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New FCC Action: Petition for Reconsideration filed by Motorola

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#1 WQEJ577

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Posted 05 June 2018 - 02:41 PM

To all GMRS licensees:

 

I have just spoken with the FCC regarding a Petition for Reconsideration filed by Motorola regarding automatic GPS and data transmissions on the GMRS band.

 

Motorola would like to allow automatic transmissions on the 462 MHz frequencies which includes repeater outputs (Channel 15-22) and the interstitial 462 MHz channels (Channels 1-7). The repeater inputs are not presently mentioned, however we will articulate our position to the Commission that these input frequencies should be prohibited due to the potential of interference to repeaters.

 

myGMRS.com (and it's parent company RepeaterFinder, LLC) will be filing an ex parte response in the docket with the following requests:

 

  1. A Busy Channel Lockout (BCL) feature be mandated for any radios which are to operate in an automatic fashion. The devices must inhibit transmission if there is co-channel activity to prevent interference to other users of the shared frequencies. Blind periodic transmissions are going to be very problematic and will almost certainly cause interference.
     
  2. Limit automatic transmission to the 462 MHz GMRS channels only. Repeater inputs must be excluded to mitigate potential interference.
     
  3. Duty cycle limits of the bursts must be set by the FCC. I believe Uniden America proposed no more than once every 2 minutes and no more than 5 seconds per transmission. This sounds reasonable to cover longer text messages and location updates without constantly trashing the band.

 

The FCC plans to respond to Motorola and issue a decision in the next couple of weeks, so anyone who would like to submit comments to the record is encouraged to do so as soon as possible. No exact deadline was given, but they expressed a desire to have this hammered out within the next week or two.

 

I will provide further details later today.

 

Original Petition for Reconsideration from September 2017:  https://ecfsapi.fcc....n for Recon.pdf

Further Comments from Motorola from January 2018: https://ecfsapi.fcc....er Comments.pdf

Letter from Motorola Detailing their Discussion with Members of the FCC from April 2018: https://ecfsapi.fcc....tification.docx

 


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Rich Dunajewski

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#2 JohnE

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Posted 05 June 2018 - 06:49 PM

I get it but it but the public won't. it will just be another "toy" for the kids to play w/.

I personally see it of no use given the limited range at the power levels of these radios. there is no way that they should be allowed on the hi side. as for BCLO I agree and timing at 5 min intervals and 2 sec of data.

just my thoughts

JE


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#3 WQEJ577

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Posted 05 June 2018 - 10:28 PM

The FCC made it clear that they wanted quality comments, not a large quantity. So I don't necessarily want to flood them with comments. I think it would be a good idea for people to only submit a filing to the FCC if they strongly disagree with the position I put forward. No need for everyone to file just to say the same things or to go off the reservation with other issues.

 

Regarding the duration of the data burst -- it really depends what modulation and baudrate they want to go with. If it's low speed, 5 seconds might be reasonable. If it's high speed, 5 seconds may be completely unnecessary. But I also don't want to sit here and argue over numbers. As long as there's some sane limit to the number of these bursts, and most importantly, busy channel lockout, I'm fairly happy.

 

If you do want to file now, the docket is here. Click "+ New Filing" or "+ Express" to get started:

 

https://www.fcc.gov/...ngs_name=10-119

 

Topics the FCC wanted feedback on specifically:

  1. Would automatic data transmissions cause interference with other GMRS operators? How so? (Strong arguments needed)
     
  2. Should these be restricted to certain channels? Why? Motorola seemed okay with avoiding repeater inputs for now, to avoid interference.
     
  3. What should the duty cycle limits be? Proposal so far was no more than every 2 minutes with less than a 5 second burst.
     
  4. What other restrictions might be needed to avoid disruption of other GMRS operators?

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#4 JohnE

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Posted 06 June 2018 - 07:06 PM

agreed, we are splitting hairs on the bursts.

the BCLO is a must and no 467 sided use.

I am also just curious as to what Moto's end game is on this given the range of these units.


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#5 WRAK968

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Posted 07 June 2018 - 08:45 AM

My personal view is that there should be NO automatic data bursts for GPS tracking. I really don't see what constantly transmitting your location would be useful for. I would think that if you do want your GPS location to be transmitted, it could be sent like an ID burst upon pressing the PTT. I believe that by doing this it would not only keep the air clear from constant data chunks being sent, but also extend battery life as the radio wont be auto transmitting for two and a half minutes or receiving & decoding two and a half minutes per radio in use every hour. This allows users to update their location either through check-in or through general conversation and could even be used on a repeater as it only sends the data burst when the user is talking.


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#6 WQEJ577

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Posted 08 June 2018 - 08:54 AM

Here's my letter acknowledging the meeting with the FCC, per their request, to keep a record of the communication:

 

https://ecfsapi.fcc....-2018-06-06.pdf

 

We'll be drafting a reply to the petition shortly.


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#7 JohnE

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Posted 13 June 2018 - 06:48 PM

Rich, quick question on timing.

Once you hit the "auto TX" button as discussed how long a duration are you looking at before it stops. 5sec data every 2min for how long ? 10 min 10 transmissions or till the batteries go dead. like a time out timer.

just thinking out loud.

JE


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#8 ihcollector

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Posted 17 June 2018 - 09:15 PM

If they truly want to do this it should be on the FRS only channels!

30 + years in the 2-way radio industry, sales, service tech, consulting, system design and implementation. Custom installations. Public safety vehicle design & installations.


#9 WQEJ577

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Posted 19 June 2018 - 08:11 PM

Here is our reply in the Docket, posted today:

https://ecfsapi.fcc....Comment-MSI.pdf
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Rich Dunajewski

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