Line A and C Inquiry and Update from the FCC

[WRYC373]

I sent an email recently asking for the basis of the line a restriction. Not due to my doubting of its validity but from curiosity due to Canada now using the frequencies listed as prohibited for their GMRS service and to see if the fcc had plans or if it was just a relic on the license.

 

Dear FCC OMR,

I am inquiring as to a discrepancy in the license provided for General Mobile Radio Service, Title 47 Part 95 Subpart E. Line A is mentioned on the license issued for GMRS prohibiting certain frequencies and I am curious as to the current code reference for that text as quoted:

"Exception: Licensees who operate North of Line A and East of Line C may not operate on channels 462.650 MHZ, 467.650 MHZ, 462.700 MHZ and 467.700 MHZ unless your previous license authorized such operations."                  

I was unable to find any code in the current eCFR Title 47 Part 95 that this exception refers to. Although I am aware of similar restrictions existing in Part 97 and Part 90 regarding other radio services but neither of those contain code that reflects a range that includes the frequencies referred to in the GMRS license restriction. 

Is there a current code reference that could be provided for that restriction? "

 

 

I got a very nice email from the FCC in response.

 

"Good Afternoon,

This email is in response to your inquiry below.  When you applied for your GMRS license in the Universal Licensing System (ULS), the application process required that you certify that you would not use the channels below when operating above Line A or East of Line C (see the snippet below from the reference copy of your application).  This requirement was originally put in place due to incompatible uses in Canada.  95.309 provides that the operator of a personal radio service station may be subject to operating restrictions if the station is to be operated in certain locations described in the rules.

We are evaluating if this restriction is still necessary based on Canada’s current usage of the channels.  With that said, your license is currently conditioned to restrict use of these channels North of Line A and East of Line C so you may not operate on the channels in these areas as long as your license is conditioned with this restriction.

I hope that this helpful

Joshua Smith

Assistant Division Chief

Mobility Division

Wireless Telecommunications Bureau

"

 

I think the important part here is that they are reviewing the current restrictions. Which gives me hope for a potential laxing of that rule. But for now Line A/C restrictions remain.

[tweiss3]

That's an interesting response. Expect any change to take decades. The US is still bound by international agreement with Canada, anything above line C, exceeding 5 watts ERP, must be coordinated with Canada, regardless of FCC "service" (industrial/business, public safety or federal) or end user. Page 10, item 4 (a): https://transition.fcc.gov/ib/sand/agree/files/can-nb/above30.pdf

This is why there is a Line C comment on itinerant business licenses over 5W stating "Location X Special Condition: Area of operation is restricted to south of Line A and/or west of Line C" and the note on itinerant business licenses of 5W or less stating "Operation on this frequency is on a non-interference basis to Canadian operations and you must accept all interference from operations in Canada. Licensee is responsible for resolving any complaint of interference to Canadian systems arising form operations on this frequency, including, if necessary, cessation of such operations."

After discussions with the FCC, it's a Catch 22, because itinerant cannot and are not coordinated by definition, thus you are stuck with the restrictions. This is the same with GMRS, without revision to the previously coordinated 50W channels, or reduction of the allowable power to 5W, we are stuck with Line A & C. I can wish it would be changed, I don't see it happening. It does beg the question of why those 2/4 frequencies were not previously coordinated, as well as the itinerant frequencies, but the Government rarely makes sense.

[WRYS709]

2 hours ago, WRYC373 said:

I sent an email recently asking for the basis of the line a restriction. Not due to my doubting of its validity but from curiosity due to Canada now using the frequencies listed as prohibited for their GMRS service and to see if the fcc had plans or if it was just a relic on the license...

Why would a GMRS user in Utah care?

[RayDiddio]

6 minutes ago, WRYS709 said:

Why would a GMRS user in Utah care?

Considering Line A and East of Line C result in a geographic disparity, you ask a good and relevant question.

[marcspaz]

And how come the lines aren't in order? As you go north, it's A,B,D,C instead of A,B,C,D. I mean, the real question is how can we trust they made good decisions when they got the order of the alphabet wrong?

[RayDiddio]

44 minutes ago, marcspaz said:

And how come the lines aren't in order? As you go north, it's A,B,D,C instead of A,B,C,D. I mean, the real question is how can we trust they made good decisions when they got the order of the alphabet wrong?

Hmm... that really is a head scratcher, eh?

I will chalk it up to that magical and mythical "Government Efficiency" thing I always hear about.

[SteveShannon]

1 hour ago, RayDiddio said:

Considering Line A and East of Line C result in a geographic disparity, you ask a good and relevant question.
 

Not really. We’re allowed to operate West of Line C which is in Alaska, or South of Line A which is in the continental United States. 

[WRYC373]

2 hours ago, RayDiddio said:

 

Wrong quote

Edited October 11 by WRYC373

[WRYC373]

2 hours ago, WRYS709 said:

Why would a GMRS user in Utah care?

It came up during discussions of people I know who live above Line A who asked me and so I asked the FCC. I also was curious and I read through a couple of related treaties and regulations on the origin of those lines. Its relatively interesting. It got to the point where I was like I really want to see the code reference here. It had nothing to do with questioning the rule more to do with where does this rule still live.

[SteveShannon]

33 minutes ago, WRYC373 said:

It came up during discussions of people I know who live above Line A who asked me and so I asked the FCC. I also was curious and I read through a couple of related treaties and regulations on the origin of those lines. Its relatively interesting. It got to the point where I was like I really want to see the code reference here. It had nothing to do with questioning the rule more to do with where does this rule still live.

https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-2

[RayDiddio]

2 hours ago, SteveShannon said:

Not really. We’re allowed to operate West of Line C which is in Alaska, or South of Line A which is in the continental United States. 

Utah is nowhere near those lines, so it was pretty relevant. But the question was about East of Line C and North of Line A in this case and while you can operate West and all, that isn't relevant to the OP's query.

But why WOULD a Utahan care unless they are traveling in which case they have no chance of violating that rule? They normally shouldn't unless special circumstances.

It's always good to know the rules anyway and to get clarification if questions arise surrounding said rules (such as with the OP), but unless leaving Utah to go near Canalaska way, they can't physically violate the rule. To me, relevant. To you? I guess not.

[SteveShannon]

13 minutes ago, RayDiddio said:

Utah is nowhere near those lines, so it was pretty relevant. But the question was about East of Line C and North of Line A in this case and while you can operate West and all, that isn't relevant to the OP's query.

But why WOULD a Utahan care unless they are traveling in which case they have no chance of violating that rule? They normally shouldn't unless special circumstances.

It's always good to know the rules anyway and to get clarification if questions arise surrounding said rules (such as with the OP), but unless leaving Utah to go near Canalaska way, they can't physically violate the rule. To me, relevant. To you? I guess not.

No, I’m saying they don’t result in a geographic disparity. I agree that to a person far from either line the rule is irrelevant. Unless they travel

[WRYC373]

2 hours ago, RayDiddio said:

Utah is nowhere near those lines, so it was pretty relevant. But the question was about East of Line C and North of Line A in this case and while you can operate West and all, that isn't relevant to the OP's query.

But why WOULD a Utahan care unless they are traveling in which case they have no chance of violating that rule? They normally shouldn't unless special circumstances.

It's always good to know the rules anyway and to get clarification if questions arise surrounding said rules (such as with the OP), but unless leaving Utah to go near Canalaska way, they can't physically violate the rule. To me, relevant. To you? I guess not.

I do actually travel. Idaho isn't that far away and parts are above Line A. Also like I said I know people who this issue does affect who had questions about it. I investigated a little and saw the document @SteveShannon linked to which references the "above 25MHz treaty" which originally establishes the Radio Border lines.

The 2 specific GMRS frequency pairs are kind of orphans created by 60 years of rule making by 2 countries somewhat independently. And while in effect the prohibition no longer serves the purpose it once did. There is verbiage in that treaty about shared services and it alludes to one party changed the use/restriction of frequencies the other may as well. So it's possible the FCC is internally looking at that specifically. But yes it is likely it will be years before we see any potential changes.

It was kinda a cool look for me into how regulations change and develop. I deal with interpreting regulations for a living and I find it interesting to talk to different regulatory bodies on how they write and interpret regulations. And that can be especially difficult when the world changes faster than regulations can.

[amaff]

15 hours ago, WRYS709 said:

Why would a GMRS user in Utah care?

Yes, why would anyone ever be curious to learn more about something that doesn't directly affect them in obvious ways anyone can see from the outside?

 

Their profile could say "Texas" and it'd still be a valid question...

[tweiss3]

The real reason is because we agreed in the 50s that Canada can do whatever they want and we can't interfere. 

I know people in the industry that had to replace aging towers by building a new one 50' to the side, when updating the coordination Canada said "we now have a system on that frequency, too bad so sad" even this previous tower/coordination had been there for 30 years prior. Wrecked the project a good 12 months for re-coordination.

I applaud the question and inquiry. It's always good to learn more. It took me a good 3 months after pouring though the Part 90 regs and all it's references, and coming up empty handed, before I found that agreement where it's pretty much buried that there is a 5W ERP limit before Canada gets a say. 

I think it was 2 years ago, I posed the question on a amateur radio net I was running, who knew what Lines A & C were, where they were located, and how it affects amateur radio. The answers were all "what are Lines A & C". It was sad, considering the area of the net is pretty squarely centered on Line A. Hint, look up information about the 70CM band (Part 97.303).

[WRXB215]

The letters issue kind of reminds me of the way the letters in the Ionosphere regions came to be. Maybe the lines just evolved over time in a similar fashion.

[WRXB215]

54 minutes ago, amaff said:

Their profile could say "Texas" and it'd still be a valid question...

Smile when you say "Texas" 

[Lscott]

23 minutes ago, tweiss3 said:

applaud the question and inquiry. It's always good to learn more. It took me a good 3 months after pouring though the Part 90 regs and all it's references, and coming up empty handed, before I found that agreement where it's pretty much buried that there is a 5W ERP limit before Canada gets a say. 

I remember that. It was buried in a really obscure part of the regulations. That was why the FCC bounced your application for some of the business itinerant frequencies you wanted.

[WRUU653]

I can’t help but see the irony of someone in Southern California who is reading a thread clearly labeled about line A and C which they themselves are no where near questioning why someone in Utah cares about line A and C.
 

Why would you want know things? Why wouldn’t you?

[Lscott]

15 minutes ago, WRUU653 said:

I can’t help but see the irony of someone in Southern California who is reading a thread clearly

Same could be said about somebody here in Michigan, where I'm at, and don't give a crap about earthquakes, mud slides and forest fires there.

[amaff]

1 hour ago, WRXB215 said:

Smile when you say "Texas" 

[WRUU653]

2 hours ago, Lscott said:

Same could be said about somebody here in Michigan, where I'm at, and don't give a crap about earthquakes, mud slides and forest fires there.

My point was not that someone shouldn’t care but that they are free to care and be interested in what they want. I’m not sure you understood where I was coming from.  Perhaps I don’t understand your point. 
 

My father is from Michigan for what it’s worth. 

[Lscott]

18 minutes ago, WRUU653 said:

My point was not that someone shouldn’t care but that they are free to care and be interested in what they want. I’m not sure you understood where I was coming from.  Perhaps I don’t understand your point. 
 

My father is from Michigan for what it’s worth. 

OK, I get it. It's just too easy to be disinterested in something you don't have a personal stake in was what I was trying to convey.

I was being a bit overboard in my comment.

[WRYS709]

4 hours ago, amaff said:

Yes, why would anyone ever be curious to learn more about something that doesn't directly affect them in obvious ways anyone can see from the outside?

 

Their profile could say "Texas" and it'd still be a valid question...

I was not taking "shots" at Utah residents, as your snarky reply implies.

I was genuinely curious why the OP cared enough to write the FCC and indeed, THAT can still be a valid question!

[amaff]

5 hours ago, WRYS709 said:

I was not taking "shots" at Utah residents, as your snarky reply implies.

It definitely doesn't. At least, not intentionally (and I'm struggling to see how it could be read that way).

5 hours ago, WRYS709 said:

I was genuinely curious why the OP cared enough to write the FCC and indeed, THAT can still be a valid question!

THAT is the part I was being snarky about. Wondering why someone would be curious about a thing is...certainly a position to take. People are allowed to be curious for curiosity's sake. My point was be they from Utah, Texas, or Florida, or Idaho, it's a reasonable thing for *any* licensed operator to ask the FCC, if they want more information on it.