[NOTE: This document was originally prepared and distributed in June 1996. Some of the events predicted here have now already occurred or are themselves now history. Effective April 2, 2003, the FCC modified the rules cited below to permit FRS stations to transmit data communications, with certain limitations. Click here to access the current FRS Rules.]
The FCC has adopted the initial rules for the unlicensed "Family Radio Service." The service became a reality in summer 1996. Interference to GMRS operations is inevitable and constantly occurring. Despite intensive complaints from licensed users, the new FCC rules offer little protection and no priority for licensed GMRS repeaters.
This publication reprints and editorially discusses the Report and Order (R&O) that adopted the FRS rules.
In November 1998, the FCC finally responded to the PRSG Petition for Reconsideration in a Memorandum Opinion and Order. In it, the FCC rejected the arguments PRSG made for clarification and addition of certain rules.
However, the FCC did reaffirm (at the request of Motorola) its intention to disallow FRS radios with removable antennas. It remains uncertain what action might be taken with regard to those thousands of FRS radios already sold that have these removable antennas, and that may now apparently be impermissible to use.
Table of Contents
PRSG Discussion of This Action > The FCC Attitude: Our Mind is Made Up, Don't Confuse Us with the Facts > The Basic Shortcoming: The FCC's Failure to Implement Its Intended Policy > Limitations on Range -- A Myth > Alleged Intent for "Family" Use > Limitations Solely by Transmitter Technical Standards > Silence is Not Golden -- The R&O Ignores Many Important Issues > Requests for FCC Reconsideration
Report and Order I. Introduction II. Executive Summary III. Discussion A. Need for the FRS B. Channels C. Transmitter Technical Standards D. Administration of the FRS IV. Conclusion V. Procedural Matters VI. Ordering Clauses Appendix A (Commenters) Appendix B (Rule Language) Footnotes
In August 1995, the FCC proposed a new "Family Radio Service" to operate in spectrum currently used by the GMRS. In July 1994, Tandy Corporation (the parent company of Radio Shack) had petitioned the FCC to create this new radio service. For a discussion of the FCC proposal, see the August/September 1995 PRE and its accompanying publication, FCC Proposes to Create the "Family Radio Service." For a list of other PRSG publications about the FRS proposal, see the list on the last page below.
Sixty-five parties filed comments to the FRS proposal. The majority of commenters were GMRS licensees, and all expressed concern about the interference that FRS transmissions in the 467 MHz band will cause to GMRS repeaters. The spacing (12.5 KHz) between the FRS 467 MHz channels and the adjacent ones used for GMRS repeater input communications is insufficient to distinctly separate the signals. The FRS transmissions will overlap into and cause interference to GMRS repeater communications.
GMRS users also cited numerous other problems with the FRS proposal, including prior FCC difficulties with mixing similar licensed and unlicensed services on the same channels. (This caused operational chaos and an enforcement nightmare when unlicensed "kiddie-talkies" and then-licensed CB radios operated on the same 27 MHz channels. The FCC eventually moved the unlicensed units to 49 MHz.) Commenters also described other technical problems with the FRS proposal that will substantially disrupt future GMRS operations. Many also made constructive recommendations for alternative policies.
The FCC ignored or rejected these objections and even the constructive recommendations, and instead adopted rules for the FRS essentially as it originally proposed, with only a minor concession to protect GMRS repeaters.
The R&O's most fundamental flaw is its failure to implement its own alleged intentions. In the first three paragraphs, the FCC states several specific concepts that it supposedly has applied to the FRS.
However, the means to implement these desired objectives is woefully insufficient or lacking altogether.
As discussed extensively by many commenters to the NPRM and to Tandy's original Petition, communications range at these UHF frequencies is determined not by transmitter power, but by antenna height. The new rules also attempt to restrict communications range by limiting FRS transmitter antennas.
Depending on how FRS radios are marketed (for instance, what kind of range is described in equipment advertisements), FRS users will likely be very frustrated with the range and performance of these units. Based on complaints we already hear from purchasers of current Tandy GMRS radios, consumer expectations are not met even with current, higher powered GMRS radios!
As these expectations of communications range and performance of FRS units become widespread, users will inevitably attempt to modify or to amplify FRS equipment, and to establish networks of FRS repeaters.
Significantly, the FCC rules do not prohibit FRS repeaters!
The failure of the R&O specifically to prohibit FRS repeater operations is a virtual guarantee that FRS repeaters will become a reality! Such stations would enhance communications range in a way that would violate the specific intent of the FRS.
These FRS repeaters would be perfectly legal under the recently adopted rules. There is no effective way to limit FRS receiver antennas. A conventional high-gain GMRS antenna advantageously located atop a tall building or mountain could also receive FRS signals, in either the FRS 462 MHZ or 467 bands.
The transmitter component of the FRS repeater could be merely a lawfully operating FRS transmitter unit coincidentally colocated with some external receiver, and employing a "VOX"-type (i.e., automatically voice-activated) transmitter. (Comments to Tandy's Petition and to the FCC's NPRM clearly indicated that some manufacturers intend to offer FRS units with precisely this automatic VOX capability.)
Since no "apparatus" (in the sense prohibited by para. 95.194(c) of the new rules) need be physically "attached" to the FRS transmitter unit, this repeater operation would be perfectly legal. It would merely retransmit the audio signal presented in its near vicinity by the external receiver.
FRS repeaters could lawfully repeat transmissions of other FRS communications (on any channel), of GMRS transmissions (on any channel), of ham radio communications (on any channel or band), or indeed of any communications from any service. The FRS rules completely fail to address or to prohibit such cross-channel, cross-band, or cross-service "repeater-type" transmissions.
[Additional Comments added in February 2003: A few FRS repeaters have indeed been put into operation. That such FRS repeaters have not become more common is probably due to the fact that no manufacturer has made FRS transceivers that operate on a "split frequency" basis, for instance transmitting on 467.5625 MHz {FRS channel 8} and receiving on 462.5625 {FRS channel 1}.]
That the Family Radio Service is intended exclusively or even just primarily for family communications has been a hoax from the beginning. Through its broad distribution and sales structure, Tandy has become the primary supplier of GMRS radios for intentional business and commercial use nationally. On the basis of inquiries from purchasers, PRSG estimates that one-third to one-half of all of Radio Shack's tens of thousands of GMRS radios have been put into business or commercial service.
In a note of remarkable if unintentional honesty, the FCC now even admits this commercial purpose of the FRS when it says:
"Small businesses may be manufacturers or retailers of devices used in the service, or they may be users of this service in their business activities."
-- FRS R&O, last sentence of para. 20(d).
Several parties commenting on the FRS NPRM noted this likely use of GMRS/FRS spectrum, in direct violation of the FCC's stated intent:
"(The FCC) seek(s) to discourage the proliferation of what are typically Part 90 uses of the GMRS. The GMRS is not and should not become the `other' Business Radio Service."
-- Report and Order, FCC Docket 87-265, para. 16.
Commercial and industrial users seeking unlicensed radio communications are likely to rush to FRS. They will create for this allegedly family radio service the same kind of problems that the FCC previously found existed in the GMRS. Intensive commercial use will usurp available FRS channels and effectively prevent its use for personal and family communications.
[Additional Comments added in February 2003: In 2002, the Industrial Telecommunications Association (ITA) petitioned the FCC to prohibit routine daily business communications on FRS channels. ITA is a frequency coordinator for certain radio services, and derives income from "selling" coordinations. Click here to go to the "What's New" page for links to more information about this.]
In its zeal to implement only the most simplified and rudimentary operating rules and restrictions, the FCC has left gaping loopholes for FRS operations that would be entirely in violation of the stated intent of the allegedly "Family" Radio Service.
The PRSG agrees that transmitter restrictions should be used wherever possible to reinforce desirable operating behaviors. Unfortunately, the FCC failed to consider other transmitter limitations that are necessary to assure proper lawful, shared-channel operation of FRS stations. In comments both to Tandy's Petition and to the FCC's NPRM, numerous parties had discussed such concepts as transmitter time-out timers, limitations on the use of tone coding that could cause the unauthorized activation on GMRS repeaters, and restrictions on external keying and audio coupling to FRS transmitters.
Instead, manufacturers argued (and the FCC accepted) that FRS transmitters should have as few restrictions as possible. Unless these standards are changed, this guarantees that FRS transmitters will be cheaply made, and will employ inexpensive, band-smashing technology on channels tightly sandwiched in between but overlapping current GMRS channels.
GMRS repeater operators are justifiably concerned about potential interference from FRS transmissions on the 467 MHz FRS interstitial frequencies. Under the new FRS rules, when such interference problems occur, GMRS licensees will have no legal recourse!
In its original Petition, Tandy suggested that FRS should be given a secondary status to GMRS primary status. That would mean that FRS users would have to accept any interference caused by lawful GMRS operations. FRS users would also be obliged to make any changes necessary to avoid causing interference to licensed GMRS users.
The FRS R&O is completely silent on the issue of FRS operation secondary to GMRS operation. This effectively means that FRS and GMRS use are co-primary -- operations in neither service would be secondary to the other. Neither would be required to protect or to be subservient to the other.
If even the most grievous and malicious FRS operations interfere with licensed GMRS operations, the GMRS users have no recourse and must accept this interference. Given the absence of technical standards addressing this issue, someone could operate a lawful FRS transmitter on an FRS 467 MHz channel immediately adjacent to your repeater and even at the same site, even with continuous, "key-down" transmission, total blocking your repeater input, and you would have no right to demand cessation of this interference!
This failure to protect existing licensed users of a radio service from similar but unlicensed interference, even if deliberate, is unprecedented in FCC history, and is an outrageous denial of GMRS licensee rights.
This co-primary status is no mere oversight by the FCC. The many comments (from Tandy's original Petition and from the numerous parties that complained about the lack of protection of GMRS from FRS interference) identified this as a central issue. Both the NPRM and now the R&O failed (indeed, refused!) to resolve this primary-versus-secondary issue -- they failed even to acknowledge its existence.
There is a limited opportunity for parties to request that the FCC reconsider these new FRS Rules. The PRSG intends to petition for such a reconsideration, covering many of the deficiencies discussed on the following pages. A copy of this petition will be made available on the PRSG "Fax-on-Demand" service. A printed copy will also be available for a nominal charge. [NOTE: PRSG and another party did file Petitions for Reconsideration. These were met with opposition from the industry, and yet additional petitions that attempted to squash arguments about legitimate concerns of GMRS licensees.]
[NOTE: Below is the actual Report and Order adopted in this Docket. The FCC language is in fixed-width type, and the accompanying PRSG commentary is in conventional HTML type with indented margins. Footnotes are indicated by [FN #], and are presented at the end of the text of the R&O. Please note also that this is the original text. The FCC has subsequently modified the FRS rules to permit limited use for data transmissions. Click here for a copy of the most recent FRS rules.}
Report and Order I. Introduction II. Executive Summary III. Discussion A. Need for the FRS B. Channels C. Transmitter Technical Standards D. Administration of the FRS IV. Conclusion V. Procedural Matters VI. Ordering Clauses Appendix A (Commenters) Appendix B (Rule Language) Footnotes
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of )
)
Amendment of Part 95 of the ) WT Docket No. 95-102
Commission's Rules to Establish a ) RM-8499
Very Short Distance Two-Way Voice )
Radio Service )
REPORT AND ORDER
Adopted: May 10, 1996 Released: May 15, 1996
By the Commission:
I. Introduction
1. On June 22, 1995, the Commission adopted a Notice of Proposed Rule
Making (Notice) proposing to establish a very short distance, unlicensed,
two-way voice personal radio service called the Family Radio Service
(FRS). [FN 1] We initiated the Notice in response to a petition filed by
the Radio Shack Division of Tandy Corporation (Tandy). [FN 2] Comments to
the Notice agreed that there is a burgeoning need for the FRS, and that
innovative products can be supplied at low cost. [FN 3] This Report and
Order establishes this new service and adopts rules substantially as
proposed in the Notice.
PRSG Observes:
Although comments from manufacturers supported the creation of the FRS, current and prospective spectrum users questioned the need for such a low-performance service. Many of the public comments cautioned about applying the rubric "Citizens Band" to the new service, cautioning it would only invite the infamous abuses and disregard for proper or intended operating procedures that have come to afflict the Citizens Band Radio Service at 27 MHz.
II. Executive Summary
2. The Notice proposed to amend Part 95 of the rules [FN 4] to establish the FRS -- a service aimed at providing an affordable and convenient means of direct, short range two-way voice communications among small groups of persons. This Report and Order adopts rules establishing the FRS. The only changes from the Notice are improved transmitter technical standards, as recommended in the comments, to maximize spectrum sharing with the General Mobile Radio Service (GMRS). [FN 5] This new service will help fill a market niche in short distance, personal communication needs. The FRS will enable families, friends and associates to communicate among themselves within neighborhoods and while on group outings. The FRS will share two small frequency bands with the GMRS. [FN 6] Interconnection with the Public Switched Network (PSN) will be prohibited. Operating authority in the FRS will be by rule rather than by individual licenses and administration will be primarily through transmitter technical standards.
PRSG Observes:
The R&O's first three paragraphs establish important fundamental criteria in this rulemaking. Unfortunately, the R&O fails to accomplish its objectives.
III. Discussion
A. Need for the FRS
3. PROPOSAL. Our goal in proposing to establish the FRS was to provide families, friends and associates the capability to communicate with one another over a very short range, typically a few city blocks. We envisioned the FRS as facilitating activities around the home, throughout the neighborhood, at group outings and at activities where group members become separated, either planned or inadvertently. The FRS also would be useful to hunters, campers, hikers, bicyclists and other outdoor activity enthusiasts who need to communicate with other members of their party who are out of speaking range or sight but still in the same general area. Further, we believed the FRS would create new jobs as well as provide more choices for consumers.
4. COMMENTS. The comments overwhelmingly support establishing the FRS. For example, the Consumer Electronics Group of the Electronics Industry Association (EIA) states that there is significant demand for the FRS. [FN 7] Motorola, Inc. (Motorola) contends that the general public has a strong need for this type of personal communication, and the FRS would meet this need. [FN 8] It notes that the FRS can be used by parents for keeping track of children, and grass roots public safety organizations, such as Neighborhood Watch groups, among others. [FN 9] Further, Motorola states that manufacturers can provide palm-sized FRS units at low cost. [FN 10] ALLTEL Mobile Communications, Inc. (ALLTEL) agrees with Motorola that the FRS would fill a narrow market niche unmet by traditional private land mobile radio services or common carriage communications providers. [FN 11] According to ALLTEL, the FRS would facilitate activities around the home and local neighborhood because it would provide small groups adequate voice communications over a very short distance. [FN 12] Cobra Electronics Corp. (Cobra) also believes that the FRS would fill a need for communications by families and sports enthusiasts. [FN 13] Tandy says FRS will enable millions of Americans to use a high quality communication service to maintain close contact with only a modest investment. [FN 14] Tandy comments that it plans to market FRS units in the $100-$150 range. [FN 15]
PRSG Observes:
Fifty-eight of the 73 comments (including reply comments) filed with the NPRM in this docket opposed the creation of the FRS as proposed. The FCC characterizes the 15 supportive comments (about one-fifth of those filed) as "overwhelming support." The FCC listened just to radio manufacturers, not to radio users GMRS licensees, nor to the kind of personal and family users for whom the FRS is allegedly intended.
Tandy's characterization of FRS radios as providing "high quality" communications is particularly misleading. These radios will have severe limitations in communications range, likely to be a significant source of frustration to FRS users. Because of the relatively long wavelength (three-quarters meter), FRS radios will especially be poor performers for building-internal communications (such as within shopping malls). A much better choice would have been to place these units in a much higher frequency band (above 2 GHz). Space is already available there for unlicensed, one-watt, spread spectrum voice communications.
5. DISCUSSION. The comments affirm that there is a need for a direct, short range, personal communications capability of the type envisioned in the Notice and that manufacturers are prepared to offer innovative palm-size FRS units at very affordable prices. The FRS would enhance public and personal safety and service to individuals, including individuals with disabilities and parents wanting to keep in touch with their children. Many families and other small groups have need for their members to communicate with each other while visiting shopping malls and amusement parks, attending sporting events, camping or when taking part in recreational and other activities. Finally, it would create new jobs as well as provide more choices for American consumers to meet their communications requirements. Therefore, we are adopting rules establishing the FRS.
PRSG Observes:
The FCC's definition of "short range" and consumers' expectations are likely to be substantially different. Performance inside buildings, and in the near vicinity of other obstructions, will be extremely limited at best.
Also, what does "direct" mean in this context. If it means a non-repeater-based configuration, this needs to be stated specifically.
B. Channels
6. PROPOSAL. In the Notice, we proposed to authorize fourteen channels for the FRS. [FN 16] The channels are located within the two Ultra-High Frequency (UHF) bands used by the GMRS. Seven of the fourteen channels would be new channels positioned on frequencies between the eight GMRS repeater input channels. The remaining seven channels are channels currently available to GMRS licensees for communications similar to those proposed for the FRS. [FN 17]
PRSG Observes:
The seven allegedly new channels are not distinct channels at all. They are sandwiched between and actually overlap the existing GMRS repeater-input frequencies.
7. COMMENTS. Commenters generally supported our proposal to use channels in the GMRS bands. The Telecommunications Industry Association (TIA) and Tandy, for example, agree that the channels we proposed for the FRS would serve the purpose intended. [FN 18] Cobra and Michael T. McKenna also voice support for using these channels for the FRS. [FN 19] GMRS licensees, however, oppose sharing the GMRS frequency bands with the FRS. [FN 20] They are concerned that FRS units transmitting on channels shared with GMRS stations or on channels adjacent to GMRS repeater input channels will cause interference to GMRS communications. [FN 21] They suggest FRS channels be placed in other frequency bands [FN 22] or be taken from channels assigned other radio services. [FN 23] EIA requests that interference to the reception of signals transmitted by television stations be minimized. [FN 24] SpaceLabs Medical, Inc. (SpaceLabs) is concerned that FRS units could cause erroneous results in medical monitoring equipment used in health care facilities. [FN 25]
PRSG Observes:
Commenters did not "generally support" using channels in the GMRS bands -- more than three-quarters "opposed" it! In general, the primary support came from radio manufacturers, not current or potential radio users.
8. DISCUSSION. We are adopting our proposal to authorize FRS to use fourteen channels located within the bands now allocated to the GMRS. [FN 26] In an era of unparalleled demand for radio communications, it is necessary that we promote the efficient and intensive use of spectrum whenever possible. One way of increasing spectrum efficiency is through spectrum sharing. We believe the bands are ideally suited for sharing between the FRS and GMRS for three reasons. First, the GMRS channels are not heavily used. [FN 27] Second, the two services are similar in that both are intended to operate in a shared environment and provide for the personal communications needs of the general public. Finally, the FRS is a low power service such that the range of any particular transmitter is small as compared to the more wide area nature of GMRS.
PRSG Observes:
The claim that GMRS channels are not heavily used was never documented by FRS proponents. On average, there are more licensees per channel in GMRS than on the comparable UHF Business Radio Service repeater channels.
The FCC's admission of "a similarity" between intended GMRS and FRS use conveniently ignores the disastrous situation that arose when unlicensed Part 15 transceivers were collocated with then-licensed CB transceivers at 27 MHz.
The power differential between GMRS and FRS is entirely meaningless. The vast majority of GMRS licensees operate primarily or exclusively low-power hand-held radios. The half-watt ERP FRS transmitter limit is operationally indistinguishable from that of these handheld transceivers also operating with their own inefficient "rubber duckie" antennas.
9. We believe that claims of potential interference to GMRS systems from the operation of FRS units are overstated. The palm-sized FRS units would use only a small fraction of the transmitter power that GMRS stations are authorized to use. Moreover, a FRS unit must use a small and relatively inefficient antenna. A GMRS station, in contrast, may use a large gain antenna located on a tower or building. These differences, combined with the capture effect of frequency modulation emission types should preclude any disruption of GMRS communications. [FN 28]
PRSG Observes:
Only GMRS land stations (especially conventional base stations and repeaters) use "large gain antenna(s) located on a tower or building." These GMRS land stations may communicate only with GMRS mobile radios, which for most GMRS licensees means those typical half-watt ERP, licensed handheld GMRS radios. There is no operational advantage of the typical licensed GMRS handheld radio over a FRS radio. The potential interference to GMRS systems from the operation of FRS units is hardly "overstated," as the R&O claims.
Furthermore, the "capture effect" (R&O, footnote 28) would actually increase the probability of interference from an FRS transmission to a GMRS radio communications exchange. We strongly support the concept proposed in the R&O that the FCC should use transmitter technical standards, especially in an unlicensed service, to minimize interference. This concept should also be used to encourage proper operating behaviors. Unfortunately, the FCC's minimalist technical standards fail to incorporate important limitations (such as transmitter time-out timers). The even-more-minimalist operational standards fail to prohibit retransmissions of other radio signals. This will inevitably result in FRS radios being operated as repeaters.
10. EIA and SpaceLabs also raise the issue of interference. They, however, provide no specifics on interference. Rather their comments appear to be based solely upon the presumption that when new services are authorized the chance of interference to radio devices currently operating is increased. There is no evidence before us that the FRS would cause interference to television reception or medical monitoring equipment. Further, we have taken steps to minimize the interference potential of FRS transmitters in general. [FN 29]
C. Transmitter Technical Standards
11. PROPOSAL. In the Notice we proposed a maximum transmitter power of 0.500 watt carrier power, various emission limitations and a requirement that the antenna be an integral part of the FRS unit. [FN 30] We also proposed that an FRS unit could, if desired, incorporate a selective calling capability so that a user could receive only messages specifically addressed to him or her. Our proposed transmitter technical standards were intended to limit the interference potential to other services as well as make it possible for the fourteen channels to serve millions of FRS users simultaneously.
12. COMMENTS. The comments support our efforts to use transmitter technical standards to minimize interference and maximize reuse. ALLTEL, for example, states our proposal would provide for adequate communications over a very short distance, thereby allowing many small groups of persons to share the same channels. [FN 31] EIA, Cobra, and Uniden America Corporation (Uniden) also support the technical standards we proposed. [FN 32] Motorola, however, argues that even more stringent standards would enhance spectrum sharing with the GMRS and are technologically practical. It suggests the allowable frequency variation can be reduced from 0.0005 percent to 0.00025 percent. [FN 33] Further, according to Motorola, the maximum frequency deviation can be reduced from 5.0 kHz to 2.5 kHz and audio frequency response should be limited to 3.125 kHz. [FN 34] Motorola also recommends that transmitter power be measured in terms of effective radiated power (ERP) at the antenna rather than carrier power as further interference protection to adjacent channels. [FN 35] With regard to a selective calling [FN 36] option, EIA, Cobra, Uniden, and Motorola support our proposal that it be optional. [FN 37] PRSG requests we prohibit FRS units from transmitting tones that could cause a GMRS repeater to transmit on the 467 MHz channels. [FN 38]
13. DISCUSSION. Our primary objectives in setting technical standards are to ensure (1) that FRS units do not cause interference to other services and (2) that large numbers of users can share the same channels in the same or adjoining neighborhoods or other areas. The comments support a maximum power of 0.500 watt and a requirement that the antenna be an integral part of the FRS unit. Therefore, we are adopting these proposals. As suggested by Motorola, we are adopting an allowable frequency variation of 0.00025 percent, a maximum frequency deviation of 2.5 kHz and an audio frequency response of 3.125 kHz. These more stringent standards will further minimize interference and increase the FRS-GMRS spectrum sharing capability without a significant increase in costs. We will also specify transmitter power in terms of ERP as suggested by Motorola. We will not require suppliers to incorporate selective calling capability in FRS units. We believe suppliers will incorporate features that FRS users demand as the market for this service develops. The final rules, therefore, allow a manufacturer the option to provide selective calling capability if and when it desires, and to use the technology the manufacturer decides is most appropriate.
PRSG Observes:
Motorola's recommendations for a tighter FRS transmitter frequency stability and for restrictions on deviation level and audio frequency response were incorporated into the rules. This will reduce (but not eliminate) FRS interference to GMRS repeaters.
Another adopted Motorola request, that transmitter power be measured in terms of ERP, actually increases FRS transmitter output, since the units use "relatively inefficient antennas." Unfortunately, the FCC has failed to incorporate other reasonable standards into the language of the actual rules. Merely because users may "demand" additional features does not mean that the rules should permit them without further consideration. Additional features and capabilities should be permitted only to the extent that they are consistent with and do not compromise basic guidelines on how FRS radios should operate. The claimed desire for building-internal communications should have led the FCC to choose a much higher frequency band.
In footnote 36, the FCC reveals a misunderstanding about the concept of "selective calling," and especially how it should be distinguished from that of "receiver muting." The limited FRS spectrum must be shared by all users. There is no effective "sharing" unless spectrum users monitor before transmitting, and refrain from transmitting if that would cause interference to pre-existent or emergency communications.
"Selective calling" should never permit, and especially should not encourage, spectrum users to avoid monitoring before transmitting. Instead, selective calling should only alert the recipient that some other radio is attempting to initiate a conversation. The radio operator, once so alerted, must then monitor the channel to determine its availability.
In GMRS, receiver muting (through the use of continuous subaudible tone or digital codes) is used extensively for the remote control of repeater ("mobile relay") stations. It is also frequently misused as a means of selective calling. Allowing such misuse in FRS would be inappropriate, and the concept of "remotely controlling" FRS transmitters should be prohibited. PRSG recommended, and the FCC acknowledged but failed to consider, that continuous signal encoding of the type used for remotely controlling GMRS repeaters should be prohibited in FRS. Only that type of "selective calling" that momentarily alerts the intended signal recipient of an incoming call should be permitted in FRS.
D. Administration of the FRS
14. PROPOSAL. In the Notice, we proposed an administrative approach for the FRS that would minimize regulation. [FN 39] Rather than issue individual licenses, we proposed to administer the FRS within the Citizens Band (CB) Radio Service where operation may be authorized by rule under Section 307(e) of the Communications Act. [FN 40] Administration would be through transmitter technical standards and governed by four simple operating rules. [FN 41] We also proposed to prohibit interconnection with the PSN.
PRSG Observes:
Unfortunately, in its quest for merely "four simple operating rules," the R&O leaves completely unresolved numerous issues, as discussed in these annotations. A basic complaint voiced by many commenters who are also GMRS licensees is that categorizing FRS as a form of "citizens band radio" is an open invitation to the kinds of infamous abuse and lawlessness that characterize 27 MHz CB operations.
15. COMMENTS. The comments strongly agree with our approach. Motorola, for example, states that it is imperative that operation in the FRS not require individual licenses. [FN 42] Its experience is that consumers are disinclined to participate in radio services that require licenses, especially where the Commission's regulatory and/or application fees would account for an excessive percent of what should be a relatively low cost product. [FN 43] Motorola also states that licenses serve no purpose given the very low power and itinerant usage of FRS stations. [FN 44] Tandy agrees. [FN 45] The Personal Radio Steering Group (PRSG), however, states that licenses are necessary to prevent business and non-family communications from being transmitted in the FRS. [FN 46]
PRSG Observes:
The massive public opposition to overlaying the FRS atop existing and adjacent, overlapping GMRS channels makes the FCC's claim that "(t)he comments strongly agree with our approach" a gross misrepresentation.
Motorola misunderstood or misrepresented the value of licensing to peer-enforcement efforts in a personal radio service. The itinerant nature of operations and the claim of low transmitter power (although, as discussed previously, FRS transmitter power will be operationally indistinguishable from that in typical GMRS handheld radios) do not diminish the importance of a licensing database for identifying sources of and seeking resolution of interference.
16. Tandy, the National Emergency Number Association, Cobra, Uniden, Motorola and Pacific Bell Mobile Services agree we should prohibit interconnection of FRS stations to the PSN. [FN 47] They state that interconnection with the PSN would prevent the FRS from fulfilling its contemplated role as a private personal radio service. PRSG also agrees telephone interconnection should be prohibited. It states that the FM technology FRS units will use and the small amount of spectrum allocated to GMRS and FRS could not support telephone traffic. [FN 48] EIA contends. however, that PSN interconnection should be optional. [FN 49]
17. DISCUSSION. We agree with the majority of the comments that argue that we should minimize regulation and that individual licensing is unnecessary. The FRS is a very low power, short-range. person-to-person radio service with users operating in a mobile environment. Experience has shown that the existence of a data base of licensees in such a service will not assist us in enforcement efforts nor is it useful for spectrum management purposes. [FN 50] Further, individual licensing is costly to the public and administratively burdensome to the Commission. Also, because the universe of potential users of the FRS is the American public, we believe administration of the FRS should be accomplished primarily through establishing transmitter technical standards rather than complex operating rules. Therefore, we are adopting the regulatory approach for the FRS that we proposed. It will be administered within the Citizens Band (CB) Radio Service. Operation will be authorized by rule. Administration will be by transmitter technical standards and simple operating rules.
PRSG Observes:
Although the FCC characterizes FRS radios as intended to be "operat(ed) in a mobile environment," nowhere in the rules is a manufacturer prohibited from making an FRS base station radio (desk-top mounted, powered from an AC charger or power supply, with a table microphone, etc.).
The FCC claims that "the existence of a data base ... will not assist us in enforcement efforts." This reflects not on the value of a licensing database, but of the FCC's own meager commitment to enforcement. The success of peer-education and peer-enforcement efforts is predicated precisely on identifying radio abusers. The availability of a licensing database is critical to this self-enforcement.
The FCC's opinion that "establishing transmitter technical standards rather than complex operating rules" would be satisfactory for administering the FRS presumes that such extensive standards have been adopted. They have not! The few technical standards that have been adopted fail to address certain critical performance parameters (time limits, monitoring before transmitting, remote control). Even with such technical standards, additional rules (such as prohibiting the retransmission of other radio signals) are still necessary.
18. As with the vast majority of the commenters, we continue to believe that interconnection with the PSN should be prohibited. The FRS is intended to fill a niche market that provides families, friends and associates the capability to communicate with one another over a very short range, typically a few city blocks. Allowing interconnection would change the basic nature of the service. Further, there are only fourteen channels available to the millions of potential FRS users. Allowing full duplex interconnection would reduce the number of usable channels to seven and lengthen the time each channel is in use. Finally, allowing interconnection could require licensing and additional regulatory burdens. Therefore we decline to allow interconnection with the PSN. Consumers interested in having this capability may subscribe to the services offered by one of the many commercial radio service providers.
PRSG Observes:
Telephone interconnection would certainly increase channel occupancy and reduce spectrum sharing, even if it weren't fully duplexed (as it need not be, with some currently available hardware).
The number of usable channels would also be reduced if FRS radios were permitted to retransmit other radio signals, whether on a real-time, fully-duplexed, cross-channel basis, or on a delayed-time, potentially single-channel "store-and-forward" basis. The number of usable channels would also be reduced if FRS transmitters were permitted to operate continuously (such as is done by "baby monitors" and even surreptitious "bugging" devices).
IV. Conclusion
19. We believe that establishing this service will fill a niche in the personal communications marketplace, and is an important step toward maximizing the efficient use of the wireless spectrum. These rule changes create a new personal wireless service that will utilize very low power, convenient-to-carry units capable of transmitting voice communications only over a very short range. These changes will enable families, friends and associates to conduct high quality two-way wireless voice conversations among themselves, thereby promoting service to individuals, and public and personal safety. We also believe these rule changes are consistent with the intent of the Telecommunications Act of 1996 that the Commission secure higher quality service for American telecommunications consumers and encourage the rapid deployment of new telecommunications technologies.
PRSG Observes:
"(C)onvenient to carry units" implies FRS portability and self-containment, but nowhere do the technical rules actually require these features. Supposedly limiting the FRS to "communications only over a very short range" will certainly be met with the same cynicism and disregard that characterizes non-compliance with the range restrictions specified in the current 27 MHz CB rules. Who will be the first to install and operate "an FRS repeater in a box" from a window of the top floor of some high-rise building?
The suggestion that FRS would encourage "the rapid deployment of new telecommunications technologies" is totally absurd. The narrow-band FM emissions of the FRS represent an antiquated and spectrum-inefficient technology. Permitting NBFM in a start-up, consumer-oriented, unlicensed service will make very difficult or impossible the introduction of more efficient and appropriate technologies later.
V. Procedural Matters
20. Pursuant to the Regulatory Flexibility Act (Pub. L. No. 96-354, 94 Stat. 1165, 5 U.S.C. para. 603, et seq. (1981), the Commission attached an Initial Regulatory Flexibility Analysis (IRFA) as Appendix A to the Notice of Proposed Rule Making in WT Docket No. 95-102. Written comments on the IRFA were requested. The Commission's Final Regulatory Flexibility Analysis is as follows:
A. NEED AND PURPOSE OF THE ACTION. Our objective is to establish a very short range, license-by-rule, two-way voice radio service in the UHF portion of the radio spectrum to meet the burgeoning public demand for an affordable and convenient means of direct, short-range, two-way voice communication among small groups of persons.
B. ISSUES RAISED IN RESPONSE TO THE INITIAL ANALYSIS. There were no comments submitted in response to the Initial Regulatory Flexibility Analysis.
C. SIGNIFICANT ALTERNATIVES CONSIDERED AND REJECTED. All significant alternatives have been addressed in this Report and Order.
PRSG Observes:
"All significant alternatives have been addressed in this Report and Order." Hardly! The FCC deliberately ignored a number of alternatives proposed by commenters.
D. DESCRIPTION, POTENTIAL IMPACT, AND NUMBER OF SMALL ENTITIES INVOLVED. These adopted rule changes will allow greater flexibility in the use of the radio spectrum, and meet the needs of the public for a short distance, two-way high quality voice radio service. Small businesses may be manufacturers or retailers of devices used in this service, or they may be users of this service in their business activities.
PRSG Observes:
The "smoking gun"! The FRS, despite its name, despite repeated FCC statements in this R&O, is intended for use by business and commercial users.
By means of this disingenuous and hypocritical docket, the FCC is proceeding full-speed to abandon the important policies established in the Report and Order in PR Docket 87-265, intended to protect the very limited GMRS spectrum, available for personal and family users, from usurpation by commercial and industrial entities eligible in other radio services.
VI. Ordering Clauses
21. Accordingly, IT IS ORDERED that Part 95 of the Commission's Rules and Regulations IS AMENDED as set forth in Appendix B. Authority for this action is contained in Sections 4(i), 303(r), and 307(e) of the Communications Act of 1934, as amended, 47 U.S.C. paras. 154(i), 303(r), and 307(e).
22. IT IS FURTHER ORDERED that these amendments are effective 30 days after publication in the Federal Register.
23. IT IS FURTHER ORDERED that this proceeding IS TERMINATED.
24. For further information, contact William T. Cross, Wireless Telecommunications Bureau, Private Wireless Division, (202) 418-0680.
FEDERAL COMMUNICATIONS COMMISSION William F. Caton Acting Secretary
Appendix A
Comments: ALLTEL Mobile Communications, Inc. Cobra Electronics Corporation Electronic Industries Association, Consumer Electronics Group Susan L. Feit Michael T. McKenna Motorola, Inc. National Emergency Number Association Pacific Bell Mobile Services Personal Radio Steering Group, Inc. REACT International, Inc. SpaceLabs Medical, Inc. Tandy Corporation, Radio Shack Division Telecommunications Industry Association, Mobile and Personal Communications Private Radio Section Uniden America Corporation numerous GMRS licensees
Reply comments: Cobra Electronics Corporation Kerry Cochran Electronic Industries Association, Consumer Electronics Group Bennett Z. Kobb Motorola, Inc. National Association of Broadcasters Personal Radio Steering Group, Inc. Tandy Corporation, Radio Shack Division Telecommunications Industry Association, Mobile and Personal Communications Private Radio Section Uniden America Corporation
Appendix B
Part 95 of Chapter I of Title 47 of the Code of Federal Regulations is amended as follows:
[NOTE: These are the rules as initially implemented. The FCC has subsequently amended these rules to permit data communications. Click here to go to the PRSG's "What's New" page for the latest information on these recent modifications. An annotated copy of the current MURS rules is also available.]
Part 95 -- Personal Radio Services
1. The authority citation for Part 95 continues to read as follows:
AUTHORITY: Secs. 4, 303, 48 Stat. 1066, 1082, as amended; 47 U.S.C. para. 154, 303.
2. Subpart B, Sections 95.191-95.194, is added to Part 95 to read as follows:
Subpart B -- Family Radio Service (FRS)
GENERAL PROVISIONS
Sec. 95.191 (FRS Rule 1) Eligibility and responsibility. 95.192 (FRS Rule 2) Authorized locations. 95.193 (FRS Rule 3) Types of communications. 95.194 (FRS Rule 4) FRS units.
Subpart B -- Family Radio Service (FRS)
GENERAL PROVISIONS
Para. 95.191 (FRS Rule 1) Eligibility and responsibility.
(a) Unless you are a representative of a foreign government, you are authorized by this rule to operate an FCC certified FRS unit in accordance with the rules in this subpart. No license will be issued.
(b) You are responsible for all communications that you make with the FRS unit. You must share each channel with other users. No channel is available for the private or exclusive use of any user.
Para. 95.192 (FRS Rule 2) Authorized locations.
(a) Provided that you comply with these rules, you are authorized to operate an FRS unit:
(1) Within or over any area of the world where radio services are regulated by the FCC; (this area includes the fifty United States and the District of Columbia, the Commonwealth of Puerto Rico, the United States Virgin Islands (50 islets and cays), American Samoa (seven islands), the Commonwealth of Northern Mariana Islands, and Guam Island) or
(2) Within or over any other area of the world, except within or over the territorial limits of areas where radio services are regulated by an agency of the United States other than the FCC or any foreign government (you are subject to its rules); or
(3) Aboard any vessel or aircraft registered in the United States, with the permission of the captain, that is within or over any area of the world where radio services are regulated by the FCC or upon or over international waters; or
(4) Aboard any unregistered vessel or aircraft owned or operated by a United States citizen or company that is within or over any area of the world where radio services are regulated by the FCC or upon or over international waters.
(5) You must operate the FRS unit only according to any applicable treaty to which the United States is a party. The FCC will make public notice of any such conditions.
(b) Your use of an FRS unit must not cause harmful interference to a FCC monitoring facility. Doing so could result in imposition of restrictions upon the operation of the FRS unit within 0.8 km (0.5 mile) of the facility by its Engineer-in-Charge. (Geographical coordinates of the facilities that require protection are listed in para. 0.121(c) of this chapter.)
(c) The FCC may impose additional restrictions on a FRS station if the station is located at a point within the National Radio Quiet Zone (an area within the States of Maryland, Virginia and West Virginia). The Zone is the area bounded by:
(1) 39 Deg 15' N. on the North; (2) 78 Deg 30' W. on the East; (3) 37 Deg 30' N. on the South; and (4) 80 Deg 30' W. on the West.
Para. 95.193 (FRS Rule 3) Types of communications.
(a) You may use an FRS unit to conduct two-way voice communications with another person. You may use the FRS unit to transmit one-way communications only to establish communications with another person, send an emergency message, provide traveler assistance, make a voice page, or to conduct a brief test.
(b) The FRS unit may transmit tones to make contact or to continue communications with a particular FRS unit. If the tone is audible (more than 300 Hertz), it must last no longer than 15 seconds at one time. If the tone is subaudible (300 Hertz or less), it may be transmitted continuously only while you are talking.
(c) You must not use an FRS unit in connection with any activity which is against federal, state or local law.
(d) You must, at all times and on all channels, give priority to emergency communication messages concerning the immediate safety of life or the immediate protection of property.
(e) No FRS unit may be interconnected to the public switched network.
Para. 95.194 (FRS Rule 4) FRS units.
(a) You may only use an FCC certified FRS unit. (You can identify an FCC certified FRS unit by the label placed on it by the manufacturer.)
(b) You must not make, or have made, any internal modification to an FRS unit. Any internal modification cancels the FCC certification and voids your authority to operate the unit in the FRS.
(c) You may not attach any antenna, power amplifier, or other apparatus to an FRS unit that has not been FCC certified as part of that FRS unit. There are no exceptions to this rule and attaching any such apparatus to a FRS unit cancels the FCC certification and voids everyone's authority to operate the unit in the FRS.
3. Section 95.401 is revised to read as follows:
Para. 95.401 (CB Rule 1) What are the Citizens Band Radio Services?
The Citizens Band Radio Services are:
(a) The Citizens Band (CB) Radio Service -- a private, two-way, short- distance voice communications service for personal or business activities of the general public. The CB Radio Service may also be used for voice paging.
(b) The Family Radio Service (FRS) -- a private, two-way, very short- distance voice communications service for facilitating family and group activities. The rules for this service are contained in Subpart B of this part.
4. Section 95.601 is revised to read as follows:
Para. 95.601 Basis and purpose.
These rules provide the technical standards to which each transmitter (apparatus that converts electrical energy received from a source into RF (radio frequency) energy capable of being radiated) used or intended to be used in a station authorized in any of the Personal Radio Services must comply. They also provide requirements for obtaining type acceptance of such transmitters. The Personal Radio Services are the GMRS (General Mobile Radio Service), the Family Radio Service (FRS), the R/C (Radio Control Radio Service), and the CB (Citizens Band Radio Service). For operating rules, see Part 95, subpart A-GMRS; subpart B-FRS; subpart C-R/C; and subpart D-CB.
5. Section 95.603 is amended by revising the heading and adding paragraph
(d) to read as follows:
Para. 95.603 Type acceptance or certification required.
* * *
(d) Each FRS unit (a transmitter that operates or is intended to operate in the FRS) must be certified for use in the FRS in accordance with Subpart J of Part 2 of this chapter.
6. Section 95.605 is revised to read as follows:
Para. 95.605 Type acceptance and certification procedures.
Any entity must request type acceptance for its transmitter when the transmitter is used in the GMRS. R/C or CB Radio Service, or IVDS following the procedures in Part 2 of this chapter. Any entity must request certification for its transmitter when the transmitter is used in the FRS following the procedures in Subpart J of Part 2 of this chapter. 7. Sections 95.627 through 95.669 are redesignated as 95.629 through 95.671 and a new Section 95.627 is added to read as follows:
Para. 95.627 FRS unit channel frequencies.
(a) The FRS unit channel frequencies are: Channel No. (MHz) 1. 462.5625 2. 462.5875 3. 462.6125 4. 462.6375 5. 462.6625 6. 462.6875 7. 462.7125 8. 467.5625 9. 467.5875 10. 467.6125 11. 467.6375 12. 467.6625 13. 467.6875 14. 467.7125
(b) Each FRS unit must be maintained within a frequency tolerance of 0.00025%.
8. Section 95.629 is amended by revising paragraph (b), redesignating paragraphs (d) and (e) as paragraphs (e) and (f) respectively, and adding a new paragraph (d) to read as follows:
Para. 95.629 Emission types.
*****
(b) An R/C transmitter may transmit any appropriate non-voice emission which meets the emission limitations of 95.633.
*****
(d) An FRS unit may transmit only emission type F3E. A non-voice emission is limited to selective calling or tone-operated squelch tones to establish or continue voice communications.
*****
9. Section 95.631 is amended by adding a new paragraph (c) to read as follows:
Para. 95.631 Emission bandwidth.
(c) The authorized bandwidth for emission type F3E transmitted by a FRS unit is 12.5 kHz.
10. Section 95.633 is amended by revising paragraph (b) to read as follows:
Para. 95.633 Unwanted radiation.
*****
(b) The power of each unwanted emission shall be less than TP as specified in the applicable paragraph:
Transmitter Emission type Applicable paragraphs
GMRS....... A1D, A3E, F1D, G1D, F3E, G3E with filtering (1), (3), (7) A1D, A3E, F1D, G1D, F3E, G3E without filtering (5), (6), (7) H1D, J1D, R1D, H3E, J3E, R3E (2), (4), (7)
FRS...... F3E with filtering (1), (3), (7)
NOTE: Filtering refers to the requirement in Para. 95.635(b)
R/C:
27 MHz band As specified in Para. 95.629(b) (1), (3), (7)
72-76 MHz band As specified in Para. 95.629(b) (1), (3), (7), (10), (11), (12)
CB..... A1D, A3E (1), (3), (8), (9) H1D, J1D, R1D, H3E, J3E, R3E (2), (4), (8), (9) A1D, A3E type accepted before September 10, 1976 (1), (3), (7) H1D, J1D, R1D, H3E, J3E, R3E (2), (4), (7) type accepted before September 10, 1976
*****
11. Section 95.635 is amended by revising paragraph (a) to read as follows:
Para. 95.635 Modulation standards.
(a) A GMRS transmitter that transmits emission types F1D, GID, or G3E must not exceed a peak frequency deviation of plus or minus 5 kHz. A GMRS transmitter that transmits emission type F3E must not exceed a peak frequency deviation of plus or minus 5 kHz. A FRS unit that transmits emission type F3E must not exceed a peak frequency deviation of plus or minus 2.5 kHz, and the audio frequency response must not exceed 3.125 kHz.
*****
12. Section 95.637 is amended by adding a new paragraph (d) to read as follows:
Para. 95.637 Maximum transmitter power.
*****
(d) No FRS unit, under any condition of modulation, shall exceed 0.500 W effective radiated power (ERP).
13. Section 95.645 is revised to read as follows:
Para. 95.645 FRS unit and R/C transmitter antennas.
The antenna of each FRS unit, and the antenna of each R/C station transmitting in the 72-76 MHz band, must be an integral part of the transmitter. The antenna must have no gain (as compared to a half-wave dipole) and must be vertically polarized.
14. Section 95.647 is revised to read as follows:
Para. 95.647 Power capability.
No CB or R/C station transmitter or FRS unit shall incorporate provisions for increasing its transmitter power to any level in excess of the limit specified in 95.637.
15. Section 95.649 is revised to read as follows:
Para. 95.649 Crystal control required.
All transmitters used in the Personal Radio Services must be crystal controlled, except an R/C station that transmits in the 26-27 MHz frequency band, and a FRS unit.
16. Appendix 1 to Subpart E is revised by adding the definition for FRS, in alphabetical order, to read as follows:
APPENDIX 1 TO SUBPART E GLOSSARY OF TERMS
*****
FRS. Family Radio Service.
*****
Footnotes:[FN 1: 10 FCC Rcd 8235 (1995).]
[FN 2: See Public Notice, July 26, 1994, Report No. 2033.]
[FN 3: A list of parties submitting comments and reply comments is in Appendix A.]
[FN 4: 47 C.F.R. Part 95.]
[FN 5: The GMRS is a land mobile radio service available to persons for two-way communications to facilitate the activities of licensees and their immediate family members. The rules for GMRS are in Part 95, Subpart A, of the Commission's Rules, 47 C.F.R. Part 95, Subpart A.]
[FN 6: The frequency bands are 462.5375-462.7375 MHz and 467.5375-467.7375 MHz.]
[FN 7: Comments of the Consumer Electronics Group of the Electronics Industry Association at 2.]
[FN 8: Comments of Motorola, Inc. at 5-6.]
[FN 9: Comments of Motorola at 6.]
[FN 10: Comments of Motorola at 6-7. Motorola states that it plans to market FRS radios priced between $100 to $250. Id. at n. 15.]
[FN 11: Comments of ALLTEL Mobile Communications, Inc. at 2, Motorola at 6.]
[FN 12: Comments of ALLTEL Mobile Communications, Inc. at 2.]
[FN 13: Comments of Cobra Electronics Corp. at 1.]
[FN 14: Comments of Tandy at 1-2.]
[FN 15: Comments of Tandy Corporation at 1-2.]
[FN 16: Notice at para. 8.]
[FN 17: These channels are available to any GMRS system licensed to an individual and may be used for low power (5 watts) base or mobile simplex operation.]
[FN 18: Comments of TIA at 1, Tandy Corporation at 2.]
[FN 19: Comments of Cobra at 1, Michael T. McKenna at 1-2.]
[FN 20: See, for example. comment of Alton G. Silver at 2, Susan L. Feit at 3, Personal Radio Steering Group, Inc. at 1-2.]
[FN 21: See, for example, comments of Clifford L. Flaharty at 1, Teri Forrester at 1, Stephen G. Berk at 1, Victor L. Louie at 1, Douglas County REACT Team No. C-0663.]
[FN 22: See, for example. comment of Carolyn Kasper at 1, James P. Robeson at 1, Douglas County REACT Team No. C-0663 at 1.]
[FN 23: Comments of Susan L. Feit at 2.]
[FN 24: Comments of EIA at 1.]
[FN 25: Comments of SpaceLabs at 2-6.]
[FN 26: The specific channels are listed in new Section 95.627.]
[FN 27: On March 14. 1996, our licensing records showed there were 13,620 GMRS systems.]
[FN 28: Capture effect is the phenomenon whereby the strongest signal received on a frequency is the only signal that is demodulated by a FM receiver tuned to that frequency.]
[FN 29: See paragraph 13, infra.]
[FN 30: See proposed Sections 95.627(b) and 95.635.]
[FN 31: Comments of ALLTEL Mobile Communications, Inc. at 2.]
[FN 32: Comments of the Consumer Electronics Group of the Electronics Industry Association at 2, Cobra Electronics Corp. at 2, and Uniden America Corporation at 4.]
[FN 33: Comments of Motorola at 9.]
[FN 34: Comments of Motorola at 8.]
[FN 35: Comments of Motorola at 9.]
[FN 36: Selective calling is a feature that allows a user to hear only communications that are addressed to his or her station. Selective calling enables a user to receive messages without having to also monitor all other communications on the channel.]
[FN 37: Comments of EIA at 2, Cobra at 2, Uniden at 4, and Motorola at 9.]
[FN 38: Comments of PRSG at 9.]
[FN 39: Notice at 9.]
[FN 40: Section 307(e) of the Communications Act of 1934, as amended, 47 U.S.C. 307(e), provides that the term "citizens band radio service" shall have the meaning given it by the Commission by rule, and that the Commission may by rule authorize the operation of such radio stations without an individual license.]
[FN 41: The proposed rules cover eligibility and responsibility, authorized locations, types of communications, and equipment requirements.]
[FN 42: Comments of Motorola at 6-7.]
[FN 43: Comments of Motorola at 6-7. Under our existing rules, the application fee for a new GMRS license, and renewal of the license every five years, is $60.]
[FN 44: Comments of Motorola at 7.]
[FN 45: Comments of Tandy Corporation at 1-2. Tandy states it plans to market FRS radio in the $100-$150 range.]
[FN 46: Comments of PRSG at 10.]
[FN 47: Comments of Tandy Corporation at 4, The National Emergency Number Association at 1, Cobra Electronics Corp. at 1, Motorola at 9, Uniden America Corporation at 4, and Pacific Bell Mobile Services at 1-2.]
[FN 48: Comments of PRSG at 12.]
[FN 49: Comments of the Consumer Electronics Group of the Electronics Industry Association at 4.]
[FN 50: See Amendment of Parts 1 and 95 of the Commission's Rules to Eliminate Individual Station Licenses in the Radio Control (R/C) Radio Service and the Citizens Band (CB) Radio Service, PR Docket No. 82-799, Report and Order, 48 Fed. Reg. 24884 (1983).]