Here is draft of the response we are going to submit to the FCC:
"This letter contains comments on the Notice Of Proposed Rule Making And Memorandum Opinion And Order On Reconsideration in the matter of the FCC's Review of the Commission's Part 95 Personal Radio Services Rules (WT Docket No. 10-119).
First, a little background about myself. I am the president of Cricket Ventures, LLC which owns and operates the web site BuyTwoWayRadios.com, one of the country's largest GMRS specialty retailers. I would like to briefly voice my support in the FCC taking up this matter and provide comments on certain subjects that were mentioned in your Notice of Proposed Rule Making (NPRM).
I am in full agreement with an overwhelming majority of your proposed changes, in particular your proposal to remove the license requirement for GMRS use. This issue has been the cause of much confusion and discouragement from our customers over the years and I welcome the changes taking effect. I have comments on several other sections of your proposal that I will detail below.
Page 6, Item 12:
You propose to list frequencies in a table along with an assigned channel number. I believe that it is a great idea to use channel numbers to identify frequencies, however I would suggest that the FCC adopt the channel numbers that are commonly used by radio manufacturers in 15 channel GMRS radios. Example radios are the Kenwood TK-3101, Kenwood TK-3131 and the Icom F21-GM. I believe that if the FCC uses channel numbers that differ from current standards it will only lead to confusion.
Page 12, Item 27:
It is my opinion that all GMRS licensing requirements should be eliminated. As stated in the proposal, licensing offers little value when a licensed user is able to operate on any frequency in any location. In addition, it is inconsistent with other part 95 services. Also, with so few GMRS users actually completing the licensing process this requirement actually serves only to punish those who follow the rules. This would continue to be the case without a large enforcement effort, a near impossibility with the number of unlicensed stations already in use.
Page 13, Item 30:
The proposal seeks comment concerning the use of GMRS devices by businesses. It is my opinion that use of GMRS radios by individuals for business purposes should continue to be allowed. A potential drawback to this is that with the possible removal of the license requirement, some businesses may choose to use GMRS radios rather than part 90 commercial products because the part 90 licensing process creates a barrier to entry. I do believe however that there are sufficient advantages to the Part 90 service that businesses will continue to choose LMR products for high use and mission critical applications. Businesses may choose to use lower cost GMRS radios in light duty or non-frequent applications.
I also believe that prohibiting business use of GMRS devices would be difficult to enforce and would likely lead to a situation like we have today with licensing, where those that follow the rules are effectively punished because breaking the rules involves no risk.
Page 19, Item 47:
I understand and support the stated concern regarding combination Marine/GMRS radios and I support prohibiting this combination. It is my opinion, however, that the proposal may be taking it too far by including Part 90 in the list of prohibited combinations (along with Parts 80, 87, and 97).
There is some consumer demand for high quality business grade GMRS radios, but this demand is very small in comparison to the demand for the typical low priced combination FRS/GMRS radios found in retail stores. Business radio manufacturers say that this demand is too low for them to justify producing a GMRS specific radio. A typical Part 90 certified UHF radio is no different from a hardware perspective from a high quality GMRS radio. Providing the manufacturer with the option to produce a radio for businesses but also having it certified for GMRS use could provide consumers in need of higher end products with more options. Without this option, those looking for high quality, commercial grade GMRS products may have very few choices."
We welcome your comments and opinions so let us know what you think by commenting here on our blog or on our two way radio forum.
