New FCC Action: Petition for Reconsideration filed by Motorola

[rdunajewski]

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.gov/file/10928247080350/Ready%20For%20Filing_Motorola%20Part%2095%20Petition%20for%20Recon.pdf

Further Comments from Motorola from January 2018: https://ecfsapi.fcc.gov/file/101081822912433/Motorola_Part%2095%20Recon_Further%20Comments.pdf

Letter from Motorola Detailing their Discussion with Members of the FCC from April 2018: https://ecfsapi.fcc.gov/file/10420845023222/April%202018_GMRS_FRS_ex%20parte%20notification.docx

 

[JohnE]

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

[rdunajewski]

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/ecfs/search/filings?sort=date_disseminated,DESC&proceedings_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?

[JohnE]

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.

[WRAK968]

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.

[rdunajewski]

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

 

https://ecfsapi.fcc.gov/file/1060628686973/FCC-Letter-2018-06-06.pdf

 

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

[JohnE]

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

[ihcollector]

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

[rdunajewski]

Here is our reply in the Docket, posted today:

 

https://ecfsapi.fcc.gov/file/1061939433150/FCC%20Comment-MSI.pdf

[intermod]

The Northern California GMRS Users Group (NCGUG) has filed our comments (generally supporting mygmrs/RepeaterFinder, LLC), adding a few more considerations.  

 

https://www.fcc.gov/ecfs/filing/10716026430701

 

Thanks to Rich for staying on top of this (10-119 has been open so long we got board and lost track of it...).       

 

Greg

KAF1291

[ULTRA2]

It's already September any further update on this? I apologize ahead of time if the results already posted.

[Ian]

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

 

This is already permitted; see the Garmin Ring for more details.  This is only an expansion to GMRS channels.

 

 

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.

 

Speaking of the Garmin Rino, enough people are willing to shell out $650 for an FRS radio that it's still in production a decade later, and with ever more smartphone-like hardware.  Hams use APRS, which has grown from a simple "amateur position reporting system" into a full-fledged tactical network (their words, not mine) which allow passing of email, instant message, position and status information…

 

I don't have any use for it, as nobody I communicate with has a ham ticket.  However, an in-dash GPS navigator / GMRS radio (god willing, GMRS repeater, too) would be amazing, especially if it was aware of repeater coverage circles and could seamlessly and automagically switch to simplex (one less thing to worry about).

 

A momentary tangent into commercial land-mobile radio and fleet management - they pay thousands of dollars to use satellite to pass quick voice messages and location and status of their vehicles in real time.  Clearly there's a use case, but mere mortals can't afford to find out if it suits them.

 

I'd like to be able to have a combination of turn-by-turn directions, and semi real-time GPS coordinate updates when I'm driving with someone else.  And geolocation bursts over GMRS are a perfect opportunity to unseat Garmin's Rino protocol in favor of APRS; this will allow other vendors to compete in that market and help drive prices down.  Furthermore, (knock on wood…) calling for help will include machine-readable GPS coordinates, which will direct help quickly and efficiently to the location of someone in jeopardy instead of requiring the organization of a search party or a helicopter with a thermal camera.

 

I'm even open to data bursts on repeater inputs, though with more trepidation - perhaps limiting them to manual triggering would be a good first step.  Or another option would be to offer cheap repeater controllers with multiple tones; data would be transmitted with one PL code embedded in a sub-audible signal -- Dakota Alert embeds triggering data for their MURS driveway alarms by modulating the CTCSS tone -- and a different PL code for analog voice, allowing a repeater to silently pass data without interrupting users of legacy hardware with the modem howl of modulated data.

 

Another possibility is silent slow data, and the use of the whole audio spectrum for loud fast data, embedding a callsign into an opening tone and a GPS coordinate into the roger beep?  I've done similar things with an Anytone I bought before their certification was pulled.  The preamble and Roger beep would embed the name of the user in such a fashion that compatible receivers would display their name or callsign on their display while they were talking.  It sounded like a cross between birdsong and modem sounds, and was perhaps an unpleasant roger beep to listen to, but it took no longer to transmit and was no more intrusive than one.

[WRBL507]

I personally use a portable GMRS radios when i go camping and hiking with my family. I also use a small portable repeater with my RV. 40-50 watts on a nice 20’ mast. I get decent range with it.

 

I love the idea of location info sent from one unit to the other automatically. That way i can see where my family is at any given moment. It saves alot of “air” time getting this information.

 

For those of you who are hams. This amounts to a very similar system that hams use called APRS. These are also short automatica bursts, usually under 2 secons. Messages are limited in size.

 

Having this informatio. Saves “air” time because to convey that information verbally would take much longwr.

 

I dont agree with mygmrs.com’s opinion and reaponse to the FCC.

 

Garmin Rhino series gps/radios have this capibility all ready. However it is not automatic.

 

The Garmin units only send the information when manually told to do so, or at the start of every manual verbal transmission.

 

However....

 

It should be a feature that has On/off:manual capibilities.

 

The bursts should be at inaudible levels like it is with the Garmin units.

 

Full power shoild be allowed and on repeater frequencies.

 

I do agree that these location bursts should be limited to no more then 1 per every 2 min. Or unless manually polled or sent.

 

I do agree they should have the feature to pause sending if the channel is busy.

 

Text messages should never be sent automatically and only sent manually.

 

The Garmin system works well. Text messages are only sent manually, and location informatjon is only sent when a transmission is made, or when manually polled or sent.

 

I would like to see more compition in this field as currently i am not aware of any combination gps/gmrs radio combinations other then Garmin.

[JLeikhim]

Is this proceeding still open? Any resolution. It worries me when Motorola asks for something. There is usually some over reach. Having 30 of those GPS gadgets on a channel at a national park will be a mess. And yes, at bubble pack prices, folks will be attaching them to their cars and motorcycles as a poor mans lojack.