No argument at all, but I cannot wrap my head around the vitriol that some hams have about low band GMRS. Some hams feel threatened by this proposal. No one ever suggested that low band GMRS would take away from the ham bands or throw shade on the great work hams do every day. I just don't get it.
No, and No.
The utility and need of GMRS (and before that, Class A Citizens Radio Service) was largely unproven until the mid 1990s. That was 35+ years of an under-performing, lightly used, licensed radio service that operated almost entirely off used radio equipment from the commercial market. GMRS took off when the service was marketed by user groups and manufacturers. Today, it's still sparsely used in many parts of the country and jam packed full in other places.
A low band GMRS service would theoretically start the same way. Used radio equipment and sparsely populated until a national group started pushing the merits and marketing the benefits of low band GMRS. With the internet and social media, that group could start on day one of the new frequencies are approved.
For current GMRS users, this is easy. Your license is automatically updated with all the low band frequencies. There is no new service. No new license. No additional fees. I am KAE-9978 on UHF GMRS, and if I chose to buy the radios, I would be KAE-9978 on 49 MHz.
Finally, more robust repeaters won't fix anything if you can't get a good repeater site where you live. It won't fix anything if you cannot afford a multicast system with voted receivers because the hills and valleys play hell on single site UHF repeaters and even worse on simplex. Low band GMRS works better with this topography and, while not perfect, the signal travels better and further at 49 MHz than it does at 462 MHz. That's simple physics.
I'm not a huge fan of low band repeaters because they cost a lot more (than VHF, UHF, 800, et al) to do them right. There is a need for advanced technical expertise on low band that isn't always necessary with the plug-and-play repeater systems on UHF. With that said, maybe eight repeater pairs won't be a bad addition to my draft. I worry about losing talk-around and the ability to operate simplex when you have a 3 MHz split on transmit/receive but that works better for duplexers and dual antenna repeater installs.
And sadly, you are likely correct on your prediction. This was a poorly researched and written petition but still a good idea.