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Crazy FCC GMRS comments.

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Hatchett

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Please take this as constructive criticism here. If you want the FCC to listen to you, take the time to type out your own logical and technical reasoning as to why you don’t think the changes should be made. Just because 15 people submit the same comment, doesn’t make it logical, or right. Duplicate/boilerplate comments are a waste of time! They pay as much attention, or even more to a single comment filed by one person, as they do that duplicate comment that was posted 15 times by 15 people. They are not going to put any more weight into it because 15 people filed it.

Some of the FCC comments I have been seeing for the GMRS NPRM, have left me scratching my head. The ones that make me just shake my head are the copy and paste filings. People that take a pre-prepared filing and add their name and send it in. This isn’t a petition drive. They are not counting signatures. The FCC is a government agency, they have seen it all. Been there, done that. They are not asking for your vote. They have not posted a poll. They want to see if anyone has valid, logical concerns about the rules changes. You can have a thousand comments, but if all of them are nonsense, then they are not going to pay attention to them. Add to that, the fact that if someone can’t be bothered to take the time to draw up a coherent sentence to describe their own thoughts, why do you think the people reading it, are going to put any weight in the comment they are sending in? As people have told me, if they ever see someone send in a “fill in your name” form, the only place that piece of paper is heading, is to the trash bin.

A person that send in the simple comment
“Your changes will rob me of the use of my repeater……. You little F$#%A#$A” will probably get more credence than a “fill in your name” form.

If you want people to listen to you, you should think enough of the subject to write up your own comments, about your own opinions, on the subject. Not someone else’s opinion!.

Here is my opinion of the most popular, and relatively bad “fill in your name” form that is taking up space in the comments section.

1. Elimination of GMRS licensing (aka “license by rule”), similar to the FRS and CB spectrum will do irreparable harm to the service and its users. Extending the licensing term from five to ten years would be in the best interests of the service as well as the users as long as the license fees remain the same or are reduced.

Umm….. Irreparable harm? A little much hu? The FCC isn’t making house to house raids here. A logical description of what the “irreparable harm” would be, would be nice. Don’t try to scare them, they have seen it all before. And considering the number of unlicensed users that are already running rampant through the GMRS band, a little description of the irreparable harm that is already happening would also be nice. Also, considering how the GMRS service already requires a license, but no one is really paying attention to it, a little description of how you think keeping the current requirement is really going to help things!.

2. Relaxing the eligibility requirements to allow users under 18 years of age should only be allowed if use of the radio is under Adult supervision and only if the licensee is 12 years of age or older.

My 8 year old niece has a camera phone and emails me videos. She syncs her phone to the computer via Bluetooth. She knows how to wardrive with the laptop’s 802.11 connection while traveling. This is not the 60s. Technology has pushed the technical competence level for children, way beyond what is was a few decades ago. The modern 12 year olds are perfectly capable of handling a 2way radio. Probably more capable than us old fogies. And if your abjection isn’t based on lack of competence in using the equipment, then tell why you think that age limit should stand.

3. Moving to narrowband 12.5 kHz spacing for the GMRS Service will cause undue financial hardship on the current licensees as it will require them to replace equipment. As the GMRS Service is a personal radio service, most licensees do not have the resources to replace this equipment in the current economic climate.

Umm… talk to the enforcement bureau, their definition of “undue financial hardship" may be a little bit different than yours. I am sure all those other agencies thought that the cost of upgrading was an “undue financial burden” but there is nothing they can do about it. The technology needs upgraded, and it is hitting everyone in the pocket book. And GMRS isn’t a right, it’s a privilege. You operating there, is on their terms, not yours. They originally provided the service to try to be considerate to the people that didn’t fit the normal licensing structure. In the current world, there is many other alternatives now.

4. Decreasing of GMRS handheld radio output power from 5 to 2 watts will in most cases cause licensees to be ineffective in their ability to communicate with their family members. In addition this will also decrease the effectiveness of licensees to utilize many repeaters as it will greatly decrease the usable footprint of most repeaters.

Technical fail!!!!!! You are not talking to spring chickens here. Don’t insult their intelligence. 5 to 2 watts is not a massive difference in usability, under normal day to day activities. I have a 2 meter handheld that can go from 5 watts to 1 watt. There isn’t that much difference. The only time you will really notice it is when you are competing with other people on a crowded channel. If the channel is crowded, then you shouldn’t be trying to talk there in the first place.

5. Elimination of the use of repeaters in the GMRS service would cause irreparable harm to the service and its users by eliminating a vital means of communications between family and friends. Also in many areas, GMRS Repeaters are utilized by many Non-Profit organizations that aid in disaster assistance activities, such as REACT, Red Cross, CERT, etc. which will greatly decrease their effectiveness.

Now that is insulting their intelligence.
On the first part. Um…. What the heck has the wireless industry been doing last several decades? Think real hard here. SMR, cellular, PCS, WIFI, satellite phone, FRS, MURS. …On and on…….. There is many options now. GMRS is a lot less critical/valuable, than it use to be.
On the second part. The Red Cross has licensed their own frequencies a long time ago. They don’t depend on GMRS frequencies. The red cross does not have the time to fidget with who does, and who does not have a GMRS license. They hand you a handheld, and you use it.

And with regards to REACT. Get a reality check. Drawing REACT into the discussion is not helping things. If REACT is worried about interference free communications channels to use within the organization, they could get a license for a LMR frequency any time they wanted to. Just like the Red Cross. That is the whole point of LMR. That is one of the main sets of users of LRM, organizations!! There is nothing stopping them. Any REACT member could use it. During an emergency, all react members could make use of it, not just the ones with GMRS licenses. They made the GMRS service for people who DID NOT qualify for LMR licenses. (ie) not a business or an organization!. So, REACT should keep their mouth shut about GMRS, because they are not exactly the intended user of it in the first place! The FCC already has a service designed for REACT, and that is LMR. And in my opinion, they are cutting their own throat, by going against “license by rule.” The more radio operators, the larger the prospective member base, and goodness knows, they need more members badly.

6. Consideration of a petition from Garmin to allow the transmission of GPS location information and user-generated text messages on certain GMRS channels. These emissions are already authorized on FRS channels, but Garmin would like the FCC to consider allowing it in the GMRS spectrum. Since this is already allowed in the FRS Spectrum, allowing this use in the GRMS spectrum would only degrade current communications and would not serve the public interest.

Now here is someone trying to say the sky is purple. The benefit of GPS over FRS during daily use, emergencies and disasters is documented, unarguable fact. The lack of harmful interference in the FRS band is documented fact. The addition of GPS in the GMRS band would be a proven lifesaving addition. Not just a real benefit for daily use, but a feature that has saved real lives on FRS radios. To make the argument that the addition of that capability to a radio service with wider coverage, would not serve the public interest, is dumbfounding, and it degrades the validity of the rest of your comments by making such an argument. You could make technical arguments why it would cause, up until now unforeseen, interference, but considering how the GPS information is carried, that would be a pretty tough argument.

7. Prohibition of approval of dual VHF Marine/FRS radios. While in most if not all cases this would be acceptable, prohibition of radios that are type accepted for Part 90 should continue to be allowed by the Commission. With the current narrowband and APCO 25 initiatives, many municipalities are currently sending to surplus many fairly new radios, which are usable under the GMRS Service. Disallowing use of Part 90 Radios will only cause undue hardship to the licensees as the types of radios allowed will be quickly diminished to the low cost (toy) FRS/GMRS type radios currently sold as bubble packs. While these types of radios are good for neighborhood communications in some cases, use for longer range communications is not possible.

Umm……. What the heck are they trying to say? Did they even read the NPRM? That is not even what the FCC is asking!!!! And it undercuts the other arguments above it. If every other organization has had to take the burden of getting rid of their own radio equipment for the upgrade, what makes GMRS users special?

EPIC FAILURE!!!!!!!

In fact, considering that it is a “fill in your name” form, it is a failure of a failure. That is not a double negative folks.

Don’t think the FCC doesn’t notice such things. That is an example of why some people arguing in your favor, is not exactly helpful.
 
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PeterGV

K1PGV
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Messages
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Yeah... That "comment template" is provided by REACT, and much of it appears to be ill-considered. Silly, huh? A bunch of people sending the exact same comments doesn't seem to be really helpful does it? OTOH, perhaps it WILL bear SOME weight with the FCC -- even if it's just that a number of folks are inspired to effectively say "me too".

I agree with most of your comments. However, one seems to seriously miss the point. Specifically:

..
Now that is insulting their intelligence.
On the first part. Um…. What the heck has the wireless industry been doing last several decades? Think real hard here. SMR, cellular, PCS, WIFI, satellite phone, FRS, MURS. …On and on…….. There is many options now. GMRS is a lot less critical/valuable, than it use to be.

On the second part. The Red Cross has licensed their own frequencies a long time ago. They don’t depend on GMRS frequencies. The red cross does not have the time to fidget with who does, and who does not have a GMRS license. They hand you a handheld, and you use it.

And with regards to REACT. Get a reality check. Drawing REACT into the discussion is not helping things.
...

SMR, cellular, PCS and WIFI (WIFI?? Isn't that a data mode? Anyhow...) are often unavailable in rural areas, especially in the Western and South Western United States. Heck, I live in New Hampshire and can't get a cell phone signal of ANY kind at my house. Not to mention these services tend to fail during disasters.

Satellite phone are great, but (a) they have to be used outdoors with a clear view of the sky, and (b) they are VERY expensive. Not something the average guy's going to have for communications.

FRS and MURS: Yes, cool. Good for local "on-scene" communication. But not repeaterized.

There are a number of organizations, including CERTs abd the Red Cross (yes, really), and even REACT, that use GMRS. They do this because the radios are readily available and inexpensive, no test is required (as there is for amateur radio), and repeaters can be put into service inexpensively and without the need for coordination.

So, *this* part of the template comments actually makes sense to me.

I guess this whole process is what the "comments period" is designed for, eh?

Peter
K1PGV
 

wapicke

Member
Joined
Jun 29, 2010
Messages
3
Ha!

I cannot believe what I just read! So, if you have one GMRS repeater on a hill, and all the little cell towers throughout a city (or two) get's knocked out . . .

Explain your concept of how GMRS is not needed in emergencies!?
 
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