" that have been created in many of our nation's cities with large buildings 2 or even 4 watts ERP does not travel very far. There is a reason why 4 and 5 watt portable GMRS radios are common and why MURS has not been very popular; a portable GMRS radio is of little benefit with only 2 watts of power. If the Commission believes a portable radio needs a power limit, it should be at least 5 watts. The Commissions' proposal meantions that the Business/Industry pool in the same frequency range only allows for 2 watts. However, there is a different target market. The Commission also talks about the Economics of Scale of limiting the GMRS service to 2 watts, since Canada allows for unlicensed radios in the same frequency. If radio manufactures want to take advantage of that, they already can. Why attempt to force them to? There are GMRS repeaters that I use in the Las Vegas area that if I was forced to communicate with at 2-watts, I would not be able to get a usable signal from my house. In paragraph 34, the Commission questions if 50-watts of power for base stations and repeaters are needed. I believe that most GMRS base stations use the least amount of power possible to make the contact. If the Commission wishes to codify that, they should. However, if a person wants to talk Simplex around a major metropolitan area, 50-watts may be necessary. I can not speak for all areas, but in the areas that I have traveled in Southern California, Southern Nevada, and Southern Utah, the GMRS services do not seem to be overly crowded. Especially with the proposal to reduce a Portable GMRS power output, I believe that GMRS repeaters are still needed. Many non-profits and disaster groups (CERT, Skywarn, REACT, and various Church Emergency Response groups, among others) use GMRS for the simple requirements of getting licenses. A 2-watt radio (or 4 watt for the matter) would have a hard time in a disaster communicating with each other if they are very far away and with the GMRS repeater. In addition, individual families (including mine) have simple GMRS repeaters that we use with our kids so we can talk to them when they are playing in the neighborhood. Even more important is the antenna height. In paragraphs 36-37, the Commission proposes changing GMRS from its current "Wideband" of 25 KHz to "narrowband" of 12.5 KHz. This change will cause a major consumer burden when their current FRS/GMRS radios are suddenly not usable. There will have to be several years to allow this to be implemented, during which time, dual FRS/GMRS radios that many consumers purchase will need to be able to choose between Wideband and Narrowband. There will have to be a significant educational period explaining the upcoming change, similar to what was done with the analog to DTV conversion that the Commission ran for several years. All that being said, I support the switching GMRS from wide band to narrow band on the condition that the they use the left over frequency to create additional GMRS channels. (I would support narrowband on FRS for the same reason). These additional GMRS channels should only be usable with repeaters and FRS/GMRS combination radios that do not support repeater offsets should not be able to use these new GMRS frequencies. There could also be significant costs to GMRS repeater operators as not all GMRS repeaters support narrowband. New equipment manufactured over that last several years appears to in preparation for the Business Radio Service going to narrowband. However, equipment that has been in place for several years may not. For this reason, the GMRS wideband to narrowband will need to have at least 5-years from the ruling date before the effective date. I oppose the proposal from Garmin found in paragraphs 40-42. With possible repeaters in these frequencies, this could cause great interference. This service can already be handled on the FRS frequencies. Another option could be to use a few of the newly vacated frequencies from FRS when that service goes Narrowband. --- In [email protected], "John Godfrey <KE5NZY> " <ke5...@...> wrote: > > I did read through the document, but it is very lengthy of course, and I > guess I missed parts of it. I thought they are proposing to extend the > licensing period from 5 years on GMRS to 10 years to align it with other > licensed services such as amateur radio. Did I just totally misread it, and > can you provide an excerpt from the document that includes your concerns, so > I might be able to comment in a more intelligent manner. > > > > 73 de John Godfrey > > > > > > > > > > From: [email protected] > [mailto:[email protected]] On Behalf Of Bill Smith > Sent: Tuesday, June 08, 2010 8:18 PM > To: [email protected] > Subject: Re: [Repeater-Builder] More on GMRS - Fwd: FCC NPRM proposes > complete part 95 rewrite > > > > > > What is the ERP of a typical 4-watt UHF portable? Pretty close to 2-watts. > > > Bill > > KB1MGH > > > > _____ > > From: Mike Morris <wa6...@...> > To: [email protected] > Sent: Tue, June 8, 2010 6:00:53 PM > Subject: [Repeater-Builder] More on GMRS - Fwd: FCC NPRM proposes complete > part 95 rewrite > > > >Date: Tue, 08 Jun 2010 20:06:17 -0000 > >Subject: FCC NPRM proposes complete part 95 rewrite > > > >Just released FCC NPRM proposing a complete rewrite of the entire > >Part 95 Rules: > >NPRM FCC-10-106A1 > > > >The FCC NPRM requests comment and discussion of their proposed > >changes, which, among other things, propose to end the requirement > >for licensing in GMRS, LOWER the power allowed (to 2 watts for > >portables), potentially remove repeaters, firmly prohibit scrambling > >of any kind, and perhaps, prohibit use of radios dual/type accepted > >for part 90 and 95! >
