Proposed Changes to GMRS - Comments Link

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rescue161

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#1
NOTICE OF PROPOSED RULE MAKING AND MEMORANDUM OPINION AND ORDER ON RECONSIDERATION

See this link http://forums.radioreference.com/cb...part-95-includes-gmrs-frs-cb.html#post1336401 for details.

The FCC is seeking comments from folks like us that use GMRS/FRS/CB on the proposed changes set forth in the above link. We can do one of two things: sit back and watch them take the bands away from us, or comment on what we feel is right.

Submit a Filing

You'll want to enter 10-119 for the Proceeding Number and select "Comment" for the Type of Filing.

Please note that everything you type will be in public view, so let's be organized and to the point.

If you search "10-119", you'll be able to see what others have typed already. We only have 30 days for comments, so make sure your voices are heard.
 

rescue161

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This is what I'm proposing to the FCC.

1) Scrambling be allowed on the Personal Radio Service.
2) The GMRS license requirement remain.
3) The requirement to be 18 years old to be licensed remain.
4) The GMRS license renewal be extended from 5 to 10 years.
5) The GMRS license fee be $100.00 for a 10 year period.
6) Only persons 12 and older be allowed to talk on the GMRS.
7) Power for GMRS handheld radios remain at 5 Watts.
8) Power for FRS radios be ½ Watt (500 mW)
9) Power for mobiles, bases and repeaters retain their power output of 50 Watts out of the transmitter.
10) GMRS antenna height not be regulated.
11) Part 90 radios be allowed to be used for the GMRS.
12) Digital modulation be allowed on the GMRS.
13) Businesses not be allowed to use the GMRS.
14) There is actually a need for the GMRS and that the service be allowed to continue.
15) The GMRS not be subject to narrowband.
16) Combination radios be stricken and removed from FCC certification status.
17) GMRS radio users to be able to program FRS frequencies into their GMRS radios.
18) CB skywave propogation be legal.
19) CB power output remain at the current regulations.
 

PeterGV

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#4
I agree with many (not all, but many) of Scott/Rescue161's comments.

It seems to me that there should be provision for a "middle level service" between unlicensed, local, low-power, "anybody can use it, including kids" FRS and "apply for a license if you can find a channel (good luck) and pay for the coordination" LMR (Part 90). That service should be GMRS.

Handhelds can be 2W (that probably makes sense, just given the RF exposure issues) but base, mobile and repeater operation at 50W (uncoordinated) should be maintained. And I think it might make sense to allow 2W handhelds to be "licensed by rule) but continue to require a license for GMRS radios > 2W.

I also agree that digital modulation should be allowed on GMRS, and Part 90 radios be automatically allowed on Part 95 services. Note that this isn't reciprocal: Part 95 accepted radios should NOT be allowed on Part 90.

I've got to gather my thoughts and comment to the Commission.

Peter
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gewecke

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#6
As I've already stated elsewhere on RR this might be approved,but it's going to be a joke to try to enforce this! The FCC do NOT enforce the retail "bubble pack" community to refrain from using gmrs repeater channels for their nonsense or radio rental companies from renting equip. on gmrs repeater output channels,so WHY does anyone think this will work??
Sorry, but I see no reason to put band-aids on a big issue here.
n9zas
 

gewecke

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#7
This is what I'm proposing to the FCC.

1) Scrambling be allowed on the Personal Radio Service.
2) The GMRS license requirement remain.
3) The requirement to be 18 years old to be licensed remain.
4) The GMRS license renewal be extended from 5 to 10 years.
5) The GMRS license fee be $100.00 for a 10 year period.
6) Only persons 12 and older be allowed to talk on the GMRS.
7) Power for GMRS handheld radios remain at 5 Watts.
8) Power for FRS radios be ½ Watt (500 mW)
9) Power for mobiles, bases and repeaters retain their power output of 50 Watts out of the transmitter.
10) GMRS antenna height not be regulated.
11) Part 90 radios be allowed to be used for the GMRS.
12) Digital modulation be allowed on the GMRS.
13) Businesses not be allowed to use the GMRS.
14) There is actually a need for the GMRS and that the service be allowed to continue.
15) The GMRS not be subject to narrowband.
16) Combination radios be stricken and removed from FCC certification status.
17) GMRS radio users to be able to program FRS frequencies into their GMRS radios.
18) CB skywave propogation be legal.
19) CB power output remain at the current regulations.
This is merely a "christmas wish" and it's not going to happen by then either! :lol:
n9zas
 

rescue161

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#8
This is merely a "christmas wish" and it's not going to happen by then either! :lol:
n9zas
Hey, it never hurts to ask. That is the summary of my comment to the FCC and it should post tomorrow. There are a lot of people that are posting their comments on the FCC site that I posted above. I suggest that if you feel that the GMRS needs a major fix, then you should come up with a solution and submit it to the FCC.
 

PeterGV

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#9
Got my comments posted, finally. Man, that took longer to write than I thought it would! In thinking it through, I came to some different conclusions than I had initially that caused me to differ with Scott KE4FHH more than I had thought.

For example, while I'd personally love to see digital emissions formats supported on GMRS (like, ah, P25 for example) I have trouble believing that would be consistent with a service that's widely used by the general public. I can just imagine mom and dad at Disney trying to talk to each other, and being interrupted by sssqqqqeeeeaaaak.... whooooshhh..... braaaaap. Yes, yes... they could/should use CTCSS, but we're talking mom and dad with a bubblepack here. You can barely get some folks to understand "Be sure to push the button all the way first, and then when you have it pushed down, start to talk. When you're done talking, let the button go."

I think the most important point to make with the Commission is that there's a need for GMRS... a slightly higher power radio service in which repeaters and (significantly) higher-power base and mobile stations are allowed. I think it makes sense to create a specific category for GMRS handhelds, and limit those to 2W. The 2W power limit makes sense to me and seems to balance RF exposure concerns with communication distance. I'd also really like to see these 2W handheld radios licensed by rule.... though I'd like to see base/mobile stations still licensed.

A final point that I'd like to note (and with which I agree with KE4FHH) is that I think Part 90 radios should be allowed to use GMRS frequencies. Similarly, I think Part 97 certified radios should be allowed to use GMRS frequencies. I think this would enhance interoperability, especially in emergency/disaster scenarios.

If they ask, we might just as well give them our opinions... So, everyone: Take some time to FILE THOSE COMMENTS!

Peter
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b7spectra

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#10
One of the biggest things the FCC could do is free up the UHF T band for usage since all in that band had gone to digital (for areas that used to have ch 14-18).
 
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#12
Similarly, I think Part 97 certified radios should be allowed to use GMRS frequencies. I think this would enhance interoperability, especially in emergency/disaster scenarios.

If they ask, we might just as well give them our opinions... So, everyone: Take some time to FILE THOSE COMMENTS!

Peter
K1PGV
I agree with where you're coming from but the FCC won't allow it. IOW, fugheddaboudit.

I'm not aware of any "Part 97 certified" radio on the market. The transmitter in commercially made ham gear does not have any type acceptance of ANY kind. The only type acceptance or certification they have is for the receiver under Part 15. From a strictly FCC point of view, commerically made ham gear is viewed as nothing more than a scanning receiver. Type acceptance issues aside, the transmitter also won't meet the technical requirements to be used in GMRS, FRS, MURS and Part 90 services.
 
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#13
I'm working on my comments too. I will be putting lots of time into them over the coming weekend.

I am for keeping GMRS licensed and largely unchanged but need to accomodate the 22-channel bubble packs and make them license by rule. Higher powered operation and repeaters and using Part 90 gear with Part 90/95 dual certification still should require licensing. Change the license term from 5 years to 10 years and reduce or eliminate the license fee.

I am 100% in favor of narrowbanding GMRS. FRS and the 22-channel GMRS/FRS bubble packs already operate narrowband. ALL Part 90 gear including those with dual 90/95 certification and marketed within the past 10 years is already narrowband capable. Making the switch should not be a big deal at all.

"Wide" bandwidth = 5 kHz deviation, older occupied bandwidth 20kHz for a 25kHz channel spacing (20K0F3E). All newer "wide" bandwidth equipment usually only has up to 3kHz of audio with 5kHz deviation, giving an occupied bandwidth of 16kHz (16K0F3E).
"Narrow" bandwidth = 2.5kHz deviation, max 3.125kHz audio modulation, occupied bandwidth 11.25kHz for a channel spacing of 12.5kHz (11K2F3E).

The terms "25kHz" and "12.5kHz" are often used to refer to the channel spacing for "wide" and "narrow" bandwidth channels. They are misnomers. They are the channel spacings for each but not the actual bandwidth!

If you're using "wide" bandwidth with commercial gear marketed within the last 10 years, you're operating "wide" but with 16kHz of occupied bandwidth on a 25kHz-spaced GMRS primary channel.

I already made the switch to narrowband years ago and haven't looked back. All it took was simple programming changes in my radios. Audio quality is the same. RF performance has been the same or better in some cases. What I also found was that ALL of my adjacent channel interference on the GMRS primaries from bubble packs operating on the GMRS/FRS interstitial freqs (12.5kHz away from the primaries) went away as soon as I made the switch. It became MUCH easier to coexist with the riff-raff. After having operated in narrow mode for several years on GMRS with all of my radios (Part 90 w/dual 90/95 type acceptance), I won't go back to "wide" bandwidth again, even it remains allowed on the GMRS primaries. Also, "wide" bandwith (5kHz deviation) mode is going away from Part 90 gear, so future Part 90 gear having dual 90/95 certification (if it remains allowed) will be narrow-only.

Narrowbanding GMRS is inevitable, so stop whining about it! Your adjacent channel interference problems from local bubble packers on the GMRS/FRS channels spaced 12.5kHz away from your GMRS primary channel will go away if you make the switch to narrowband. I did it and IT WORKS!
 
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PeterGV

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#14
The transmitter in commercially made ham gear does not have any type acceptance of ANY kind.
I didn't know that. I know we can make our own gear, but I guess I didn't realize that there was no certification for Part 97 compliance.

Thanks Dave,

Peter
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#15
I didn't know that. I know we can make our own gear, but I guess I didn't realize that there was no certification for Part 97 compliance.

Thanks Dave,

Peter
K1PGV
It is this convenient "loophole" that allows hams to make their own gear and operate it on the bands. :)

I will be working on my GMRS comments for the NPRM over the weekend. Time is runnnig out!
 

PeterGV

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#16
It is this convenient "loophole" that allows hams to make their own gear and operate it on the bands. :)
Ah! So, I looked this up. I was thinking of the rules around "external RF power amplifiers" 97.315 and 97.317...

Thanks Dave...

Peter
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#17
I plan to have all of my comments done and submitted by July 7th. Anybody know the exact deadline date? The NPRM says the deadline is 30 days after publication in the FR. Given I don't have the exact date, I'm treating Wednesday July 7th as the deadline.

If you haven't already done so, get your comments filed before it's too late! Time is running out!
 
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rescue161

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I plan to have all of my comments done and submitted by July 7th. Anybody know the exact deadline date? The NPRM says the deadline is 30 days after publication in the FR. Given I don't have the exact date, I'm treating Wednesday July 7th as the deadline.

If you haven't already done so, get your comments filed before it's too late! Time is running out!
I don't know the exact date either, but I was using the 7th of July as the deadline for my submissions. PLEASE, if you value these services, then please submit your coments before 7 July, 2010.
 
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#19
Saddly, only 133 comments have been filed as of this afternoon.

If users want GMRS to remain GMRS, you have until Wednesday to comment to the FCC as described above.
 
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#20
Comments are still OPEN as of today 7/8/2010. Anybody know the real deadline?

I filed my comments early this morning (on 7/8/10).
 
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