Before the
                     FEDERAL COMMUNICATIONS COMMISSION
                           Washington, DC  20554


In the Matter of                               )
                                               )
Biennial Regulatory Review -- Amendment        )   WT Docket 98-20
of Parts 0, 1, 13, 22, 24, 26, 27, 80, 87,90,  )
95, 97, and 101 of the Commission's Rules      )
to Facilitate the Development and Use of       )
the Universal Licensing System in the          )
Wireless Telecommunications Services           )


                            PETITION FOR STAY


Filed by:    Personal Radio Steering Group, Inc.
             PO Box 2851
             Ann Arbor, Michigan  48106
             (734) 662-4533

    Date:    January 13, 1999



I.  BACKGROUND OF THE COMMENTER.


  The Personal Radio Steering Group, Inc. (PRSG) is an
all-volunteer, not-for-profit Michigan corporation established in
1980 by licensees in the General Mobile Radio Service (GMRS, FCC
Part 95-A) to provide services to and to serve as an advocate for
the GMRS personal-use community.

  The PRSG has published more than 300 different guides to GMRS
licensing, technology and operating practices. PRSG's flagship
publication, the GMRS NATIONAL REPEATER GUIDE, lists the more than
3,500 GMRS repeaters, their sponsors, technical characteristics and
detailed coverage information.  The GUIDE has become the essential
reference to this cooperative, nonprofit communications network for
licensed private individuals.  PRSG also works closely with major
land mobile equipment manufacturers to disseminate instructional
materials for radio purchasers.


II.  BACKGROUND OF THIS DOCKET.


  On December 14, 1998, the Federal Register (volume 63, number 239,
pages 68903 through 68984) published the REPORT AND ORDER adopting
the Final Rule in this Docket.  Within the time period allowed under
Federal Statute, the Petitioner file a PETITION FOR RECONSIDERATION
of this REPORT AND ORDER.


III.  ELIGIBILITY TO PETITION FOR STAY.


  The Petitioner requests that the date of effect of the changes
in the rules pertaining to Part 95, Subpart A, of Title 47 of the
Code of Federal Regulations be stayed until the issues raised in its
PETITION FOR RECONSIDERATION are fully resolved.

  The Petitioner argues that it is eligible to request this stay of
effect because of the following conditions:


1) The Petition is likely to prevail on its merits.


  The Petitioner has identified new rules in the REPORT AND ORDER
that reflect substantial changes in FCC policies that the FCC had
not proposed in the original NOTICE OF PROPOSED RULE MAKING, and
which the FCC therefore adopted improperly because the FCC provided
no opportunity for public comment.

  The Petitioner has also identified new rules in the REPORT AND
ORDER that are in direct contradiction to other established and
confirmed FCC rules and policies.


2) The Petitioner will suffer irreparable harm if a stay is not
granted.


  The corporate Petitioner and the personal author of this PETITION
FOR STAY and the PETITION FOR RECONSIDERATION are licensees in the
General Mobile Radio Service (GMRS).  The corporate Petitioner is
also an advocate for the interests of the GMRS personal-use
community.

  The interests of the corporate Petitioner, of the personal author
of this Petition, and of the GMRS personal-use community for whom
the corporate Petitioner advocates will be harmed if the FCC permits
the adopted rules to go into effect before it gives full
consideration to the issues raised in our PETITION FOR
RECONSIDERATION.  Interference, including interference to
communications pertaining to life- and property-threatening
emergencies, is likely to occur if the FCC allows GMRS licensees to
implement some of the expanded operating capabilities improperly
adopted by or inadvertently permitted under the rules adopted by the
REPORT AND ORDER in this docket.


3) Other interested parties will not be harmed if this PETITION FOR
STAY is granted.


  This Petition requests that the FCC maintain the current STATUS
QUO.  All FCC licensees in the GMRS will continue to be eligible to
exercise fully the operating privileges under their current
licenses, and will suffer no harm to their respective current
operations.


4) The public interest favors a grant of a stay.


  The PETITION FOR RECONSIDERATION requests changes in rules adopted
in the REPORT AND ORDER that are confusing, and that are
contradictory with other rules and with established and confirmed
FCC policies.

  The public interest will benefit from a full resolution of these
issues, conflicts, confusions and contradictions BEFORE the FCC
implements the rules adopted in the REPORT AND ORDER.



                                  Corwin D. Moore, Jr.
                                  Administrative Coordinator
                                  Personal Radio Steering Group Inc.