Below is a copy of an email I sent to the FCC Commissioners regarding these proposed rule changes. The ECFS is down, and I hope to *maybe* draw some executive attention to the fact that there are, still, plenty of licensed, rule-abiding GMRS operators nationwide.
Copy of communication:
Dear FCC Leadership,
I am writing to express concerns over the proposed rule changes to FCC Part 95 rules governing personal radio services. Unfortunately the ECFS appears to be down, and I feel that this particular set of rule changes demands the attention of the executive leadership.
Before I comment on the rule changes themselves, I’d like to provide a little background information about myself. I work in public safety as both a Police Communications Officer and an Emergency Medical Technician. I am also a member of a local CERT, radio enthusiast, and awaiting the July changes to the amateur radio testing pool to sit for my technician class amateur licensing. I am a licensed GMRS operator, WQLU507.
In reading the proposed changes to Part 95, it would appear that the changes to the rules will effectively eliminate the GMRS, if not in nomenclature, at least in spirit. Currently there are many licensed operators, such as myself, who enjoy the local, and sometimes regional communication freedom offered by the current GMRS rules. I am a member of the North Georgia GMRS network, which is an advanced network of repeaters constructed and maintained by GMRS users in Georgia. The proposed changes to the rules would eliminate this valuable network as a whole, and negate all of the hard work by members of the group who strive to maintain and grow the resource as a means of communications. Living in rural northwest Georgia, this repeater network is a valuable resource to those of us who live in areas not easily serviced by todays cellular offerings. At my residence in Paulding County Georgia, I am barely able to maintain a GSM signal with my local provider, however, I get full quieting on one of the North Georgia GMRS repeaters, allowing me to keep in contact with family in the area as well as friends who are also members of the network. I am enjoying teaching my 11 year old younger brother about two-way radio, and always being able to get in contact with him via use of the repeater network.
As a CERT team member, I can tell you that all of the senior members of our group are licensed GMRS operators, and many are amateur operators. Utilizing both the repeater network available and simplex operations, we are able to communicate anywhere within the county at any time. As I stated earlier, cellular coverage in my, and many rural Georgia counties, is simply not reliable enough to be considered appropriate for emergency communications. The proposed rule changes would effectively eliminate this as a means of communications for our group during an emergency, as a 2 watt transmit power limit would render mobile unit to mobile unit simplex operations useless. Utilizing GMRS as one means of communications for our group is a valuable resource that simply couldn’t be replaced by any other current offerings in the spectrum.
I do support a rewrite of the rules to streamline and simplify certain aspects of the radio service as a whole. I feel the proposed changes banning “hybrid mode” radios that operate on both GMRS and FRS frequencies, often sold with greatly exaggerated coverage claims and little to no mention of licensing requirements would be a step forward for GMRS. I feel the move to eliminate licensing requirements altogether would destroy the valuable resource provided to current GMRS license holders, and greatly bolster the profits of companies selling inexpensive radios without regard to their impact on licensed operators. I feel the current transmit power restrictions are appropriate for the service and effective at eliminating unwanted emissions and interference. Being a “Personal Radio Service”, I feel the needs of the licensed operators of the service should be the driving force for rulemaking, not the wants and profit margins of the radio manufacturers. More strict control of radio types, licensing enforcement and stricter control over manufacturing guidelines could go a long way in improving the licensed GMRS, negating the need to effectively abolish it.
I appreciate your taking the time to listen to my concerns. When the ECFS is operational again, I will post this same information there to allow for public review and comment in the spirit of the rulemaking process.
Thank you for your time,
Dreagon “Dre” L. Gilley, NREMT-I, NAEMD-A
WQLU507