Commenting on the MURS
Petitions for Reconsideration

Editorial Addition [June 28, 2003]:

The discussion below pertains to the initial three Petitions for Reconsideration filed in December 2001. As a result of those Petitions, the FCC amended the MURS Rules effective November 2002. Click here to view the changes that resulted from these three initial Petitions.

In November 2002, PRSG filed a second Petition for Reconsideration covering an additional three issues about which there had been no prior opportunity for public comment. In June 2003, the FCC accepted that Petition and announced a comment period. Click here to view information about this most recent consideration. The remainder of this page concerns the earlier three Petitions.

You can always find the very latest information about MURS by clicking here.

Background:

The Multi-Use Radio Service (MURS) is a new unlicensed, personal-plus-business radio service in the 150 MHz band. It is allocated five specific frequencies formerly available only to licensees in the Business Radio Service. On November 13, 2000, MURS became available for unlicensed use, including for personal and family communications.

Three parties (Motorola, Personal Radio Steering Group [PRSG], and William Easterday) submitted Petitions for Reconsideration in this FCC Docket 98-182 asking the FCC to change or withdraw parts or all of the rules recently adopted for MURS. The public has until January 3, 2001, to submit comments in support of or in opposition to the various requests in these three Petitions.

In particular, the Motorola petition would dramatically reduce the availability of MURS to the public. If you believe instead that the FCC should keep and enhance MURS for the public, you will want to send your comments to the FCC before the deadline.

(For more information about MURS in general, or about the FCC Rules that govern this new VHF Citizens Band service, click here.)

The Motorola Petition:

Motorola wants the five frequencies in MURS preserved solely for business and industrial use. Motorola believes that expanding the use of these frequencies for non-business purposes would degrade the quality of service that business and industrial users expect on these frequencies.

Motorola specifically requested:

1. That MURS be renamed to the "Low Power Business/Industrial Radio Service";

2. That absent a restriction limiting this service solely to business and industrial use, the FCC should reinstate a licensing requirement in the Business Radio Service for operation on these frequencies;

3. That the FCC prohibit the interconnection of these frequencies with the Public Switched Telephone Network (PSTN); and,

4. That the FCC prohibit integrating MURS units with FRS units.

If the FCC were to grant Motorola's radical request that MURS should be restricted only for business and industrial use, personal use would again be prohibited on these frequencies. (Notably in the Report and Order in this docket, the FCC has already established that most users of these frequencies are not licensed, and that there is extensive non-business use of these frequencies.)

A PDF version (requiring Adobe Acrobat Reader) of the Motorola Petition is available for downloading or on-line review.

The PRSG Petition:

PRSG acknowledges that there is an established base of both business and personal users on these five frequencies. We believe that the new rules should encourage a continuation of the current mobile-oriented nature of this service (for mobile-to-mobile and base-to-mobile operations). We also note that business and personal users and uses have long co-existed on these frequencies.

However, we note that the new rules fail to incorporate certain restrictions that existed in the previous rules for the use of these frequencies. We also believe that certain new restrictions are necessary to preserve and protect the current users and predominantly mobile-oriented uses of these frequencies.

The PRSG Petition offers a more moderate and desirable alternative to the complete elimination of MURS for personal use that Motorola requests.

The PRSG Petition requests:

1. That the FCC change from a power limitation based on "effective radiated power" to one based on actual transmitter output power (which is less confusing for the general public to understand);

2. That a maximum limit on transmitter antenna height be imposed;

3. That use of MURS frequencies for mobile relay (repeater) stations be prohibited;

4. That the FCC should consider a more appropriate name for this mobile-oriented but combined personal/business-use radio service;

5. That the technical standards should be further simplified; and,

6. That interconnection with the PSTN should be prohibited.

With only five frequencies available in MURS, PRSG believes that these changes are necessary to protect existing uses and to obtain the most efficient use of this spectrum.

The Easterday Petition:

The Easterday Petition requests that existing Business Radio Service licensees on these MURS frequencies be temporarily "grandfathered" in with the previous BRS technical operating standards, which in some cases are less restrictive than the technical standards imposed under the MURS Rules.

What Should You Say in Your Comments?

The FCC requires certain specific information from parties commenting on petitions.

• At the top of the first page, you must say "Docket 98-182." If you submit your comments in a printed format, we recommend that you repeat this reference at the top of each subsequent page. (Many parties that file comments in the various FCC proceedings using a standard "boilerplate" heading, but it is not necessary for you to do so. Click here to download an example of how this standard heading might look for your comments.)

• You should title your submission, "Comments on Petitions for Reconsideration."

• You must give your name and mailing address. If you are submitting your comments electronically (more about this later), you should also give your E-mail address.

• You must explain what your interest is in this docket. For instance,
  • Are you commenting as a current or potential user of MURS?
  • What FCC licenses do you currently hold?
  • What is your radio operating experience?

• You should then explain your support of or opposition to the points raised in the various petitions for reconsideration.

• You must state that on this date, you have sent a copy (via USPO First Class Mail, via FedEx, or via whatever other means) of your comments to each party about whose petition you have commented. You must include the name and mailing address of each such petitioner. (This is the "service list." More information about this later.) If the petitioner has agreed to accept your comments electronically (as have petitioners Easterday and PRSG), you can note that you have sent them this way instead of in a printed format.

• You must date your comments. If you are submitting them in a printed form. you must also sign your comments.

Your "service list" might be the following:

       "I certify that on this date (January 3, 2001), I have sent a
        copy of these comments to the following parties:

       "Mr.William Easterday
        111 Greenway Drive
        Elyria, OH  44035
        [sent electronically by petitioner's permission to:
         kb8fu@alltel.net]

       "Corwin D. Moore, Jr.
        Personal Radio Steering Group Inc.
        PO Box 2851
        Ann Arbor, MI  48106
        [sent electronically by petitioner's permission to:
         prsg@provide.net]

       "Richard C. Barth, Ph.D.
        Vice President and Director,
        Telecommunications Strategy
        Motorola
        1350 I Street, N.W., Suite 400
        Washington, DC  20005"

(NOTE: In the Motorola address, it is "I" (rhymes with "eye") Street, not "L" Street or "One" Street.)

You need to include in your "service list" only those petitioners about whose petitions you have actually submitted comments (in support or opposition).

Other General Ideas to Remember:

However you comment on the Petitions, there are several things to keep in mind.

• The FCC created MURS to relieve a problem with licensing. The FCC did not set out to create a brand new alternative for personal use, especially for hobby use. Instead, this whole effort was in recognition of the widespread unlicensed use of these frequencies, and in recognition that radios operating on these frequencies have long been marketed for "personal" use.

• There is already a substantial "installed base" of users of these frequencies. The FCC did not intend that any existing users (either business or personal, whether licensed or unlicensed) should be displaced or forced to move to different frequencies in order to continue their present operations. The FCC intends MURS to recognize the substantial number of unlicensed users that already use these frequencies.

• There are already provisions for "hobby-type" operation in other radio services with comparable spectrum. The FCC did not intend MURS to become a hobby-type radio service.

The essence of Motorola's Petition is that MURS could become overrun with hobby-type operations, and force existing users off of these frequencies. PRSG believes that this is an overly "alarmist" viewpoint which overlooks the fact that personal and business users have long co-existed on these frequencies.

How and When to File Your Comments

You may file either written or electronic comments (via E-mail or via file transfer using the Internet).

For printed comments, you must mail or deliver them so that the FCC receives them not later than 7 PM Eastern Standard Time on January 3, 2001. To participate formally in this proceeding, you need to send a signed original and five copies (or a signed original and ten copies if you want each Commissioner to receive his or her own copy).

If you send them by US Mail, you should send them to:

(No further street or office address is necessary.)

If you send them by some carrier other than the US Postal Service, you must send them to:

For electronic comments, you must submit your comments before midnight on January 3, 2001. (That is five hours later than deadline for the FCC's receipt of printed comments.) You need to send only a single electronic copy.

To file your comments electronically, you will need to use the FCC's "Electronic Comment Filing System" (or ECFS). (It's actually quite easy to use!) Go to the FCC's ECFS Web site (at http://www.fcc.gov/e-file/ecfs.html) for further instructions. We recommend that you read over the "ECFS Tips and News" on that page first.

To file your comments, select the first option on that page: "Send a File or Brief Comment Using Your Internet Browser." This is a 2-step process, first to register that you intend to submit a file, then to actually submit that file.

Filings are accepted in Microsoft Word 6.0 or higher, up to and inclusive of Office 97. Filings can also be accepted as straight ASCII file (namely, no formatting commands or high-level ASCII characters). (For instance, the PRSG Petition for Reconsideration was originally submitted as a straight ASCII file.)

There is also an on-line ECFS Users Manual which (if you are really ambitious or curious) you could also download and review.

As you register to submit you comments, under "Proceeding" (Question 1) enter "98-182". Under document type (Question 12), you may select any of three descriptions:

• COMMENT, or
• OPPOSITION TO PETITION FOR RECONSIDERATION, or
• REPLY TO PETITION FOR RECONSIDERATION

Even if you submit your comments electronically, you must still send a printed copy to each petitioner about whose petition you have commented, unless the particular petitioner has agreed to receive your comment electronically. In this docket, Petitioners Easterday and PRSG have agreed to receive your comments electronically. (In other words, if you comment only on the Motorola Petition, you need to send a copy of your comments only to Motorola.)

If you submit your comments electronically, you should also include the E-mail address at which you can receive any reply comments that the petitioners may want to submit for consideration in this docket. When they reply (which they must do not later than January 15, 2001), the petitioners must also send you a copy and must provide a "service list."

If You Have Further Questions:

Send PRSG an E-mail message.