Fee Waivers

[SteveH]

We have a town EMA in our area that is using FRS bubble pack radios to communicate from the EOC to a warming shelter. Under this EMA's jurisdiction is another warming shelter that cannot be reached using FRS (or at all using this type of radio, regardless of the power setting). GMRS would be a great option. 5 watts should work with a decent antenna.

 

The filing fees rules provides an exemption for "governmental entities:"

 

PART 95 GMRS FEE EXEMPTIONS:
Eligibles filing as Governmental Entities are exempt from fee payment. Additionally, there is no fee required for applications filed with purposes of
Amendment (unless adding call signs, adding waivers, or changing Exemption for the Fee(s) to ‘No’), Administrative Update, Request to Cancel a
License, or a Request for Withdrawal of a Pending Application.

 

In this case, the licensees would have to be the director (a town employee) and several people who may or may not be in the employ of the town but would be working under the direction of the director. Would the exemption also be applicable to them? Or is there another way of working this for an agency?

 

The same situation would arise in the case of SAR teams who use (knowingly or unknowingly) GMRS and other responders.

 

73, Steve

[SteveC7010]

We have a town EMA in our area that is using FRS bubble pack radios to communicate from the EOC to a warming shelter. Under this EMA's jurisdiction is another warming shelter that cannot be reached using FRS (or at all using this type of radio, regardless of the power setting). GMRS would be a great option. 5 watts should work with a decent antenna.

 

The filing fees rules provides an exemption for "governmental entities:"

 

PART 95 GMRS FEE EXEMPTIONS:

Eligibles filing as Governmental Entities are exempt from fee payment. Additionally, there is no fee required for applications filed with purposes of

Amendment (unless adding call signs, adding waivers, or changing Exemption for the Fee(s) to ‘No’), Administrative Update, Request to Cancel a

License, or a Request for Withdrawal of a Pending Application.

 

In this case, the licensees would have to be the director (a town employee) and several people who may or may not be in the employ of the town but would be working under the direction of the director. Would the exemption also be applicable to them? Or is there another way of working this for an agency?

 

The same situation would arise in the case of SAR teams who use (knowingly or unknowingly) GMRS and other responders.

 

73, Steve

 

First, i do not find the language you are quoting in the revised Part 95 subsequent to the R&O which was recently adopted. If you are using a copy of Part 95 older than 2017, it is no longer relevant to the conversation.

 

There is language in there that concerns grandfathered business and governmental entities, but the grandfather clause is for licenses issued prior to sometime in 1987.

 

If you can show us exactly where in the new Part 95 is language resides, perhaps we can continue the discussion. I am pretty sure that most, if not all of us understand and believe that GMRS is now licensed only to individuals,not entities of any kind. Licenses issued to individuals only cover their family members as defined in 95a. In the case of GMRS, It's almost certain that governmental entities and business are simply not eligible for GMRS licenses and have not been for 30 years.

 

The wording about fees that you quote appear to be in regards to station licenses and that generally holds true for Part 90 licenses. Since there are no station licenses now issued in GRMS, whatever fee exemptions that may exist in other services simply don't apply.

[SteveH]

The language is in the current instructions for the GMRS license. Correct, there are currently no new group licenses nor will there be. I'm assuming that the exemption is carried through in the new rules. The question is, given the fee waiver for government entities (I take that as individuals working for the government), can that be applied to individuals (not employees) who support the government agency. For example, could CERT team members get a waiver since they are registered with an agency?

 

One place that this is mentioned is at http://wireless.fcc.gov/feesforms/feeguide/services/generalmobile.pdf

[SteveC7010]

The language is in the current instructions for the GMRS license. Correct, there are currently no new group licenses nor will there be. I'm assuming that the exemption is carried through in the new rules. The question is, given the fee waiver for government entities (I take that as individuals working for the government), can that be applied to individuals (not employees) who support the government agency. For example, could CERT team members get a waiver since they are registered with an agency?

 

One place that this is mentioned is at http://wireless.fcc.gov/feesforms/feeguide/services/generalmobile.pdf

 

I maintain several Part 90 licenses for a local government. The fee waivers are for the agencies themselves, not individuals. That seems to be the general rule of thumb throughout FCC licensing.

 

I worked for several local governments for my entire career, and I never heard of individuals being licensed with fees waived in the manner that you suggest. I am very doubtful that they'd do that for GMRS. The only way to be sure is to ask the FCC directly. Any answer you get on an internet forum would not be reliable. So my single recommendation is to go ask the FCC.

 

Since you raised the question, please remember to tell us what the FCC says. You've raised an interesting question, and I am certain that many of us would like to learn the outcome.

[SteveH]

Yes, time to ask the FCC.

 

On a positive note, after looking at the terrain profile between the EOC and the new warming shelter, I'm willing to (almost) bet that a 5 watt GMRS radio with antenna on the tower can work a 2 watt FRS radio at the shelter. That would considerably simplify things as only a small set of people work at the EOC as opposed to a larger pool that would be working the shelter.

 

Our EOC and shelter in the next town south has a much simpler situation. They are only about 200 yards apart and we use Part 15 wifi data/telephony devices (Village Telco Mesh Potatoes) between them.

 

Our county EMA, like many, has a good stable of FRS/GMRS radios. I'll be there tomorrow and will turn a few on to see what channels and power settings were last used when they were deployed.

 

 

[PastorGary]

Since this is a city government system, why not just license the EMA/EOC with Part 90 equipment?  Using GMRS/FRS  for the purposes stated may not be reliable under some circumstances (interference from civilians)  and may be abused unless everyone using the equipment is individually licensed and trained properly.  I'm sure that someone in City Government already has an FRN for licensing other agencies, so a Part 90 license for a few 5 watt handi-talkies might be best all around. There are several Itinerant frequencies available that do not need frequency coordination and will probably have less outsider traffic than using FRS/GMRS.

[SteveH]

Part 90 radios were discussed and dismissed. The county puts pretty tight reins on public safety radio usage and pretty much restricts use to those who are NIMS certified and operating under an incident commander. Also, in the county, we have multiple warming shelters so there's concern about control.

 

If we can work something like GMRS at the town EOCs and FRS at the shelters, that makes the system quite flexible.

[n4gix]

Except for the fact that GMRS users cannot legally communicate with FRS users, all should be well...

[SteveH]

Huh...not on the shared channels?

[WQWI871]

Except for the fact that GMRS users cannot legally communicate with FRS users, all should be well...

That kind of confused me.

[SteveH]

The FCC's answer to the question was simple - no waivers on GMRS license fees. An individual is not an entity.

 

Oh well, was worth trying.

[WQWI871]

[SteveH]

The next move is to look for shelter workers who are related to each other.

[SteveC7010]

The next move is to look for shelter workers who are related to each other.

 

On that note, doesn't the shift for FRS from 0.5 watt to 2 watts on 1-7 and 15-22 offer you some opportunities to improve coverage? Probably the limiting factor for the moment will be the existing FRS/GMRS radios that will only do 1/2 watt on some of the channels.

[WQWI871]

Makes it a little difficult for businesses. I think there's either businesses doing group GMRS or FRS, I can walk into most shops here and see GMRS or FRS being used with either one GMRS license or even none.

[SteveH]

On that note, doesn't the shift for FRS from 0.5 watt to 2 watts on 1-7 and 15-22 offer you some opportunities to improve coverage? Probably the limiting factor for the moment will be the existing FRS/GMRS radios that will only do 1/2 watt on some of the channels.

The killer for FRS only, even at 2 watts, would probably be the attached antenna. We'll find out in a few days. Another approach might be MURS. I've got a couple of Dakota Alert base station MURS radios and decent antennas to try.

[WQWI871]

Yeah, non removable antenna sucks. The 2w limit is nice, but, I don't know how long It'll be before someone releases new combo radios with that change. Ashame that all my handhelds are still in like new condition because I use them lightly, so, I'd probably keep using mine up for a while anyways. And those Dakota Alerts are neat. I'd get a couple if I had the spare funds, but, I've been spending a lot on other radio supplies lately.

[jwilkers]

Well there really aren't even any GMRS bubble packs out there that even come close to 2 watts. Looking at Fcc data, most bubblepacks are below 1 watt. The industry has had the opportunity to make radios up to 5 watts; but none have done So. We will see, I guess.

 

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[Jones]

Part 90 radios were discussed and dismissed. The county puts pretty tight reins on public safety radio usage and pretty much restricts use to those who are NIMS certified and operating under an incident commander. Also, in the county, we have multiple warming shelters so there's concern about control.

 

If we can work something like GMRS at the town EOCs and FRS at the shelters, that makes the system quite flexible.

Pastor Gary is right:

 

"...City Government already has an FRN for licensing other agencies, so a Part 90 license for a few 5 watt handi-talkies might be best"

 

The shelter group does not need to use the counties radios, or share the public safety channel.  The group, as a division of the local government, needs to apply for their own VHF frequency, and get some 5 Watt HTs, or perhaps even 5 Watt base VHF stations with outside antennas.  Even UHF at 5 Watts would be fine with outside antennas. 

 

Part 95 is NOT designed for this purpose, and is not to be used by government agencies other than in a true emergency, which warming shelter coordination is on the very thin edge of that.  If I were the FCC, I would kick that out, and make you apply for part 90.

 

Yes, the radios will be more expensive than bubble packs, but professional part 90 radios on a coordinated frequency are the right tool for the job in this case.

[SteveH]

I probably made the mistake of trying to force GMRS as a solution as we're trying to promote that in our area. Then the goose chase for the fee waiver that really doesn't exist for individual licenses.

 

Our default for warming shelters is FRS and several are close enough to the centers of activity that FRS works. In one town we replaced FRS with wifi mesh telephony and we'd like to see more of that.

 

The warming shelters are staffed by volunteers from the community so the model is more of an informal CERT effort.

 

Of possible interest, I stumbled on FEMA's CERT communications presentation. It's dated 2012 so it's mostly up to date. It covers everything from sneaker net to Part 90 to ham with landline, cell, satellite, computer network, FRS, GMRS, MURS and CB in between. The only service specifically not recommended under any circumstances is CB. There are a few errors like MURS being repeater capable and the equipment availability being a bit off. See https://www.fema.gov/media-library-data/1449695072664-f9e63377160573cd3050158874dc548c/cert_emergencycommunications_ppt_100615.pdf