There is only one day left to post YOUR comments on this critical item. Only 6 so far have commented in dissent. You can make an express comment filing if you wish . I did, and mine was wordy.
My old boss had a saying about allowing a camel to put his nose in the tent. Eventually you have the whole camel in your tent. Midland is interested only in maximizing sales of product, not protecting the GMRS service. You might like their product, fine, but Midland wants to distort the rules to sell product, without any regard to the technology that has existed since the inception of GMRS many decades ago. Point of fact, they have no problem ignoring that GMRS is a wide band 16K0F3E emission and sell radios that are narrow band and are reduced in performance. They did some trickery on one already certified radio model and claimed it could be made wide band via software. If so, it would be illegal to do so. So far I have no evidence that the software slipped out the back door, actually works. That is the company Midland.
1) More digital noises on the channels will become very annoying. I can tell you from experience, that the rodger beeps from FRS radios at the national parks will drive you nuts. Now with 50 watts and persistent GPS locations from 5 or 10 ATV's and voice communications will be impossible. Yes you can use PL but, if you are in the wilderness, sometimes it can be a safety net to listen in CSQ. Midland can do all this SMS messaging and geolocation on 900 MHz ISM band like their competition in this space. They can have mesh networking as well and extend the footprint substantially.
2) A digital voice option in GMRS would be great. However Midland describes a 4:1 TDMA solution that will not work in simplex which is 99% of their market. They are apparently un-knowledgeable about this and have thrown it in for arguments sake. If Midland were to develop such a product, it would not be a standard like P25 or DMR, it would be proprietary and incompatible with everyone else (Like Yaesu C4FM Fusion). If the radios are strictly digital, there would be no interoperability with existing FM wide band radios. Good luck on calling for help with your radios as you hear only digital voice. Midland can also do this on 900 MHz ISM band like Motorola DTR. There would need to be no FCC rule changes as ISM rules are very flexible.
None of what Midland has proposed should be approved. Especially adding digital data to high power radios. If a digital voice option is to be considered, it should be described by the user community and should be a recognized standard like DMR and should have FM wide band mode as a primary mode of operation for interoperability with existing radio population. Frankly, a blanket approval of part 90 DMR radios, would be sufficient. But Midland wants more than that as a proprietary option will be cheaper to make and will lock in users to their crappy brand.
Please dissent on Midlands entire proposal and do so quickly. An Express Comment is fine. Just Say No to bad engineering.
https://www.fcc.gov/ecfs/search/docket-detail/RM-11970