intermod

Are you thinking we want to implement DMR because we want to use digital?   The San Francisco/Sacramento region is heavily congested and interference among repeaters is increasing.   There is no practical solution using the same amount of spectrum unless you move to digital technologies.   
You are also trying to compare apples to oranges.  GMRS is a more attractive solution to the majority of people because their priority is communication as opposed to technical pursuits.  Here in California, CERT, neighborhood or fire watch, militia groups, etc. have implemented GMRS because 80-90% of their members have no direct interest in the technical aspects of amateur radio.
 

Lots of it going on.  I have not identified that one rule...maybe I will dig around.   The Commission routinely grants licensees requests to split the channel down the middle and licenses them to separate entities.   Presumably they have waived that particular restriction.  
G 

Bingo...

Totally agree.   These remain like gold, but we have been using them for trunked control channels, and then combine them with Part 90 channels, where we cannot attain FB8 status.
The Part 22 channels are wideband (like GMRS) and can support two DMR channels like I proposed on the original post.   
I am also experimenting with placing three DMR channels in one Part 22 (-6.25 kHz, Center, + 6.25 kHz), with geographic separation between any 6.25 kHz adjacent channels. 

We also have some idle ones in our area I contacted the FCC a month ago to see how one might licenses them.   An attorney confirmed that an auction is required.  And none are currently planned. 

I cannot disagree completely. 
In general, most all of the amateur systems sound on the edge of garbally, shrill, or muffled (Brandmeister)
Our GMRS DMR repeater can also sound this way, but it depends on the transmitting user's radio quality.
The utility DMR systems sound just fine and the vast majority of users like it - even the older employees. 
 
After working on many DMR systems, my confident conclusion is:   
 - DMR audio can become quite good depending on the manufacturers microphone selection, audio processing on both TX and RX sides; and
 - Using the the same radio manufacturer throughout the network; and
 - The tonality of the speakers voice (some voices sound better on DMR than others; its also biased against females)
 - The RX speakers make no difference.  
The best I ever heard was when a $1500 David-Clarke headset was used with an XPR7550 portable radio.  Equal or better than a strong wideband analog signal - and I am quite picky.  This configuration met all the above conditions, however.

Yet I never said I could squeeze in four .  
Strangely, I think we are in agreement here, however.   
Just one example.  There channels in the VHF and UHF commercial bands remain 25 kHz wide like GMRS (see 152.72 MHz, 454.350 MHz, etc.).  These are under FCC Part 22, not Part 90.  Within the 454.350 channel we placed one DMR signal 6.25 kHz below and one 6.25 kHz above the center at 454.350.   So that provides for four simultaneous conversation paths (four slots).   
I am currently experimenting with placing a third DMR signal centered on 454.350 MHz, but geographically separated from the other two to limit adjacent channel interference.  So far this is working great as long as the separation is adequate.  

GMRS is quiet much of the time here as well, other than the simplex traffic from business, or when there are major fires.  The "congestion" issue I mention is related to time-of-use.  Our groups, and those on other repeaters on the same channel, often want to use their systems at the same time.  Due to the terrain here, our portable radio users can get stepped on from users of other systems operating mobile or control stations at high-elevations, even 80 miles away.                    

Agree - it really has to work this way. 

It's rather unreasonable to expect any service to remain static. Analog TV has gone basically extinct, 11M CB now has analog FM, auto manufactures are trying to eliminate AM radios in cars, the FM PMR446 license free service in the EU now allows two types of digital voice modes and so it goes.  
GMRS was limited in the number of channels it could use and the changes in 2017 added more, and a few headaches. It's going to change again. It's not a question of IF but WHEN and what those changes will look like. Some of the proposals here have little to no chance of happening while some do have merit.
If GMRS doesn't evolve it will just be another dinosaur looking for the nearest tar pit.

The eight current GMRS channels can handle eight simultaneous conversations today (in the same area).  The proposal below would allow for 32 simultaneous conversations without expanding the GMRS service.
For those not familiar with DMR technology, each DMR repeater signal has two "timeslots" which allows for two independent talk channels.  Two DMR signals can fit within the same space as one analog FM signal today.  This is possible because a DMR signal only requires about 7.6 kHz of spectrum, while todays wideband analog signals need 20 kHz of spectrum.
Thus, four conversations can be supported within each of the current GMRS channels. 
The center frequency of each DMR repeater (and the radios it supports) would be programmed 5 kHz above or below the current center channel.   +/-12.5 kHz might also be used.   
Below shows how this would work in reality. 

The FCC would not need to allocate new radio spectrum.  They only have to allow more efficient use of what we already have.
The other benefit of DMR is that two different repeater groups could invest in one DMR repeater, which splits the cost in two while each maintains their own "channel".   As a DMR repeater takes the same rack space as an analog repeater and only requires one antenna, the repeater site lease costs could be split between the two groups as well.
It would take the FCC some time to accomplish this, so if they started now, they might be able to complete this rule change in 2024.
 

Sorry that you have been triggered.  I have more quotes if you need them.  How much money do you have?

My wording could have been better.  My main point was that, when the FCC permits repeaters in a shared service, repeater users cannot always protect simplex users from interference (IX).  So when you are planning a repeater, digital or otherwise, while I try and work around a local simplex group that call a certain channel home, eliminating interference is not always possible.   Thus, simplex users cannot expect interference-free operation (except intentional IX).   

This is a interesting paper.   Particularly for our current conversation:
"...First let us look at the currently authorized emissions for GMRS. Looking in 47 CFR Subpart E
95.1771 we find some surprising, authorized voice emission modes, A3E, H3E, J3E and R3E. All of
these are several types of voice amplitude modulation, Single/Double Sideband with suppressed or
reduced carrier etc. None of these official modes are compatible with the FM mode! Why isn’t the FCC
worried about interoperability between FM and these modes?..."
Was this ever submitted to anyone at the FCC (officially or otherwise?)
 

Are you thinking we want to implement DMR because we want to use digital?   The San Francisco/Sacramento region is heavily congested and interference among repeaters is increasing.   There is no practical solution using the same amount of spectrum unless you move to digital technologies.   
You are also trying to compare apples to oranges.  GMRS is a more attractive solution to the majority of people because their priority is communication as opposed to technical pursuits.  Here in California, CERT, neighborhood or fire watch, militia groups, etc. have implemented GMRS because 80-90% of their members have no direct interest in the technical aspects of amateur radio.
 

The eight current GMRS channels can handle eight simultaneous conversations today (in the same area).  The proposal below would allow for 32 simultaneous conversations without expanding the GMRS service.
For those not familiar with DMR technology, each DMR repeater signal has two "timeslots" which allows for two independent talk channels.  Two DMR signals can fit within the same space as one analog FM signal today.  This is possible because a DMR signal only requires about 7.6 kHz of spectrum, while todays wideband analog signals need 20 kHz of spectrum.
Thus, four conversations can be supported within each of the current GMRS channels. 
The center frequency of each DMR repeater (and the radios it supports) would be programmed 5 kHz above or below the current center channel.   +/-12.5 kHz might also be used.   
Below shows how this would work in reality. 

The FCC would not need to allocate new radio spectrum.  They only have to allow more efficient use of what we already have.
The other benefit of DMR is that two different repeater groups could invest in one DMR repeater, which splits the cost in two while each maintains their own "channel".   As a DMR repeater takes the same rack space as an analog repeater and only requires one antenna, the repeater site lease costs could be split between the two groups as well.
It would take the FCC some time to accomplish this, so if they started now, they might be able to complete this rule change in 2024.
 

4K0 dPMR is definitely much easier to fit in.   Even having several high elevation repeaters, I would not have any issue with 4K0 stations 12.5 kHz away from my inputs.   Even high power mobiles.  I likely get more interference from the narrowband analog radios there now, especially when they are within a few miles of the repeater.    The commercial frequency coordination standards originally allowed new 4K0 stations to be installed 12.5 kHz away from 20K0 (or like you mention 16K0) without getting any approval from the wideband users - even at the same repeater site.  So this is well established.   But that was also with tighter frequency stability standards.  
Maybe this is the first step to obtain acceptance of digital modes.   

Was her name Karen?

The eight current GMRS channels can handle eight simultaneous conversations today (in the same area).  The proposal below would allow for 32 simultaneous conversations without expanding the GMRS service.
For those not familiar with DMR technology, each DMR repeater signal has two "timeslots" which allows for two independent talk channels.  Two DMR signals can fit within the same space as one analog FM signal today.  This is possible because a DMR signal only requires about 7.6 kHz of spectrum, while todays wideband analog signals need 20 kHz of spectrum.
Thus, four conversations can be supported within each of the current GMRS channels. 
The center frequency of each DMR repeater (and the radios it supports) would be programmed 5 kHz above or below the current center channel.   +/-12.5 kHz might also be used.   
Below shows how this would work in reality. 

The FCC would not need to allocate new radio spectrum.  They only have to allow more efficient use of what we already have.
The other benefit of DMR is that two different repeater groups could invest in one DMR repeater, which splits the cost in two while each maintains their own "channel".   As a DMR repeater takes the same rack space as an analog repeater and only requires one antenna, the repeater site lease costs could be split between the two groups as well.
It would take the FCC some time to accomplish this, so if they started now, they might be able to complete this rule change in 2024.
 

I assumed he would eventually figure this out.   He seems a bit challenged.  

I assumed he would eventually figure this out.   He seems a bit challenged.  

I think what "Motorola figured out" is that once the users perceive that DMR operates the same as P25, and the system administrators discover that DMR is about 30% the cost and they get twice the channel capacity and more features than P25, they will no longer purchase expensive P25 hardware.   Its a marketing decision by Motorola, that just happens to also be good for maintaining interoperability.   Its the same game played by politicians. 
I agree with your comment on interop, except that 95% of the time, the locals can't talk to other locals or the feds anyway, either because they are on different bands (locals cannot afford multiband radios), or the Fed did not, or refuse to share their encryption keys.  Of they fail to program in each others frequencies.  An normally is bad practice to change channel to another system because your commanders need you on your normal channels.  
If DMR had a profit margins that P25 does, Moto would just come up with an excuse to promote that technology instead - and so would the politicians. 
It has noting to do with co-channel interference related to DMR - this is fake news (likely by Moto or Kenwood).  DMR, P25, NXDN will all be similar at the co-channel distances we are talking about (DMR is noisier than most when strong, but they would not license someone that close).  Frequency Coordinators assign co-channel stations based on carrier-to-interference ratios, and the modulation is not even a consideration, except when they look at adjacent-channel separation.  Then they still don't care if its P25, NXDN, DMR, etc. - they only look at the bandwidth of the signal which is the first three of four digital in the emission designator.   
But I may be wrong. 

If you are currently operating one of these technologies (or other digital) in GMRS repeater operation under a special FCC license please contact me offline.  We are trying to determine how many are out there now and where. 
intermod@sngf.org
Northern California GMRS Users Group (NCGUG)
 

If you are currently operating one of these technologies (or other digital) in GMRS repeater operation under a special FCC license please contact me offline.  We are trying to determine how many are out there now and where. 
intermod@sngf.org
Northern California GMRS Users Group (NCGUG)
 

Here in the San Francisco Bay and Sacramento regions we have started hearing a "baby monitor" type devices using GMRS 462 and 467 MHz primary repeater frequencies, in nursing home settings (given the message content).  We are aware of about twenty incidents of this over the past three months, but the rate of occurrence is rising.  The most recent was strong enough to interfere with a CERT/Fire Council repeater out here. 
 
These typically operate during daylight periods, and appear to be continuously keyed for up to 12-16 hours at a time, although background noise, such as televisions, could be keeping them transmitting if set for VOX.  They do not have time-out timers enabled.  These change channels occasionally, but usually end up on 462.625, 462.725, 467.625 and 467.725 MHz.   They use a D754 or a D734 DCS code.
 
This kind of device was explicitly mentioned in past FCC GMRS rulings as it was feared that manufacturer's might use these channels for such things.
 
Given most repeaters here in California are on 1500-4000 ft. mountains, continuous destructive interference will occur to our repeater inputs.   
 
I tried to DF the source of one of these last week, but it was found to be in San Francisco and we ran out of time.  SF is a particularly difficult place to do this due to the density, hills and other sources.  Thankfully these are constantly keyed.  The device I was looking for was horizontally polarized, making it about 10-20 dB weaker when received on a vertical vehicle antenna.   A Yagi in horizontal worked best.  
 
My goal was not to go after the user (they don't know better), but instead get a picture of the device, determine its manufacturer and model number, and establish who is selling it.  As these may be used in nursing care facilities, they will likely have to bring the device out to us to be safe. 
 
Please let us know here if you hear these as we are trying to keep a list of the channels and codes in use so we can identify the specific radio model. 
 
This is clearly in violation of §95.1733(a)(10) and §95.1763© for GMRS, and §95.587(3) for FRS.  It also appears to violate §95.533.