OK my submission has been sent. Frankly, the Midland proposal is defective on all counts. Much as we would all like a digital mode, the FCC is likely to rubber stamp Midland (a Job Creator) and not pay any attention to detail. So when 5 years from now, all the radios being marketed are Midland and have only an obscure digital mode TDMA/Fusion, folks will wonder why they cannot use a repeater or why their old reliable radios are pumping out noise all the time.
Please pay attention to what they are asking and play devils advocate. Midland is not your buddy. They just want to make a buck.
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Midland once again proposes changes to the FCC rules for the General Mobile Radio Service (GMRS) which are detrimental to the scope, operation and spirit of GMRS which is primarily a high performance voice communications service for individuals and families. They propose lifting the restrictions they had agreed to under previous rule changes permitting short range digital transmissions. A. Proposed Changes to Rule Text; Midland desires to eliminate the requirement for a fixed integrated antenna for certain digital modes as stipulated under 95.1787(a)(4). Midland proposes that the power level be increased from the currently permissible 5 watts to 50 watts Midland proposes that digital transmissions be increased in repetition from once every 30 seconds to once every 10 seconds. Midland has once again raised their ask in creating a digital messaging and location service from GMRS which is primarily a voice service employing FM "wide band" modulation. The digital service that Midland proposes has been successfully deployed by other manufacturers in the 900 MHz ISM band without any modifications to existing rules. There is no technological advantage to using GMRS for this application, nor any technological barrier to Midland also using ISM Band(s) for the deployment of such an application. There is no reason to integrate such a feature into a Midland GMRS radio other than to create a competitive advantage for Midland. Users are not compelled to buy an integrated radio when they can use separate products for these same functions without any technical or functional burden. Further, Midland apparently recognizes the interference potential of deploying this application in an urban environment (of many radios) and has chosen to constrain the rule to Remote and Rural Operations without any explanation of how, where and when these 50 watt digital transmitters will be allowable. B. Addition of Digital Voice Transmissions to the list of Permissible GMRS Uses. Midland Proposes adding emission types F1E and F7D , and suggests a "TDMA" like digital voice mode. While others had suggested same in the 2017 rule making, the FCC was careful to omit this change as the GMRS and FRS services, which are FM modes and somewhat interoperable, serve an important lifeline for personal emergency messaging, introducing various digital modes into the services, absent a standard, and absent a requirement for FM interoperability, erodes this important feature of the current GMRS and FRS services. The FCC must be very careful that Midland or other manufacturer does not create a digital mode that is proprietary and exclusionary, especially to long established FM capabilities. Midland suggests that the use of TDMA mode will increase spectrum utilization on the GMRS service. While technically TDMA could provide a 4:1 improvement over FM 25 KHz bandwidth, it cannot be accomplished in a SIMPLEX operation which is nearly 100% of the market which Midland has captured. Midland has only recently offered repeaters, and none of their portable radios, and most mobile radios neither support Repeater operations nor are they employing full 25KHz bandwidth. The uncontrolled, and non standardized proliferation of digital modes will increase interference, reduce interoperability and will cause confusion to the GMRS market. C. Grant of the Instant Petition for Rulemaking is in the Public Interest Because it Will Improve Safety Applications for Off-Road GMRS Users. As I have stated above, the changes which Midland has requested will erode the functionality of the GMRS service and could otherwise be accomplished without any rule modification in other frequency bands such as 900 MHz ISM band as other manufacturers have done successfully for both voice and data services, including Mesh Networking.
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If I missed anything, feel free to plagiarize mine and add to your reply to FCC.
