are "old" users who would own 4.44 million radios and replace 20% of these

or. 888,000 radios/year).

The number of imported hand-held units cited above is interesting
because its percentage of the total market (26.5%) is considerably higher
than was observed in earlier years (less than 10% on the basis of field
inspections). Traditional "walkie-talkies" are not particularly convenient
to use in a vehicle, even if an external antenna is used.43 ‘his suggests
that many users of the CBRS may be "passive" in the sense that they may not
routinely use these radios, but carry them in vehicles in case there is need

of communication.

Conclusion

The CB Radio Service has demonstrated the regulatory lesson that
if a personal radio service attracts the interest of large numbers of
the public, the service is likely to evolve in accordance with the popular

will, notwithstanding initial regulatory intentions or ongoing dictates.

43 Frequent flexing of the popular RG-58 antenna cable quickly results in
a broken center-conductor, a chronic maintenance problem associated with
such installations.

-51-



1200 feet above average terrain) may go as far as 50 miles. In some western
states where extremely high (5000 feet above average terrain) mountain sites
are available, the service radius may exceed 100 miles, at least in
unobstructed directions.2! Mobile stations may communicate directly on
either the base or mobile frequency when the comparatively wide service ares
of the repeater is not required. The base station frequency is generally
preferred since it enables the user to observe any repeater activity. Also,
since control stations may not directly communicate with mobile units on 3
mobile frequency, the base station frequency is the only permissible
alternative. Such operation is generally termed "direct" or "repeater talk
around", and is becoming increasingly popular as equipment cost declines.
Control stations are often referred to by licensees as "base stations"
because they comprise the principal operating point in the system as far as
the user is concerned. However, they are really base station-like only in
the sense that they do not move and usually have external antennas. They
are treated more like mobile stations in terms of technical regulation and

licensing policy.

GMRS growth

Prior to 1967, the number of GMRS stations was added to the number
of Class B, © and D stations to form the total number of authorized citizens
radio stations, so there is no way of knowing how many "Class A Citizens"

(as it was known then) stations existed between 1947 and 1966 because the

ai At UBF frequencies, an improved service area is more easily obtained
by increasing antenna height rather than trangmitter output power.

-21-




Glass of license lumber of licensees

Novice 77,000
Technician 83,000
General 117,000
Advanced 98,000
Extra 38,000

The fact that some 83,000 Technician class licensees have not
attained the General class license at this time suggests that the 8
WPM differential in Morse Code proficiency may not be trivial. Otherwise,
even if many Technicians had little or no interest in non~Morse Code HF
operation, they would nave probably have sought the General class license
even if only for the status that comes in having it. Therefore, the 13 WPM
Morse Code requirement is a significant barrier to entry to the General
class. How significant it is depends on the number of Technician class
licensees who would like to operate in the HF bands but who have not done so
either because philosophically they consider the Morse Code requirement
irrelevant to good telephony (and other non-Morse Code) operating Practice,
or who because of some degree of neurological or physical impairment cannot
(or can only with great difficulty) master the higher Code speed. An
impartial observer of this situation might suggest that a Morse Code
proficiency requirement be related to operation only in those frequency

bands reserved for Morse Code operation.

Another possible explanation for questionable barriers to entry in

the ARS is that those who have attained the higher license classes with some

~ 60 -


common communications protocol. This is necessary because a personal radio
service does not involve only intra-licensee communications characteristic

of the Part 90 services, but various types of inter-licensee communications.

The PRGS also argues that the new service should be ubiquitous;
that is, be usable without geographic constraint by the traveling public.
The provision of traveler’s assistance and emergency communications should

be facilitated.

Accountability should also be required, since the sharing of
limited spectrum can only be accomplished by mutual cooperation. To the
extent possible, cooperation in use of the frequencies should be insured by
a user transparent operating protocol. An automatic transmitter

identification system (ATIS) should also be featured in the new service.

The new service should also be expandible- able to accommodate
substantial growth. The PRSG notes that while the 400 kHz available to the
GMRS (and the new PMRS) can obviously not be expected to accommodate the
number of users envisioned in the PRCS proposal, it should be able to
accommodate 500,000 to 2,000,000 users if spectrum~efficient transmission

methods are implemented.

Lastly, the PRSG believes that the process of implementing the
PMRS should offer continuity. Evolution of the GMRS into the PMRS should be
structured to avoid, as much as possible, major dislocation or disruption of
current personal use systems. Current GMRS users should not have to make

unnecessary sacrifices in the transition to a more flexible radio service.

- 69 -


employee expressed in the salary cost had the employee returned to the
office, only to be sent out again on the new pick-up, versus the time
required to divert to the pick-up point on the initial return trip (i.e,
the value of the more efficient use of the employees time), the savings in
transportation costs, plus any benefits deriving from the earlier

availability of the delivered goods.8

The actual dollar value of the communications exchange just cited
may be difficult to determine (as would be the value of all radio communica—
tions by a licensee over @ particular period). Nevertheless, the licensee
should be able to attribute some value to the use of radio that would be

offered if continued use of the radio was suddenly made contingent upon it.

Individuals likewise place some value on the use of their time,
and in a given circumstance would be willing to pay for efficiencies made

possible through the use of two-way radio. Thus, a motorist stranded on an

8 The Commission concluded, in the Report and Order in General Docket
83-26 (50 Fed. Reg. 865, para. 21), that efficiencies and cost savings such
as those cited here translate into reduced cost of goods and services to the
public, and thus, that the public interest would be disserved by any
impediment (such as a new spectrum allocation for personal communications)
to commercial access and use of radio spectrum. There is, however, nothing
intrinsically superior about benefitting consumers indirectly through lower
prices of market goods rather than directly through the availability of high
quality personal communications.

~ll-




erroneously24 ) been used a8 a gauge of frequency use, and in the absence of
other data, it will be used here since there are similarities in the way

users in each service operate.

From the data given above (using the "ASMM" mobile count), we see
that the number of mobile units per licensee is 11.2 in the BRS and 13.6 in
the GMRS. These "authorized" figures may be nearly double the actual number
of mobile units in use, but there is no reason to assume that the
overstatement on mobile units in the two services would differ. The ratio
of authorized to actual usage would probably be the same. Also, the average
Personal user is unlikely to have more than five mobile units (two to three
vehicular to correspond with the number of automobiles used by the family
and one or two portables for peripatetic and public service use) so the
information suggests that the GMRS commercial user is somewhat larger (in

terms of authorized mobile units) than the average BRS user.

The ASMB mobile count difference between the two services is also
interesting. As mentioned previously, mobile relay operation is the
dominant mode of operation in the indicated frequencies (greater than 90%

of all users). Thus, the number of mobile units authorized the use of the

24 Mobile units would not be a valid indicator of use where there were
significant operational differences between radio services. For example,
interconnection (using the two-way radio to place telephone calls between
mobile units and parties in the public switched telephone network) is
permitted to a limited extent in the BRS (see Section 90.477) but not in the
GMRS. If BRS licensees were making extensive use of interconnection, the
average frequency utilization (in units of time) per mobile unit may be
higher.

- 26 -





the Part 90 radio services. It is a complicated form, requiring, inter
alia, the applicant to determine the latitude and longitude of his mobile
relay or base station, the height above sea level and the distance to the
nearest airport. There is little likelihood of the novice applicant
completing it successfully without help. Normally, Form 574 is completed by
equipment suppliers as a service to their customers. Thus, its use is not
generally burdensome to "the public." However, much of the personal use
radio equipment is purchased second-hand from sources not providing
application completion services. New users of existing personal use systems
can model their applications on those that have already been successfully
submitted to the FCC (i.e., those that have resulted in a grant), but the
Form 574 can be daunting to those wishing to set up new systems who have no

one to turn to.

One way many GMRS applications could be simplified is to eliminate
the need for individuals to be specifically authorized the use of mobile
relay stations; replacing this licensing requirement with a rule to the
effect that "the licensee shall not communicate with a mobile relay
("repeater") station without prior consent or arrangement with the owners."
This would eliminate the need for a lot of information on the Form 574 that

pertains to the mobile relay station.

Consistent with the preceding recommendation, and to encourage
more efficient spectrum utilization, GMRS licensees should be encouraged to
transmit office or home-to-mobile communications directly (i.e., without
going through a repeater), if possible. This would require the

authorization of a combination base/control station, preferably under the

-33-



General Class licensees take the same written test as the
Technician Class, but must pass a Morse Code proficieny test of 13 words per
minute. Operating privileges are the same as the Technician Class, except

that general access to the HF bands (1.8-30 MHz) is permitted.

Advanced Class licensees must be Proficient in Morse Code at a
rate of 13 words per minute and pass an intermediate level difficulty test
in electronic theory. The operating privileges are the same as for the

General Ulass, except that access to certain HF sub-bands is permitted.

The Amateur Extra Class licensee must be proficient in Morse Code
at a rate of 20 words per minute and Pass an electronics test of maximum

difficulty. Full access to all ARS frequency bands is permitted.

Amateur licensee examinations consist of "elements" as described

in the following table:

ELEMENT TABLE

1(A) General Code @ 5 wPM.

1(B) General Code @ 13 WPM,

1(C) Expert’s Code test @ 20 WPM.

2 Basic law, rules and regulations essential to a beginner’s operation,
including sufficient elementary radio theory for the understanding of
those rules.

3 General amateur practice and regulations, radio operation and
apparatus, provisions of treaties, statutes and rules affecting

amateur stations and operators.


The personal use versus commercial use question

The most significant problem in the GMRS concerns the perceived
rights of personal users versus commercial users. As early personal use
systems came on the air, a common reaction of earlier commercial users was
one of incredulity. Personals users were told that they were using
“commercial frequencies", that "CB type communications are not allowed" and
that they (the personal users) "had better get off the channel." A typical
personal user reply to these claims was that "anyone can be authorized to
use frequencies in this (GMRS) service", that "personal communications are
entirely legal", and that “business communications ought to be in the
Business Radio Service." Insults were sometimes traded over the content of
communications. In at least one case, a taxicab company was driven off its
channel when a new personal use repeater suddenly enabled individual
taxicabs to communicate with each other, causing a collapse in system
discipline.27 In another case, the same taxicab company paid a new personal

use system to vacate their frequency.28 However, operational conflicts

27 Conflict over the use of 462.675/467.675 MHz between Red Top Cab of
Arlington, Va. and National Capitol REACT of Washington, D.C., 1976.
Taxicab companies normally do not operate in the mobile relay mode.
Usually, the dispatcher transmits on the base frequency and listens on the
mobile frequency while the cabs transmit only on the mobile frequency and
listen only on the base frequency. This enables the dispatcher to hear cab
transmissions simultaneously while dispatching. The cabs cannot hear each
other, only the dispatcher.

28 Conflict over the use of 462.600/467.600 MHz between Red Top Cab of
Arlington, Va. and the Catoctin Communications Club of Frederick, Md., 1975.

The latter was paid approximately $500.00 to change frequency to
462.700/467.700 MHz.

-29-



Nevertheless, the Commission should insure that the amateur
examination elements are appropriate to the types of operation that would
be performed by the licensee. There have been many complaints over the
years that Morse Code proficiency requirements have constituted an
unnecessary and artificial impediment to fuller use of the ARS. Many have
questioned why a potential amateur with vast knowledge in the electronics
field should be excluded from the service due to personal disinterest in the
Morse Code. (There are currently no "codeless" classes of amateur license.
The desirability of a "codeless” class of amateur license has been
investigated in several rule makings,45 and the prevailing amateur view

has been that all amateurs should nave at least some proficiency in Morse

Code.)

Even if it is conceded that all amateur licenses should require
some knowledge of Morse Code, the relevance of the currently required
degrees of proficiency should be verified. For example, currently the only
difference between attaining a General license and a Technician license is
the required degree of Morse Code proficiency. The Technician class
requires 5 WPM and the General 13 WPM. The 8 WPM difference may be a
significant deterrent to attainment of the General class. The following
table gives the approximate (rounded to the nearest thousand) number of

licensees 1n the various classes:

45 See the Report and Order in PR Docket No. 53-28, (49 Fed. Reg. 1097,
January 9, 1984).

-59-




Provision could also be made for the use of amplitude compandored
sideband (ACSB) or any other narrow-band communications technology in the
GMRS. Assuming 5 kHz of required bandwidth per frequency, this would
increase the number of available channels to 40. Trunked use of some or

all of those frequencies would result in even greater efficiencies.

Even better flexibility would result from permitting the use of
any spectrum efficient technology in the GMRS, provided the radiated
emissions are contained within the allocated GMRS spectrum, particularly if
the operation of such a system would pose no compatibility problems with
pre-existing systems. Such technical changes, if permitted consistent with
the cost-effective availability of particular technologies, would permit the

GMRS to be utilized to its fullest capacity.

While additional technical flexibility would benefit the GMRS as
currently configured (i.e., as a typical land mobile radio service with
frequencies available only on a shared-use basis), additional value might be
derived by providing for the assignment of frequencies on an exclusive (or

at least semi-exclusive) basis.

For example, it is more difficult for GMRS licensees as a
collective body to decide to implement more spectrum efficient technology
than for an individual licensee to do so. An individual GMRS licensee
may decide that there are benefits to be obtained through the use of some
narrow-band technology that will multiply the number of available channels.
But if this benefit cannot be realized due to the reluctance of other

cochannel licensees to participate in the more spectrum efficient

~ 39 -



VI. OTHER ALTERNATIVES FOR PERSONAL COMMUNICATIONS

Sections II through V of this study have concerned relatively
minor proposals ror restructuring the current personal radio services to
better satisfy future demand for personal radio communications. However, :
the development of a viable personal communications marketplace is likely to
require more extensive changes and, very likely, the involvement of other

private land mobile radio services.

The following options go beyond the "fine tuning" of the current
personal radio services suggested in earlier sections. While they may
involve providing for greater operational and technical flexibility in the
services indicated, their primary intent is the creation of a personal
communications marketplace and, in a more general context, a general land

mobile communications marketplace. They are not without drawbacks, however.

1. Pexmit personal use of SMRS systems
The Commission should consider allowing personal operation on 900
MHz SMRS systems .62 SMRS systems offer a communications quality similar to

the GMRS at its best, although premium (expensive) communications equipment

62 A Special Mobile Radio System" (SMRS) is a private carrier managed
communications system operating in the 800-900 Miz band. While there are
some single-channel SMRS systems, most are trunked in 5 to 20 channel
groups. Currently, eligibility is limited to those eligible in the Part 90
radio services (Public Safety, Industrial and Land Transportation Services).
Individual use of such systems is not permitted.

- 8l-


While IMTS and cellular common carrier services are widely used
for personal communications (principally, for private telephone
conversations between a person in a vehicle and a person at some point
within the public switched telephone network), they are not discussed at any
length in this study because their regulatory regime is distinctly different
from traditional private services. This study is principally concerned with
better provision of personal two-way radio (or land tobile) radio services
that generally do not require access to the public switched telephone
network or the sophistication that is characteristic of most common carrier
systems. Thus, while the common carrier radio services principally fulfill
an important demand for mobile telephone service, it is uncertain to what
extent the current systems could be reconfigured to satisfy demand for other

type of personal communications.

Other services are semi-personal due to regulatory necessity. The
Aviation and Marine Radio Services may be used for some highly restricted,
incidental personal communications. However, because activity in the air or
on the water is potentially more hazardous than on land, frequencies must
always be available for emergency communications. Indiscriminate personal
communications are not possible due to the limited number of frequencies
available and must be restricted in terms of availability and content if

overall service discipline is to be maintained.

Thus, some services have a significant personal use element, but
because of industry structure or potentially undesirable external effects

requiring correction through regulation, can be characterized as


ABOUT THE AUTHOR

James E. McNally, Jr. has been employed with the FCC for seventeen years and
currently is a senior electronics engineer with the Commissions Office of
Plans and Policy. Previous FCC assignments include four years with the
Field Operations Bureau (in which he was principally involved with a special
Citizens Radio Service enforcement effort), seven years with the Private
Radio Bureau (where he was involved with private land mobile and personal
radio regulation), and four years with the Mass Media Bureau (in the Policy
and Rules Division). Additionally, Mr. McNally has held a Technician Class
Amateur Radio License (WB3APV) and a General Mobile Radio Service license
(KAB-0689) since 1975, and formerly held a Citizens Radio Service License
(KDN-6063).

-i-


assistance would be improved by the ability to operate on any available

frequency, but particularly 462.675 MHz.

Lastly, since the GMRS is not a frequency coordinated radio
service,34 the ability to operate on any channel, coupled with the
availability of frequency synthesized radio equipment, could enable users
to use the available spectrum more efficiently. Thus, if two potential
communicators are close enough for direct (simplex) communications, and the
frequency they normally occupy is in use by someone else, they could awitch
to a clear channel and promptly conclude their business. Thus, the ability
to operate on any frequency in the GMRS would create a type of "manual

trunking system" that would enhance the value of the service.

Similar efficiencies could result even when the use of a repeater
is necessary. Multi-channel operation could encourage repeater operators to
make interoperability agreements that could lead to more efficient use of
the spectrum. For example, the small number of personal use repeaters makes
it unlikely that two cochannel systems will be established in the same
area. Since there are often significant differences in repeater service
areas, restricting service users to one channel and one repeater system

could result in inefficient use of the spectrum if the communications path

34 A frequency coordinated radio service is one that has one or more FCC
recognized frequency coordinators. Such coordinators generally work with
equipment manufacturer representatives to determine the most appropriate
frequency for an individual applicant’s use. In the GMRS, on the other
hand, prospective users either rely on the advice of their equipment
supplier or select their own frequency.

- 36-



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- 646A.


stations to participate in non-profit financial arrangements necessary for
the support of the stations. However, potential users should not be
discriminated against by virtue of source of equipment or non-membership in
4 particular club or association. Assignment of a particular operating
channel would be necessary until trunking technology was available.
Frequency coordination in the manner of the Part 90 services should not be
necessary, but a repeater and control tone registration program of some type

should be encouraged.

The PRSG also believes that users of the PMRS should be required
to have the capability for direct communications; that is, the ability to
transmit on the repeater output frequency in order to avoid using the
repeater itself if possible. Two-frequency direct (duplex) operation would
also be phased out as being overly spectrum consumptive. Furthermore, —
duplex base stations which cannot monitor the channel for ongoing traffic
before transmitting can cause interference and should be required to monitor
the output frequency. A similar situation occurs in the case of wireline
control point operation of repeaters. The PRSG also recommends that
mobile~only operation on 467 MHz frequencies be prohibited since such use
cannot recognize interference to repeater operation. Thus, the general
solution to these problems is to preclude all operation on 467 MHz

frequencies except that related to repeater access and control.

The PRSG also proposes new narrow-band FM operation on GMRS offset
frequencies 462.6125 and 462.6375 MHz. These would be available for
general use, direct communications between all users but subject to very

restricted output power. Other offset channels would be reserved for

-~72-


Bd bidahehake tye





number of service users. Because of the large number of frequencies
available in the BRS, the same procedure was not followed. Also, some
frequencies in the BRS (e.g., central station protection service
frequencies, "offset" frequencies and the like) have assignment or operating
limitations that make them atypical. Accordingly, for the BRS sample, 8
"general use" channels were selected for analysis. As a matter of
convenience, it was discovered that eight such channels existed exactly one
MHz below the assignable GMRS frequencies. The survey results are given
below ("ASMB" is the authorized number of mobile units on the indicated
"base" frequency, "ASMM" is the number of authorized mobile units on the

associated mobile frequency):

Nationwide Unique Call Signs Assigned per Frequency GMRS/BRS

GMRS BRS
Frequency Call Signs ASMB ASMM Frequency Call Signs ASMB ASMM
462.550 1628 18449 28187 461.550 1485 7463 17637
462.575 2033 18039 34712 461.575 1492 7054 16370
462.600 1883 14098 22897 461.600 1512 7107 16465
462.625 1454 12853-16793 461.625 1416 7308 16116
462.650 1351 24114 927297 461.650 1388 7005 = 15156
462.675 3057 26369 29320 461.675 1428 7251 = 15598
462.700 1624 11205 14519 461.700 1491 8487 17202
462.725 1459 15226 23754 461.725 1364 7106 =: 15582
Totals: 14489 140353 197479 Totals: 11576 58781 130126

~ 24 -



personal use than for commercial use.°4 This should not be cause for
concern, because the current commercial users of such a repeater could first
be given the opportunity to pay more to retain its use. Similarly, if
cochannel licensees are bothered by the extra congestion that may develop as
a result of personal use, there should be nothing to prevent them from
approaching a repeater manager and offering some compensation if personal
users are excluded. The goal is for all communications system users to pay
an appropriate price for the quality of service they desire. This result
cannot be achieved if personal users are arbitrarily excluded from access

to most of the private land mobile spectrum. Even if personal user demand
for access to commercial repeaters is small (which is likely to be the
case), a system will be in place whereby commercial users (through their
repeater managers) can trade in interference rights and pay a price that

will result in the quality of communications they desire.

64 A conservative approach to permitting personal use of commercial
spectrum might be based on the belief that while personal users ought to
have access to commercial spectrum, they need not have unrestricted access.
Thus, (under this conservative approach) it would be inappropriate (for
example) to grant a license to operate 4 repeater in the Business Radio
Service to an individual applicant. Also, @ prospective repeater operator
should be fundamentally eligible to operate a station in a particular
commercial radio service in order to have the incentive to make a prudent
judgement as to the compatibility of personal use in a given area. (In a
gense, personal users could be eligible on a secondary basis~ contingent on
being "sponsored" vy a commercial user.) This would have the advantage of
tending to preserve the "business" identity of the Business Radio Service.
A more progressive and flexible approach would be to allow a commercial
licensee to sell the authorization (i.e., assign all rights contained
therein) to a personal user for a suitable price, or to initially permit
individuals to sponsor commercial repeaters as an investment opportunity
(i.e., selling communications service would in effect become the "business"
of the individual). :

- 83 -


communications.

The PMRS would eventually offer 4 manually selectible “community
channels". Each would offer sing le~frequency simplex type operation for
group or community activities requiring communication among a number of
users. Three channels would also be reserved for manually selected access
to particular repeaters for wider area group communications. Provision for
a greater number of community channels was seen as jeopardizing the nature
of the PMRS, which, as indicated previously, is intended to be functional
and utilitarian rather than conversational or recreational. The remaining

channels would be used for digitally accomplished directed communications.

The foregoing Summary touches only on the more Prominent PMRS
Proposals. Numerous ancillary proposals and details have been omitted as
unnecessary to understanding the overall thrust of the petition. Further
information may be obtained by consulting either the RM-5058 or PR Docket

No. 86-38 file.

RM-5242 (Short-term restructuring of the GMRS to enhance personal use)

On October 29, 1985, the PRSG submitted a supplemental petition on
GMRS reregulation that was assigned petition number RM-5242. The PRSG urged
that the Commission act on the submitted proposals (which were similar to
the interim proposals made in RM-5058) promptly, whether or not it acted on

the proposals outlined in RM-5058. Specifically, the PRSG Proposed that:

1. The FCC permit only individual licensing in the GMRS;

2. Restrictions on cooperative repeater use by travelers should be relaxed;

-74-


essentially no eligibility restrictions in GMRS, about half the licensees
are commercial entities, many of whom have chosen the GMRS largely because
of congestion in the other private land mobile services.4 Over the last
decade, use of the GMRS by personal users has increased significantly. This
shared use by personal and commercial users has resulted in some problems
which will be discussed at length in the next section.

The Citizens Band Radio Service is similarly a private service
intended for short-distance two-way personal and business communications.)
Over the years, use of the CBRS has become almost exclusively personal
in nature. Generally, communications are of a recreational nature, although
traveler’s assistance communications are significant. Other types of
expedient communications are less common. The CBRS offers forty channels in
the 27 MHz band for voice communications in the "AM" or "double sideband"
mode (which is similar to the emission used by AM broadcast stations).
These channels may be split in order to yield 80 "single sideband" channels.

This service was quite popular in the late 1970°s-- there were nearly

4 See Graph 1, infra, where the number of GMRS licensees declined in the
period 1970-1973. This unexpected behavior is explained by action taken in
1968 in Docket 13847 when the Commission "split" the then current 50 kHz
bandwidth UHF channels into 25 kHz bandwidth channels, thereby doubling the
number of available UHF channels in all of the private land mobile radio
services. For several years thereafter, the GMRS was not needed as a
service alternative and many of its licensees relocated to their more
appropriate radio service. However, due to high growth in the use of
two-way radio in the seventies, the GMRS again became utilized as an
alternative in 1974. As will be explained in the next section, the
Perception that GMRS is a less congested radio service appears no longer
warranted and may explain a recent decrease in GMRS growth.

5 See 47 CFR 95.401




bands), or cause such operation to be discontinued if significant problems

developed.

5. Allocate 460 MHz spectrum im from the Industrial Radio Services & to the GMRS

This option assumes that personal user opportunity of access to
spectrum remains essentially unimproved, that the GMRS is retained
essentially as is, that a spectrum-ef ficient technology has been implemented
and that demand exceeds expectation. The reallocation of several channels
from the Business Radio Service or one of the other Industrial or Land
Transporation Radio Services may be justified. A 450 MHz band allocation to
the GMRS would avoid the need tor a multi~band operating capability. The
GMRS contributed trequencies to these services in its infancy and they have
had the benefit of substantial 900 Miz allocations over the years. The
number of commercial users who would need to vacate their channels would be
on the order of several thousand (assuming an average of 1500 usere per
channel). The loss of (for example) four channels in the Business Radio
Service would only amount to several percent of its total allocation, but it
would represent a 50% increase in the GMRS allocation. Such a reallocation
might be appropriate if the GMRS continues in its tradition of being a
disciplined radio service, if spectrum-efficient technology is widely used,
and if such technology is not in use in the Business Radio Service.

Clearly a considerable disparity in perceived spectrum utilization between
the two services would be necessary to overcome the expected political

opposition.


communications in the ARS must pertain to personal development.

Recreational communications are permissible, as are many communications
relating to matters of personal expediency and public welfare. The
Commission’s mandate to allocate frequencies in the public interest requires
periodic re-examination of amateur radio regulations and policies to

determine whether they continue to serve the public interest.

Certain aspects of ARS operation may require re-examination in

order that it may be maximally useful as a personal radio service:

1. The examination elements for each license class should be
reviewed to insure that required skills correlate with
operating privileges. Any unnecessary requirements that

may constitute a barrier to entry should be eliminated. 47

2. The rules relating to permissible communications,
particularly so-called “business communications"
(including personal communications of a financial
nature) should be reviewed and clarified consistent
with the goal of providing for maximum flexibility
consistent with the nature and purpose of the

service.

47 A partial review consistent with this recommendation is underway in PR
Docket No. 86-161 (Amendment of the Amateur Radio Service Rules to expand
the Privileges Available to Novice Operators) 51 Fed. Reg. 17074, May 8,
1986, where examination of the operating privileges available to Novice
Class operators is currently under review. This proceeding is summarized in
the next section.

-65-



were not limited to taxicab companies. It igs alleged that some commercial
users relocated to better antenna sites in order to “outcapture" the signals
of personal use repeaters in selected areas; and that in some cases,
established commercial systems were not fully loaded before new commercial
Tepeaters were put on the air in an attempt to pre-empt further Personal

growth in the area.29

This type of response to the sharing problem is unfortunate, and
is inconsistent with Section 95.7(a) of the Commission’s Rules which states
that “channels or channel pairs assigned to GMRS Systems are available only
on a shared basis and will not be assigned for the exclusive use of any
licensee" and that "all applicants and licensees shall cooperate in the
selection and use of channels and channel pairs in order to reduce
interference and to make the most effective use of the authorized

facilities." This rule anticipates licensees monitoring the frequency for

29 The Personal Radio Steering Committee (PRSG), an association of loosely
affiliated personal users that publishes a national Personal use repeater
directory, a set of annotated rules and other information of interest to
Personal GMRS users, has petitioned the FCC (in RM~5058 and RM-5242) to
limit the authorization of commercial entities in the GMRS in order to
enhance the service’s personal use utility. PRSG alleges that in many areas
(principally, but not exclusively, urban areas) all available GMRS
frequencies are very congested; that commercial users are frequently
intolerant of personal use; that many commercial users are ill-advised to
operate in the GMRS by equipment salesman who fail to mention the potential
impact of personal communications; that the GMRS is often used by licensees
in other services who want a second frequency in their original service,

but cannot provide the required justification; that commercial users
invariably operate in the mobile relay mode when direct mobile-to-mobile
communication is Possible; and, that commercial stations often fail to
monitor the channel for ongoing communications before transmitting. PRSG
mentions that high volume dispatch operations in GMRS are particularly
troublesome.

- 30 ~


3.

Explore the feasibility of permitting some degree of
interconnection in the GMRS, thereby permitting greater

operational flexibility in the use of the service.

Update the GMRS technical rules to allow the use of

state-of-the-art communications technologies.

- 42 -


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- 464 -


III, THE CITIZENS BAND RADIO SERVICE

Greation of the CB Radio Service

The current Citizens Band Radio Service (CBRS) was created as the
Class D Gitizen’s Radio Service in 1958 by a First Report and Order in FCC
Docket No. 11994 that reallocated most of the 450 MHz band spectrum from the
Class A Uitizens Radio Service to other emerging commercial land mobile
radio services (principally the Business Radio Service); and, as
compensation to the general public, allocated 22 frequencies in the 27 MHz
band for its use in the belief that the lower cost of equipment would pve
within the means of more citizens. This assessment proved accurate. Within
a year the FCC was receiving about 7000 applications per month for stations

in the new Class D service.

General description

The CBRS is a personal radio service used predominantly for
recreation or to facilitate some personal activity. No station or operating
license 1s required and the only eligibility restriction prohibits use of
the service by toreign governments and their representatives, and federal
government agencies. Users may operate on any of 40 channels starting at
26.965 MHz and ending at 27.405 MHz. The channels may be “split” for single
sideband (SSB) use, but the dominant mode of operation is double sideband
amplitude modulation. Transmitter output power is limited to 4 watts.
Base-to-mobile range is typically 5 to 10 miles, and is principally limited
by a high noise level consisting of a mix of many distant stations” signals

commonly referred to as "skip." The frequent problem of unwanted distant

signal reception is perhaps the greatest drawback to the service and is the

+ 43 -



GMRS restructuring evaluation criteria
The PRSG outlines nine criteria that it believes should guide the

restructuring and evolution of the GMRS into the PMRS.

First, the service should be functional. It should be designed to
serve the legitimate, non~frivolous, real-time communications need of the
modern citizen in a mobile society. The PRSG notes that recreational uses
of radio are already permitted in the CBRS and the ARS. Further,
point-to-point communications (such as home-to-home communications) should
be highly restricted, if permitted at all, due to the availability of other

media (such as the telephone).

The new service should also be accessible; that is, accesa to the
service should be easy and equitable. Licensing procedures should be
simplified to the greatest extent possible. Membership in a special
interest group should not be required, and use of a particular repeater

should not depend on acquisition of equipment from a specific vendor.

The PRSG further believes that the service should feature
operational simplicity. Sophisticated functions should be equipment
controlled. A basic selective calling feature should be provided so as to
eliminate the need to continuously monitor ongoing traffic for specific
personal calls. The use of this feature should be routine, thereby

discouraging conversational "round table" type communications.

Next, compatibility should be a feature of the new service. That

is, a common type of emission should be used by all equipment, as well as a

= 68 -


The CRS is not envisioned as a cordless telephone service, and the

Possibility of interconnection, while not Precluded, is discouraged. 59

Comments are then solicited on the most suitable operating
Protocol, the number of emergency or priority channels that should be
provided, and means for insuring that non-emergency communications not take

place on these channels.

The Commission notes that while individual GMRS stations are
licensed, it does not intend to license CRS stations. However, it leaves
open the option of licensing CRS repeater stations, or stations with higher

than normal output power or antenna height .60

The Notice then requests comment on whether commercial and
Personal uses have been compatible in the CMRS and whether they would be
compatible under the Proposed concept. Comment is also sought on the extent
to which current GMRS operation should be grandfathered and whether suitable

communications alternatives exist for those users.

58 Ibid., paragraph 14.
59 Ibid., paragraph 15,

60 Ibid., paragraph 20.

- 78 ~


length is comparatively short and the repeater service area is great. A
multi-channel operating capability could lead to greater use of local area
systems for medium distance (5-20 miles) communications, with use of wide

area (20 to 50 or more miles) systems only when really necessary.

Interconnection in the GMRS

Interconnection or "phone patching" is the use of a private land
mobile station (such as a GMRS station) to place telephone calls in the
public switched telephone network (PSTN). Interconnection in the GMRS was
permitted on the same basis as other land mobile stations in the Part 90
radio services until 1978, when it was prohibited in response to problems in
enforcing the then-current interconnection policy that required manually
accomplished interconnection at shared facilities (principally,
“repeaters").35 While interconnection policies in the other land mobile
radio services have subsequently become more permissive, action on requests
for changes in the GMRS interconnection policy has been deferred pending
resolution of the proceedings exploring the need for a new personal radio

service. Since this question has been answered in the negative, there

35 See the First Report and Order in Docket No. 20846 (Policies and
Regulations to Govern Interconection of Private Land Mobile Systems with
the Public Switched Telephone Network) adopted on August 17, 1978. Early
interconnection policy was restrictive for three reasons: dispute over
whether shared use of private land mobile stations constituted common
carrier operation; dispute over whether mobile telephone communications
should be the exclusive domain of radio common carriers; and, concern about
the effect of conversational communications (characteristic of telephone
use) on the dispatch nature of communications in the private land mobile
radio services. The first two issues were resolved in the final phases of
Dockets 18921 and 20846, respectively. The latter has become largely moot
due to deregulatory actions in the Part 90 services that have permitted
increasingly liberal interconnection.

-37-



ALTERNATIVES FOR IMPROVED PERSONAL COMMUNICATIONS

by

James E. McNally, Jr. */

Office of Plans and Policy

September, 1986

*/ The opinions and conclusions expressed in this report are those of the
author. They do not necessarily reflect the policies or views of the
Federal Communications Commission or any other organization or individual.
The author wishes to thank Michael G. Kemper of the Computer Applications
Division for his "Old Density" program used to estimate the number of
actual users on specific frequencies, and Thomas C. Spavins and Alex D.
Felker of the Office of Plans and Policy, and Roger D. Madden, John B.
Johnston and Stuart E. Overby of the Private Radio Bureau, for their many
helpful comments and suggestions.


The most heavily used of the ARS spectrum are the HF bands between
1.8 and 30 MHz (for worldwide, long-distance communications) and the VHF
(50-225 MHz) and lower UHF (420-450 Miz) bands. From the standpoint of
providing for personal communications of a greater number of the general
public, only the VHF and UHF Spectrum would be generally desirable. The HF
bands” natural use is for long-distance communications. While this
capability may be of interest to a small number of the population that might
desire to circumvent the need for making long-distance telephone calls,
widely variable interference (due to changing propagation conditions), radio
and television interference potential (comparable to that of the CB Radio
Service) and limited amount of spectrum make the HF bands unsuited to any

large increase in personal use.

Indeed, the VHF and UHF amateur bands are desirable for personal
communications for two reasons: 1.) The frequency bands and communications
systems widely used in those bands are similar to those used in other land
mobile services; and, 2.) There are minimal entry barriers to.the use of
this spectrum. A person desiring to operate in the amateur 2 meter band
(144-148 Miz) need only obtain a technician class license that requires 5
words-per-minute Morse Code proficiency and general knowledge amateur
regulations and radio theory. The average person wanting to "cram" for the
examination would probably be adequately prepared after a period of several
days to two weeks, assuming several hours of study per day. While such
study could be viewed as an inconvenience, it is certainly not a significant

barrier to entry.

- 58 -


“Citizens Band Radio Service." These and other less significant changes

were very effective in making CB truly a citizens radio service.

Growth

By sate 1974, the number of licensees had passed the 1,000,000
mark and entered a period of exponential growth. This growth was no doubt
due in part to the deregulatory action taken above; but in large measure was
likely due to the arab oil embargo. Indeed, the public was quick to discover
the value of CB radio in finding open gasoline stations during the 1973-74
gasoline shortage. CB was also (and still is) employed to monitor for
reports of radar traps and police vehicles in an effort to circument the 55
MPH speed limit. Graph 2 shows the growth of the Class D service from 1960

to 1985.

As can be seen, the service experienced consistent growth through
the sixties (by 1962 it was the FCC’s largest radio service), leveling off
in 1970 at about 850,000 licensees. The growth rate picked up dramatically
in 1974 (probably for the reasons explained above) and exploded from 1975
to 1979 (extensive media coverage ensured that "CB radio" became a household
word). However, it certainly appears that interest in CB was only a fad,
since most of those licensees authorized between 1975 and 1977 failed to
renew their licenses during the period 1980 to 1982. This sharp decline in
initial interest, coupled with an almost complete lack of new interest,
Probably accounts for the apparent decrease in number of users in that

time period.


Asyamatric Reg jon for ‘Coapat tt toa Policy: Analyeie, °
re, Paper, #14 7 :



source information has long since been discarded. Beginning in 1967, the
FCC Annual Reports separate GMRS from the rest. The growth history is given
in Table 1.22 The number of stations specified for the years 1981-1983 is
less than might otherwise be determined. Prior to 1980, the FCC licensed
individual classes of stations, giving each a separate call sign. Thus, a
single licensee would normally be licensed for three stations- a control
station (e.g., KAA-0123), a mobile relay station (e.g., KAA-0124) and a
mobile station (e.g., KAA-0125). These three stations combined to make a
communications system. To facilitate licensing and system identification,
the Commission adopted an Order effective June 30th, 1980, that implemented
a procedure of system licensing. System licensing permits most GMRS systems
to be authorized on a single application form, under a single call sign.

For the years 1980-1983, the Commission added the number of systems that
were authorized to the previous total number of Stations. In 1984, an
adjustment was made to the figures to reflect the number of stations
authorized per system, but the figures for the preceding three years were
not individually corrected. Since (as stated above) most GMRS systems are
mobile relay or "repeater" systems, the approximate number of individual
GMRS licensees is one-third the number of authorized stations. Thus, on the
basis of the number of stations authorized, we would expect that there are
currently some 12,000 individuals or entities operating in the GMRS. In

actuality, there are about 14,500 GMRS licensees, as determined from a count

22 Source data reflected in this and subsequent graphs was obtained from
Private Radio Bureau (PRB) statistics, FCC Annual Reports and, in the case
personal user data, author estimates based on judgments of PRB licensing
personnel.

~22-


II. THE GENERAL MOBILE RADIO SERVICE

The General Mobile Radio Service (GMRS) is the direct descendant
of the original Citizens Radio Service that was created on December ist,
1947 ,16 Eligibility to operate is essentially unrestricted (foreign
governments, their representatives and individuals under 18 years of age
may not apply) and there are few restrictions on permissible
communications.17 4 station license is required, and the application form
(FCC Form 574) is that used by the other commercial and public safety (Part

90) land mobile radio services.

Frequencies allocated to the GMRS

The GMRS is currently allocated 16 discrete UHF frequencies that

are usually paired to make 8 actual channels that are authorized on a

16 Over the years, the current General Mobile Radio Service was known as
the "Citizens Radio Service" (1947-1958), the "Class A Citizen’s Radio
Service" (1958-1978) and the General Mobile Radio Service (1978-present).

17 Permissible and non-permissible communications are summarized in
Section 95.181 of the Commission’s rules. The more significant
non-permissible communications include those which would demonstrate an
intent to cause interference or those that would be more in the nature of
a broadcast or common carrier service.

-18-


Personal use of the GMRS

While individuals have always been eligible to operate in the
GMRS, early users were commercial concerns that elected to operate in the
GMRS to avoid the congestion the other services, to provide a single
communications system for employees whose activities may have required the
use of two or more of the other commercial radio services, or to have what
was effectively an exclusive-use frequency. For many years (from its
creation in the late forties until 1974), personal use of the GMRS was
minimal. Even today, the GMRS is a radio service virtually unknown to the

public.

In the early seventies though, the number of applicants applying
as individuals (thereby assumed to operate more for personal than commercial
purposes) began to increase. The majority of these personal users were (and
are) individuals dissatisfied with the quality of service offered in the
CBRS, and who wanted quality base-to-mobile communications in a disciplined
operating environment. The GMRS was the only alternative available and the
quality of service was considered worth the cost of equipment.26 By the
mid-seventies, personal use GMRS applicants (individuals) reached 50% of the

annual total and has remained at that level ever since.

26 The availability of used commercial radio equipment at affordable
prices was also a significant factor stimulating personal use of the GMRS.
Also, many early personal users were associated with Radio Emergency
Assistance Communications Teams (REACT) that were seeking a more
interference-free means of communications and had sponsored repeaters in the
GMRS primarily for intra-team communications. Very few personal users own
single user repeaters- they are simply too expensive. Nearly all personal
use repeaters are operated by some type of collective.

- 28 -



filing comments and could only devalue the service in the eyes of its

licensees.
Current number of CB users indirectly estimated

Since the FCC no longer issues CB 1icenses, it is difficult to
estimate how many CB stations are currently in operation. However, using
Commerce Department figures for the first 11 months of 1985, we estimate
that the total number of CB radios imported that year was approximately
2,064,000. Of these, about 1,360,000 were mobile (DC only) units, 95,000
were combination types (CB/AM/FM radios) and 546,000 were hand-held units.
Somewhat surprisingly, only 63,000 base station units (AC only or AC/DC
units) were imported. (However, mobile units can easily function as base
stations with an external power supply.) Assuming that the overall CB radio
inventory is about constant because overall use of the service has
stabilized, these import figures (few, if any CB radios are made in America)
probably reflect actual consumption. No authoritative data is available on
what percentage of this equipment was purchased for replacement purposes and

what percentage was purchased by new entrants.

Nevertheless, the CB radios that were imported would satisfy the
demand of some 1,000,000 new stations annually (assuming 2 radios per
station), or about 5,000,000 existing stations, assuming no increase in the
number of users and a radio lifetime expectancy of 5 years. More
realistically, the CB "turnover rate" is probably about 20% per year, with
little or no new growth. This assumption would yield a total of 2,777,000
stations (20% or 555,400 of which are new annually and would purchase 2

radios each for a total of 1,110,800 radios and 80% or 2,221,600 of which

- 50 -


V. PENDING PERSONAL RADIO PROPOSALS

Currently, there are no rule making petitions in the CBRS that
would significantly expand or enhance its use by the general public. With
respect to the ARS, the Commission, on April 30, 1986, adopted a Notice of
Proposed Rule Making in PR Docket No. 86-161, in response to 8 petitions,
that proposes to expand the privileges available to Novice class amateur
operators in order to stimulate new interest in the ARS.48 Among the
proposed privileges would be the ability to use voice emissions in certain
frequency bands for the first time. The proposals are intended to reverse a
trend that has seen the loss of 10,000 Novice Class amateurs (about 12% of
that class) over the last two years. An important question raised in the
Notice is whether this loss may not be a result of the limited privileges of
the Novice class license, but may instead reflect an imbalance in the
privileges and qualifications associated with the present license classes. 49
This proceeding affords an opportunity for public comment on the license
qualifications and operating privileges of the entry level classes of

amateur license.

48 See Footnote 47, supra.

49 Ibid., Footnote 4. Comment is requested on whether the Technician
Class operator written test requirements could be confined to those topics
from Element 3 commensurate with the VHF and UHF privileges suthorized by
that license. The Notice points out that it would be a simple matter to
rearrange the topics into two syllabi: Element 3(A) for VHF and UHF and
Element 3(B) for MF and HF. Element 3(A) would be a requirement for
Technician and higher classes of license, and Element 3(B) would be a
requirement for General and higher classes of licenses. An alternative not
mentioned would be to retain Element 3 and afford Technician Class operators
additional MF and HF privileges.

~ 66 -




A potential impediment to Personal use of shared commercial
frequencies is that since they are not authorized on some sort of Property
or resource-right basis, there is nothing to discourage an opportunistic new
entrant from constructing a new system in a long-established, stable
environment for the sole Purpose of being bought out in some way by current
usere who wish to retain the Status quo. Thus, some reasonable way of
Precluding such entrants would have to be provided- perhaps by the
application of area~specific channel utilization criteria that could be
applied by a frequency coordinator to assess the impact of the new system
on current users.65 The difficulty in defining the resources of current
users may be considerable and additional study is necessary to determine
whether such an effort to foster a communications marketplace on

non-exclusive use frequencies would be worthwhile.

3. Allocate spectrum um in the 900 Miz ISM band or the 1.215-1.300 215-1.300 GHz band
for personal use

Currently, the Amateur Radio Service is authorized the use of 26
MHz of spectrum in the 902-928 Maz band and 85 MHz in the 1215-1300 Miz
band. while the latter band is high in relative frequency, all of this
spectrum is still in the UBF range, and relatively affordable equipment is
available for direct and repeater-type operation. The Commission may want

to consider allocating part of this spectrum for personal use, or create

65 Such a determination by a frequency coordinator might be appropriate
in view of the additional spectrum management responsibilities delegated in
the recent Report and Order in PR Docket No. 83-737 (adopted April 3, 1986).

~ 84 -


semi~personal in nature. As such, they will not be further discussed in

this report.

This study. considers whether there are other non-personal radio
services (the Part 90 private land mobile radio services), which if freed
from unnecessary regulatory constraints could more effectively participate
in a competitive communications marketplace and contribute to the resolution
of the personal radio problem. If these services are able to accommodate a
personal use element, considerable progress can be made toward providing
individual members of the general public with better opportunity of access

to quality two-way radio service.

The personal radio debate

The debate on the personal radio problem began with the
Commission’s decision on October 12, 1978, that the Citizens Band Radio
Service was inadequate to meet the personal communications needs of the
public and that a better way of meeting these needs was required.1
Subsequent Commission actions have considered whether public personal
communications requirements should be satisfied through the creation of a
new, comprehensive personal radio service. In view of the competition among
established spectrum consumers for the limited amount of unallocated
spectrum, the creation of a new personal radio service will be difficult.

This study suggests that such an approach may be unnecessary, and if

1 See the Report and Order in PR Docket No. 79-140 (Inquiry into the
need for creation of a new personal radio service), 48 Fed. Reg. 12262,
March 23, 1983.


Of potential interest to members of the general public that may
not be interested in the ARS are two petitions (RM-5058 and RM~5242) that
seek to make the GMRS better able to satisfy potential public demand for
quality two-way radio communications. Also of interest is PR Docket No.
86-38, that proposes to replace the GMRS with a new "Consumers Radio
Service" that it believes may be more responsive to public needs. A brief

summary of these proposals is given below.

RM-5058 (Restructuring the GMRS into a new "Personal Mobility Radio

Service")

On June 11, 1985, in view of the Commission’s decision not to go
forward with the proposed Personal Radio Communications Service (PRCS) in
Docket 83-26, the Personal Radio Steering Group (PRSG) filed a petition
(RM-5058) to amend Part 95 of the Commission’s rules governing the GMRS.
Essentially, the PRSG sought the restructuring of the GMRS to enhance its
personal use capability and enable it to meet significantly greater demand
for higher quality personal communications, and its ultimate evolution into
a new "Personal Mobility Radio Service" (PMRS). The name of the service,
according to the PRSG, was chosen to more clearly illustrate its personal
nature and reflect an emphasis on person-carried radios, rather than radios
installed in vehicles. This is not to say that regular mobile operation
would be "secondary" in any sense, but rather that as the public comes to
perceive the utility of the new service, the continuous capability to
communicate will be desired, giving rise to widespread and even dominant use

of portable units.

-67-



narrow-band emission use. Two of these would be used for repeater control
purposes. During this interim PMRS period, the PRSG proposes restricting
users to not more than two channels, in addition to the offset frequencies
mentioned above, in order to insure equitable treatment of all service users
(they believe that in the past, some GMRS users have been given multiple
frequency authorization without adequate justification). However, all PMRS
service users would also be permitted to operate on 462.675 MHz, the current
de facto emergency channel. The use of this channel for motorist assistance

and emergency communications would thereby be enhanced.

Description of the finalized PMRS

The final-stage PMRS, proposed to be implemented in the late
1990’s, would be patterned somewhat from the PRCS, using digital system
control and selective calling techniques. Additionally, it could utilize
digital modulation, such as linear predictive coding (LPC) with frequency
shift keying (FSK) or minimum shift keying (MSK) to transmit voice quality

information in a 5 kHz or less bandwidth channel, as technology permits.

In comments filed on its own petition, the PRSG proposed
reconsideration of the weighting process currently applicable to operation
in the GMRS that favors the use of repeater rather than direct
communications. While repeater operation would be an important feature of
the PMRS, the emphasis would be on accomplishing more spectrum efficient,
short-distance communications. Thus, a channelization plan and operating
protocol was proposed that would decrease the number of repeater channels
available when loading of the direct communications frequencies increased

beyond a certain point, making those channels available for direct

-73-


INTRODUCTION
The public interest in two-way radio telecommunications was

demonstrated by the popularity of the Citizens Band Radio Service (CBRS),
which in 1979 had 15 million licensees. However, the quality of service in
the CBRS was poor, in part because of adverse long-distance propagation
conditions and excessive congestion. Further, widespread use of the CBRS
was alleged to have caused significant interference to television reception.
Aware of these drawbacks, and desiring to give the public opportunity for
access to a better quality radio service, the Commission, at a special
meeting on October 12, 1978, decided to explore the feasibility of a new

personal radio service in the 900 MHz band.

However, on November 5, 1984, the Commission concluded that other
uses of the 900 MHz radio spectrum would better serve the public interest.
On January 30, 1986, the Commission proposed replacing the General Mobile
Radio Service (a personal radio service in the 460 MHz band that offers
excellent quality communications, although at a substantially higher cost
than the CBRS) with a new Consumer Radio Service (CRS) intended to offer low

cost but very short-distance personal communications.

Resolving personal radio issues has been complicated by the
competing demand for radio spectrum by the commercial segment of the
communications industry, the absence of an effective public lobby,
uncertainty as to the communications needs of the general public, and the
absence of a method by which the value of radio communication to current and
potential two-way radio user groups can be determined. If the Commission is

to improve the availability of better quality two-way radio communications


for a mobile license to operate in the GMRS. Operation from the home, with
a "mobile unit" connected to a fixed, external antenna (for what would
traditionally be "base" or "control" station operation) would be considered
a logical extension of the basic mobile operating privilege. A "land
station" license would be required only for base stations exceeding

certain baseline technical parameters. Similarly, a "repeater license"
would be granted to trustees of GMRS repeaters. Effective radiated power,
in the case of the mobile license, would be limited to 5 watts,°0 and the
associated fixed antenna must not exceed 20 feet above the height of the
house or other supporting structure (other than an antenna tower or
similarly specific antenna supporting structure). The use of directional
antennas in the "control station mode" would also not be required, in order
to facilitate direct home~to-mobile communications where possible. The
frequency tolerance of these stations would be the same as a mobile

station.

The PRSG proposes that repeaters be licensed only to a single
"trustee" whom the Commission can hold responsible for its proper operation.
Furthermore, repeaters should be required to operate on a non-profit basis.
They could be owned by anyone (including a commercial entity), but the
responsibility for operation would be vested in a specific individual.

Repeater trustees should be given the authority to require users of their

50 The PRSG-proposed mobile power limit of 5 watts ERP represents a
substantial reduction in the currently permitted transmitter output power of
50 watts (which with a 3 to 5 dB gain antenna would be 100 to 158 watts
ERP). This reduction may be intended to place vehicular unit communications
capability on a par with less powerful (2 to 5 watts ERP) portable units.

-71-


is required.63 Personal demand for that degree of quality is likely to be
tather small, the Price being a significant barrier to entry. But if
Personal users are willing to Pay the price, SMRS operation should easily be
able to satisfy their needs, As noted Previously, there is often some
compatibility between Personal and commercial use, and this could be

established by the SmRs operator.

2. Permit Personal use of commercial systems on non-exclusive “exclusive frequencies
Another alternative would be to consider al lowing personal
Operation on any commercial repeater system, if the permission of the
existing users or repeater manager is obtained. Commercial repeaters, even
if operated on shared channels, are generally managed by equipment suppliers
or service shops, not a collective of ‘individual licensees. The particular
repeater manager should be able to operate in a manner similar to an SMR
operator, making a case-by-case decision as to the compatibility of personal

use of the commercial system.

Occasionally, the situation may occur that the repeater manager

will conclude that more money may be made from leasing a repeater fcr

63 New GMRS two-way mobile radios are typically available for $500-$900.
New 800 MHz trunked SMR two-way mobile radios cost between $900 and $1500.

- 82-


Therefore, any attempt to rigidly define the characteristics of a personal

radio service is likely to be fruitiess.44

CB radio was initially intended as a short-distance 2-way radio
service for utilitarian Personal and family communications, but evolved
instead into a Principally recreational radio service with secondary but
significant use as a travelers information and assistance service. The
current equipment inventory pattern suggests that the latter use may be

assuming increasing importance.

The ARRO survey, which was taken at the height of CB’s popularity,
indicates reasonably high user satisfaction with the service,
notwithstanding adverse Propagation characteristics and congestion.
Subsequent disinterest in the service probably resulted from boredom with

CB as an entertainment medium more than anything else.

Considering the early Stage user satisfaction cited above, the
currently available 40 channels are probably sufficient for the currently
estimated 3,000,000 cB Stations. (This admits that there may be congestion
Problems in selected areas.) Since the spectrum allocated to the CBRS is

not great and is not in demand for other services, and since cases of CB

44 This may also prove to be the case in the Commission’s Proposal

in Docket 86-38 to create a new "Consumers Radio Service" based on equipment
that would prevent undesired operation. If such a service is created with
Operational characteristics annoying to its users, a “state-of-the-art"
CB-type rebellion could consist of replacing the integrated circuits
comprising the "brain" of the equipment with those that do what the user
wants. .


The ARRO conclusions demonstrated the basis for the fad-like
popularity of CB radio. The emphasis on CB as an entertainment medium,
coupled with minimal interest in base-to-mobile communications, suggests
that popular expectations were never very high, particularly with respect to
the mobile characteristics of the service. The most popular form of
communicating with CB radio is to engage in a “party-line" or "round table"
type of conversation. This type of activity is useful in expanding an
individual’s circle of friends; however, because of the complete lack of
security 1n CB communications, more private thoughts cannot really be
expressed for fear of inviting dissenting opinions that may be inimical to
the generally good comradeship that exists among CB operators. Once the
number of friendships established through CB radio has reached a desired
level, the quality of each triendship may require development on a more
private level. Then, too, if CB 18 viewed more or less purely as
entertainment, after a time new ideas encountered through it will become
old, conversations will become increasingly routine, and the service
generally more boring. This is particularly likely if there is a lack of
new entrants into the service due to simple disinterest among much of the

population.

Another factor which may account for the short-term interest in CB
radio 1s station maintenance. While CB transceivers are quite reliable,
CB radio mobile antennas are rather ungainly as antennas go and, like
automotive receiving antennas, subject to vandalism. Proper repair or
installation of a new antenna requires the use of technical equipment and
tuning procedures that are really beyond the ability of the non-technical ly

inclined lay person. Thus, if interest in CB radio has already declined

~- 4B -


limited to, dinter alia, farmers, livestock breeding services, construction
companies (other than those involved in constructing buildings), and
concrete and fuel delivery firms. Now while these are all worthwhile
activities, it is certainly less evident that the dollar value of radio to a
breeding company is comparable to its doller value to a road construction
company (indeed, the value perceived by the same types of users may differ,
as well as the real value to society). Also, there are undoubtedly many
commercial entities eligible only in the Business Radio Service that realize
a value from the use of radio that equals or exceeds the value realized by
the typical special industrial licensee: Thus, the Commission’s decision
to merge the two services as it Proposed in 1957 in Docket 11991 may have
been based on an incorrect determination of value.l] 4 good case might be
made that the two services should be integrated with assignment of the

combined resources being made on the basis of the value licensees expect

11 The Commission was persuaded that the Special Industrial Radio Service
should be retained, that many of its operating restrictions should be
eliminated, but that its eligibility restrictions should be revised to

and not having significant safety problems (see the Report and Order, Docket
No. 11991 (23 Fed. Reg. 4790)). This action illustrates the Commission’s
Policy of attributing particular communications requirements to certain
types of commercial entities and satisfying those needs by the creation of
particular radio services. Once the eligibility requirements for the
services were determined, many equally valuable uses of the spectrum by
similarly deserving but less known users were precluded. An alternative
might have been to to merge the Special Industrial and Business Radio

particular frequencies for long-range or safety communications and permit
their use by any applicant able to demonstrate a satisfactory need.

-14-


Summary of alternatives for regulation of the GMRS

After many years of effective use as an auxiliary commercial
service, the GMRS has experienced a significant increase in personal users,
probably because it is the service of last resort to individuals desiring
quality base-to-mobile communications and because equipment costs have
fallen to the point of affordability by middle-class citizens. Furthermore,
since the availability of the GMRS is unknown to most of the public, there
is potential for considerably more personal growth. Even now, it appears
that the GMRS may be experiencing congestion greater than that in the
Business Radio Service and may deserve an additional spectrum allocation.
Yet, whether or not such an allocation is ‘made, action can be taken to
extend and enhance the GMRS as the only quality personal radio service. The

following recommendations should be given consideration:

1. Prohibit new commercial use of the GMRS and gradually
phase out current commercial use in order to expand the
availability of the GMRS for personal use, but only if
other alternatives permitting an individual’s opportunity
of access to quality two-way radio service do not

appear feasible.

2. Restructure GMRS application procedures to facilitate
personal entry and wore efficient use of the available
spectrum by eliminating the collection of unnecessary
information and by authorizing use of the entire GMRS

frequency band.

-41-



most common rule violations ("Thou shalt not work skip.", etc.).

Increasing disciplinary ems

Growth in the Clase D service was steady through the sixties,
although as the number of licensees grew, disciplinary problems became
increasingly evident. Many licensees concluded that CB had more use as a
recreational radio service and began to ignore the operational restrictions
cited above. The FCC replied to such activity by creating a special
Citizens Band enforcement team in 1969 that was subsequently expanded to
five teams in the early seventies. "Enforcement actions" were conducted in
cities of a significant size on a monthly basis. However, the effect was
generally short-lived, with the levels of violative activity resuming former
levels six months to a year later. The enforcement effort was simply not

able to cope with the large number of licensees.

Docket 20120 deregulation

In 1974, the FCC decided to accede to the popular will and
legitimize the largely recreational character of the Class D service. In a
comprehensive deregulatory rule making proceeding (FCC Docket 20120)
conducted between 1974 and 1980, the FCC eliminated or mitigated many of the
operational limitations. Hobby~type conversations were legitimized, the 5
minute waiting period between communications was reduced to one minute, and
intrastation communications could take place on all frequencies.
Additionally, spectrum between 27.235 and 27.410 MHz was allocated to the
service, increasing the number of channels from 23 to 40. Channel 9 was
reserved for emergency or travelers” assistance communications. The name of

the service was changed from the "Class D Citizens Radio Service" to the

- 45-


The implementation schedule should recognize that individuals do not have
comparable economic opportunities (e.g., amortization of equipment for
income tax deductions) that are available to commercial land mobile
entities. To the extent Possible, economic incentives to accelerate

equipment conversion should be built into the rules.

Interim PMRS Proposed

The PRSG believes that Narrow band technologies, digitized
Speech, trunking and similar measures can yield a high Capacity PMRS,
However, it concedes that these technologies are not yet available and
recommends that Pending their development, an interim PMRS be implemented
and used until about 1995, The interim PMRS would essentially be a
restructured GMRS with continued use of the current narrow band FM

technology. It would require the regulatory changes summarized below.’

First, the PRSG recommends that eligibility to operate in the PMRS
be restricted to individuals. The Commission is urged to preserve the
GMRS/PMRS for those who are genuinely ineligible to operate elsewhere. The
PRSG also recommends that personal use groups (such as REACT) noi be
licensed as Sroups, because individual users sometimes operate under the
group call sign when transmitting purely Personal communications, thus
avoiding the accountability inherent in individual licensing. Most
importantly, the PRSG urges an immediate moratorium on authorizations and

modifications in the GMRS by those not currently licensed as individuals.

Second, the PRSG recommends amendment of current licensing

Procedure so that most users need only complete a simple application form

~70-


15,000,000 licensees in October of 1979. However, the tremendous
congestion, aggravated by extremely favorable long-distance propagation
conditions (which are most unfavorable for local use), along with other
less significant factors, rapidly led to disenchantment with this service.
Even before the licensing of CB stations was discontinued in 1983, the
number of users had declined considerably. On the basis of the trend
existing at that time, the number of interference complaints received in the
1980-1985 timeframe, and the number of CB radios sold during 1985 (estimated
at 2.25 million units), it may be reasonable to estimate that there are

about 2.7 million households using CB radio to some degree today.

The Amateur Radio Service, currently numbering some 415,000
licensees, in both definition and fact is the most complex personal radio
service. Concisely stated, it is a noncommercial service intended to
provide emergency communications, ongoing amateur education, advancement
in the communications art, an expanded technical pool, and enhanced
international good will.6 Most amateur communications are recreational
or educational in nature. It is arguable which is dominant since to a very
large degree the recreation is education in the ARS. Many largely
recreational conversations contain a technical element. Expedient and
emergency communications account for only a small portion of the overall
traffic. Considerable and diverse radio spectrum has been provided by the
Government in the hope of stimulating engineering progress and developing

technical skills. Incentive for advancement is provided through the

6 See 47 CFR 97.1


Reasons for CB"s initial popularity and subsequent decline

There are several speculative conclusions that may be drawn from
the statistics. Since the availability of CB radio was well publicized by
both television and movies, a number of users who may have otherwise been
indifferent to the possibilities offered by two-way radio may have become
licensees under pressure by triends "to be one of the crowd." CB radio, in
many ways, was (and still is) a social activity. In a 1978 report,38 the
FCC’s Personal Radio Planning Group (PRPG) discussed the results of a survey
conducted by the Advanced Research Resources Organization (ARRO) that
identified several significant needs underlying the demand for CB radio.
They included the need tor being entertained by listening to people talk,
aiding others who need nelp, being able to get help in a highway emergency
and getting directions while driving.39 It noted that other needs "such
as being able to talk to one’s home from a car, and telephone
interconnection capability were not as significant."40 ‘hus, the PRPG
report concluded that "Based on this information, it seems that most people
currently need personal radio for highway use and a source of entertainment

rather than as a sophisticated communications tool."41

38 Alternatives for Future Personal Radio Services, Personal Radio
Planning Group, Office of Plans and Policy, May, 197...

39 Ibid., p. 33.

40 Ibid.
41 Ibid.

- 47 -


TABLE OF CONTENTS

Introduction

I.

Il.

Personal Radio Defined and Discussed
The semi-personal radio services
The personal radio debate
The personal radio services

Difficulty in valuing personal communications in the
absence of a marketplace mechanism

Examples of regulation that probably would be inconsistent
with the operation of a communications marketplace

Inadequacy of regulation as a substitute for a
communications marketplace

The General Mobile Radio Service (GMRS)
Frequencies allocated to the GMRS

Mobile relay or "repeater" operation

GMRS service area and modes of operation

GMRS growth

Congestion in the GMRS

Nationwide Unique Call Signs Assigned per Frequency GMRS/BRS
Personal use of the GMRS

The personal use versus commercial use question
License application procedures in the GMRS
Band authorizations in the GMRS

Interconnection in the GMRS

-ii-

Page

10

13

15

18
18
20
20
21

24
28
29
32
34
37


Amateur growth

Graph 3 (on the next Page) depicts the number of amateur licensees
over a 35 year period beginning in 1950. It indicates that the ARS has gone
through alternate high and low-growth periods of moderate duration, and
suggests that absent any significant changes in the service, it may be a
third to half-way into a low Srowth period. Since 1982, the number of
licensees has increased only by about 1100 annually. The graph does not
suggest a likely limit to the number of amateur operators. However, the
high growth rate that took place between 1975 and 1981 coincides with the
"boom years" of CB radio. Perhaps widespread familiarity with cB radio,
followed by subsequent disenchantment and the search for a suitable
alternative, served to stimulate interest in the ARS. If this is the case,
then the growth between 1975 and 1981 may be anomalous. It is possible that
absent the substantial but short~term interest in CB radio, the ARS might be
in a 20 year period of stagnant Browth. While some amateurs may view a
minimal growth rate with satisfaction (since it tends to limit the amount of
congestion), the potential effects of a relative decline in the number of
amateurs relative to the overall population may be cause for concern over
whether the public welfare is thereby being disserved, since amateur radio
Operators represent a significant public service and disaster relief

communications capability.

Concluding remarks

Historically, the ARS has been a personal radio service
principally through its use as a means of individual development of
electronic and telecommunication skills. To encourage personal development,

various classes of Operator licenses are appropriate. However, not all

- 64+


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~ a-


Using amateur radio to place an order for a pizza to be picked up on the way
home from work would similarly be improper. Another common belief is that
it is permissible to advertise over the air that certain equipment is for

sale, provided the price is not mentioned.

The 1983 Order that adopted Sections 97.3(bb) and 97.110 indicated
that "Classic examples of business communications are those which deal with
calling the office from an automobile by way of amateur radio in order to
receive and leave business messages, or with providing a regular

communications service to an employer, a local government or other entity. "46

However, on July 19, 1983, in a letter to Christopher Imlay,
counsel to the American Radio Relay League (ARRL), the Chief of the Private
Radio Bureau noted that he had received many inquiries since the issuance of

the Order, indicating that it had not been as clear as it could have been.

The letter emphasized that the Order "does not prohibit amateur radio
operators from participating in the routine events of traditional public
service activities" and that "amateur radio operators may provide
communications for municipal parades, marathons, walkathons, Eye bank
activities and the like" and that while "(such activities) may incidentally
benefit the sponsor, their main purpose is to provide a service to the
public which is the real beneficiary." The letter goes on to include as

being permissible "public service communications for neighborhood bike

46 Order in the Matter of Business Communications in the Amateur Radio
Service (48 Fed. Reg. 32999, July 20, 1983), para. 2.

-62-



both the communication and technical phases of the art; expand the existing
reservoir of trained operators, technicians and electronics experts; and
lastly, continue and extend the amateur’s unique ability to enhance

international good will.

Classes of operator license

Because the ARS is oriented toward personal development,
incentives are provided to encourage continuing progress. They consist of
six classes of operator/station license: Novice, Technician, General,
Advanced and Amateur Extra. Operating privileges increase with the class of

license.

Thus, the Novice Class licensee (who. must pass a test
demonstrating the ability to receive Morse Code at a rate of 5 words per
minute, familiarity with the ARS rules and regulations, and practical
elementary electronics), may use radiotelegraphy (international Morse Code)
only on a tew HF and VHF trequency bands. No radiotelephony (voice

communication) is currently permitted.

Technician Class licensees must also be able to receive Morse Code
at 5 words per minute. Additionally, they must pass a test on rules,
regulations and electronic theory that is of nominal difficulty. The
operating privileges are the same as the Novice Class, except that
radiotelephony on frequencies in the VHF and higher bands (i.e., frequencies

above 30 MHZ) is permitted.

-55-



important, with user groups being formed to assist in the lobbying effort.
Since some kind of competition for use of the spectrum was necessary due to
its limited availability, it occurred through the persuasive abilities of
the lobbies and their legal representatives. The usual approach to
obtaining spectrum generally avoided attempting to quantify benefits, and
instead, emphasized various qualitative differences between the uses
proposed by the contending parties. Inevitable distortions and inequities
xesulted.!2 This same condition exists today, although its effects are

somewhat ameliorated by the Commission’s ongoing deregulatory effort.13

The Commission’s notice and comment rule making procedure poses
particular problems for personal radio due to the absence of an effective
public lobby.!4 The few citizens groups that exist have rather specialized

(and therefore small) constituencies and find it difficult to participate

12 For a more thorough discussion of this and similar weaknesses
characteristic of the traditional (notice and comment rule making
proceeding) federal regulatory process, see the introduction to The
Regulation Game by Bruce M. Owen and Ronald Braeutigam, pp. 1-42, Ballinger
Publishing Company, Cambridge, Massachusetts.

13 See, for example, the Report and Order in PR Docket No. 84-109
(Amendment of Part 90 of the Commission’s Rules to eliminate permissible
communications restrictions in the Private Land Mobile Radio Services), 50
Fed. Reg. 6179, February 14, 1985, which eliminated restrictions on
permissible communications of licensees with exclusive-use frequency
assignments, but not those of licensees operating on shared frequencies
(concern had been expressed that unrestricted communications on shared
frequencies would aggravate frequency congestion).

14 The argument may be made that the Commission should take the role of
public advocate. However, the Commission is expected to be impartial and
objective in its allocation of spectrum, so it is inappropriate that it
should be biased in favor of any particular interest group, including
personal radio users.

~16-



ongoing communications and waiting for them to be completed, if necessary,
before initiating new transmissions, not engaging in mutually antagonistic

practices.

However, there are cases where repeaters are used for both
commercial and personal communications. In many cases, separate personal
and commercial systems coexist on a given channel with relatively few
problems. This may be due to compatibility arising from the circumstance
that many commercial users are active only during working hours, when
personal communications are generally at a minimum. This leaves the channel
free for personal use during the evenings and weekends. From the personal
use perspective, compatibility may be optimum when commercial users do not
transmit during the commuting hours, when personal use is likely to be most

intensive.

The considerable increase in personal use of the GMRS over the
last decade and the history of additional allocations to the Industrial
Radio Services, often at the direct expense of the GMRS (see the discussion

on Frequencies allocated to the GMRS, above) or personal radio generally

(e.g., the decision in Docket No. 83-26 not to create a new personal radio
service at 900 MHz), appears, on the basis of equity, to make a case for

restricting commercial use of the cmrs.30 If the Commission decided to

30 Such a restriction would not be without precedent. Until 1958,
eligibility in the GMRS was limited to those not eligible for an
authorization in any of the other private land mobile radio services. See
the references on GMRS eligibility requirements in the Appendix.

-31-


after some variable period of exposure, a broken antenna may provide the

incentive to drop out altogether.

The foregoing is offered merely as a plausible explanation for the
declining popularity of CB radio. Obviously, many other factors will be
operative. While the ARRO study indicated general licensee satisfaction
with the CBRS, the variable interference level contributes to the
unreliability of service, as would congestion in more densely urbanized
areas. In any event, the decline in number of licensees was dramatic, even

before the FCC discontinued CB Licensing.

Delicensing of CB radio

On April 27, 1983, in its Report and Order in Docket No. 82-799,
the FCC decided to discontinue licensing of CB and radio control stations.
This was done principally to ease the administrative burden on the FCC,
although the Commission pointed out that the license had little intrinsic
value since eligibility restrictions were minimal, and the license was
available upon mere declaration. Accordingly, the requirement for station
identification was deleted, although the rules "encourage" users to identify
with any pre-assigned FCC call sign, operator initials followed by zip code,
name, or where relevant, organizational description.42 The use of
"handles" or pseudonyms was permitted in conjunction with any of the

just-described means. This delicensing was opposed by the majority of those

42 See Section 95.417(b) of the Commission’s rules.

- 49 -


non~exclusive use basis.18 ‘These UHF (460 MHz band) frequencies are among
the most desirable for land mobile operation and provide superior service,

although at a new equipment cost five to eight times higher than the CBRS.

In the period 1957-1968, various rule makings (principally,
Dockets 11991 and 13847) reallocated the Citizens Radio Service spectrum
to the Public Safety, Industrial and Land Transportation Radio Services 80
that only 4% of the original 1947 allocation of 10 MHZ (460-470 MHZ) remains
today. Subsequent spectrum reallocation proceedings (Dockets 18261 and
18262) allocated considerably more UHF (800 MHz) spectrum to land mobile
services other than the GMRS, and the recent release of the "reserve"
spectrum in Gen. Dockets No. 85-1231, 1233 and 1234 similarly made no

provision for the cmrs.19

18 Frequencies (in MHz) allocated to the GMRS:

Base/Mobile Control/Mobile
462.550 467.550
462.575 467.575
462.600 467.600
462.625 467.625
462.650 467.650
462.675 467.675
462.700 467.700
462.725 467.725

19 The GMRS, per se, was apparently not considered for an allocation,
since it was never mentioned in the referenced proceedings. However, the
question was raised as to whether it would be feasible to permit some of the
reserve spectrum to be used for a new personal radio service outside of
major metropolitan areas. Ultimately, however, this question was decided

in the negative.

-19-


declining cost of Portable equipment .61 Demand for the CRS is equally
uncertain. Thus, any restructuring of the GMRS should Provide for the
evolution of a communications marketplace that will enable the GMRS
(whatever its future name might be) to better reflect the desired cost and

quality of two-way personal comunications.

——

61 A new, low-end (two watt, one to four channel) 460 MHz portable radio
("walkie-talkie") can be obtained for less than $400. Similar mobile units
cost $50. to $100, more, probably because their output power is somewhat
higher (six to fifteen watts).

~ 80 -


should be no reason to delay appropriate reform of the GMRS, including

examination of the possible benefits of interconnection.

Interconnection capability would enhance operational flexibility
and could be useful at times when no one is available at the base or control
station, and there is need for a person in a mobile unit to obtain some type
of assistance, or has urgent need of particular information. Even in
personal systems where all users monitor the channel, situations may occur
where there are no users that can make a local telephone call to obtain the
service or information desired. In such cases, interconnection capability

can greatly facilitate individual activity or the public welfare.

Technical flexibility in the GMRS
Because there have been no substantive rule makings relating to
operation in the GMRS in recent years, it lags behind many of the other land

mobile radio services in terms of technical flexibility.

Permitting the operation of low power (2 watts or less transmitter
output power) systems on “offset frequencies" (frequencies offset by 12.5
kHz from the normally assigned channels) would add 7 new channels to the
service that could be useful for a variety of short-distance communications

functions .36

36 Such operation is currently permitted in the Business Radio Service
and many other Industrial Radio Services. See 47 CFR 90.267.

- 38 -



3. The frequencies 462.6125 and 462.6375 should be made available to all
GMRS licensees for low power, non-repeater communications;

4, Each operating point should be capable of transmitting and receiving on
the 462 MHz frequency of the assigned channel pair(s); and,

5. A “trustee” should be responsible for each repeater, with general use
pase/fixed /mobile station authorization implemented in order to simplify

GMRS licensing.

The rationale provided in support of these changes was similar to
that described above relating to the interim PMRS proposals. This petition
was dismissed April 16, 1986, by letter of the Chief, Private Radio Bureau,

who indicated that it would be treated as a comment on petition RM-5058.

Consumer Radio Service proposed

On January 30, 1986, the FCC adopted a Notice of Inquiry
concerning the creation of a new “Consumer Radio Service” (CRS).°! The new
CRS would replace the GMRS and permit individuals to contact each other over
short distances for the purpose of conducting a brief voice conversation.
The belief is expressed that the new service will be useful to campers,
hikers, cyclists, commuters, shoppers, travelers, public service
organizations (such as REACT) and others, where "the need is for personal
directed communications as the only possible means of contact between

people."52 The Commission further states that "the use best suited to

51 See the Notice of Inquiry in the "Matter of Creation of a new Consumer
Radio Service", PR Docket No. 86-38, (51 Fed. Reg. 5212, February 12, 1986).

52 Ibid. at paragraph 5.

-75-


IV. THE AMATEUR RADIO SERVICE

To reiterate the definition made in the first section, a personal
radio service is one that is used for personal development or to facilitate
the activities of an individual. The Amateur Radio Service (ARS), which was
created principally as a means of personal development, is properly

considered a personal radio service.

Initially, amateur radio was an informal association of inventors
and experimenters interested in radio as an art in itself. Radio was first
an experimental, then a developmental activity. The early experiments
increased individual knowledge. Imagination quickly foresaw important uses
for the new science. First, maritime radio evolved to enhance the safety
of life at sea. Broadcasting and other uses of radio soon followed. Ina
real sense, amateur radio was the "mother" of the other radio services,
nurturing them in the early decades with continual advances in

communications technology.

Definition of the Amateur Radio Service

Section 97.3 of the FCC’s Rules defines the Amateur Radio Service

as a radiocommunication service of self-training, intercommunication and
technical investigation. Section 97.1 states that its basis and purpose is
to: Recognize and enhance the value of the amateur service to the public as
a voluntary noncommercial communications service, particularly with respect
to providing emergency communications; continue and extend the amateur’s
proven ability to contribute to the advancement of the radio art; encourage

and improve the service through rules which provide for advancing skills in

- 54 -



Personal communications needs is a critical component to design of a
restructured GMRS" and that "most of the personal commmnications needs we
have discussed (as mentioned above) would be most suitably addressed by a
service providing two-way voice communications between persons with
transceivers carried on the person."'53

!

The Commission is clearly mindful of its unsuccessful struggle
with the public over the nature of the CBRS, for it next states that "rather
than relying upon operator discipline and significant levels of Commission
enforcement to prevent interference and achieve rule compliance, we could
require equipment that would control users” actions automatically."54

Ba

To further clarity its proposal, the Commission notes that "we
envision units carried’ dp. the person for short-distance, low-power
Communications that would, if they were readily and inexpensively available,
assist people in the conduct of everyday living."55 The Commission
indicates that while the new CRS is not intended to duplicate those
services which provide for vehicular mobile radios, there would be nothing
to prevent a person from carrying a CRS unit into a vehicle, and that such

a unit would allow people to have flexibility in the use of the equipment.

53 Ibid., paragraph 6.
54 Ibid.
55 Abid., paragraph 7.

~76 -


The anomalous number of users on GMRS frequency 462.675 is due to
its popularity as a personal use channel. Most early personal use systems
were established on this frequency and over the years personal users have
put greater effort in securing this channel for their use. It is also

widely used by REACT-type groups and is a de facto emergency use channel in
curs .23

The figures for the BRS suggest that equipment suppliers (who
usually select frequencies for their clients), working with the frequency
coordinator for that service (NABER), are evenly distributing licensees among
the available channels. The average number of licensees per channel in the
sample is 1447 and the maximum deviation from this is 83. In GMRS, which
has no frequency coordinator, the average number of licensees per channel
is higher at 1811, but the maximum deviation is 1246 if 462.675 is
considered, and 460 if it is not. Based on these sample statistics, the

GMRS appears to have some 25.2% more licensees per frequency than the BRS.

However, the number of users alone is an insufficient indicator
of use. The number of mobile units per licensee also must be considered.

The number of mobile units has traditionally (though sometimes

23 The acronym "REACT" stands for Radio Emergency Assistance
Communications Team. Initially, these were groups of Citizen’s Band
licensees who regularly monitored CB Channel 9 for emergency and motorist
assistance requests. Many of these groups now use the GMRS for intra-team
communications and sponsor many of the personal use GMRS repeaters. Most of
their operations are 462.675 MHz, so it has become the de facto GMRS
emergency channel. CB Channel 9 continues to be monitored by these groups.

-25-


I. PERSONAL RADIO DEFINED AND DISCUSSED

This section discusses the concept of personal communications and
personal radio services. The personal radio services that will be
subsequently studied are briefly discussed. The difficulties in determining
the value of personal radio services relative to commercial radio services

are also noted.

This essay defines personal communications as those communications
principally intended to enhance the activity of the individual. In order of
probable importance, they include the following categories: emergency
communications, expedient communications (i.e., communications intended to
make the performance of activities more efficient), educational
communications and recreational commmnications. A personal radio service is
a radio service intended to provide for one or more of these categories of

personal communications.

The semi-personal radio services
There are a number of radio services which are personal in nature

that, while not the subject of this study, deserve brief mention.

The common carrier services are semi-personal in nature because,
while they are used extensively for personal communications, services and
rates are set on the basis of overall market conditions. A carrier’s
favorable response to the unique circumstances or unusual service
requirements of an individual is unlikely. The individual has minimal

impact on the day-to-day management of the service.


utilization process, or because the rules preclude the licensee’s use of
the additional channels so-created, then the value of service that would be
provided by the new technology to that licensee (and indirectly, to society)
is likely to be reduced. Thus, incentives may be required to encourage use
of new technology in a shared frequency enviroment so as to maximize the

value of radio service.

One such possible incentive would be to permit users currently
sharing a single channel to divide it into exclusive-use channels if
possible, with a guarantee that no new licensees will be authorized the use
of the exclusive-use frequencies except pursuant to an agreement with the
existing licensees. Thus, current service users would acquire a property
right in their service that would enable them to subsequently manage their
frequency in accordance with their own best interest.37 The success of
incentives for implementing the use of new technology will probably be
related to the degree to which they vest current service users with a

tangible say in the future of their radio service.

37 Such a plan would appear to require the implementation of some minimum
cochannel and adjacent channel separation criteria in order to prevent the
exclusive use channels from being further degraded by nearby authorizations
involving the use of the older technology. Any short-spaced assignments
existing at the time of conversion to the new technology would probably also
need to be "grandfathered." See Implementing New Technology in the Land
Mobile Radio Services, an Office of Plans and Policy staff report by Philip
B. Gieseler (September, 1983) for additional discussion relating to the
implementation of property rights in shared-use radio services.



among members of the general public, a different regulatory approach to the
Problem may be desirable. This study suggests regulatory changes intended

to develop a more comprehensive and competitive land mobile communications

marketplace.

A brief overview of the current Personal radio services is
Provided and characteristics that may reduce their ability to contribute to
the resolution of the personal radio problem are identified. Possible
short-term regulatory changes are suggested, as are longer-term inquiries,

some involving the non-personal land mobile radio services.


"20 foot rule" applicable to most control stations at this time.32  1¢ the
same proviso was made with respect to what might be termed a "small
base/control station", most GMRS application forms could be considerably
simplified with a concomitant decrease in application Processing time. The
resulting convenience would need to be weighed against the Precision
Provided by knowing exact base station coordinates;- but since the GMRS is
Not a frequency coordinated radio service, and because a grant would be made
in any case, the lack of such information would appear to pose no

significant problem.

Band authorizations in the GMRS

Another change consistent with the foregoing recommendation on
application procedure would be to routinely authorize GMRS licensees to
operate on any available frequency in the service, rather than a specific
frequency or frequencies. Similarly, the Commission should reconsider

whether or not it should be concerned about authorizing specific areas of

32 Under the "20 foot rule" applicants proposing to use control stations
that will have antennas less than 20 feet above the supporting structure
(other than a tower), currently need not provide the FCC with detailed
geographic information about the control station.

~ 34+


to derive from it.

The same conclusion may be valid with respect to other commercial
radio services. While the activities of all of those eligible to operate in
the various Part 90 radio services conduce to the public welfare, the
benefit derived from creating a multiplicity of radio services with unique
frequency allocations is less evident. Also, even if the rationale for
creating those services was valid at one time, it may not be today, since
technology has provided more usable spectrum and minimized early differences
in equipment performance in the various frequency bands. Thus, there is
reason to believe that in the absence of a method whereby prospective radio
users can demonstrate the value they place on radio (an effective
communications marketplace) the Commission’s traditional decision-making
process (the notice and comment rule making proceeding) has served as a
substitute of disputable success. Had such a marketplace been in place at
an early date, there might have been much greater integration of the various
land mobile radio services and additional opportunity of access for personal

users.

Inadequacy of regulation as a substitute for a communications marketplace
The creation of the various radio services and eligibility
restrictions is due to the fact that over time, certain. then-ineligible but
potential users of two-way radio successfully persuaded the Commission to
allow them access to part of the spectrum. In the absence of an explicit
spectrum market, this had to be done by convincing the Commission that their
use of the spectrum was uniquely necessary for the good of society or more

worthy than some competing alternative use. Political effectiveness became

-15-


creation of various operator license classes which link operating privileges
with technical knowledge and Morse Code operating skill. Limitations on
the use of this service are few, and consist principally of some
restrictions on the types of permissible communications that are intended to
ensure the noncommercial, experimental nature of the service. Since large
segments of the population are unlikely to be interested in radio as an
object in and of itself, the Amateur Radio Service, while a legitimate

Personal radio service, will always have a somewhat limited appeal.

Difficulty in valuing personal communications in the absence of a
marketplace mechanism

The determination of the value of personal communications (or a
Personal radio service) compared to commercial communications (or a
commercial radio service) is not easy in the absence of a marketplace
mechanism (i.e., a system that requires each user to pay some price for the
privilege of communicating).? Consider the following purely hypothetical

example:

An employee is returning to the office after making a delivery.
Personnel at the office become aware that goods ordered by the company have
arrived at a location close to the employee and use two-way radio to request
their pick-up. The value of this exchange of communications to the

commercial entity is approximately the value of the time saved by the

7 See OPP Working Paper #2, Frequency Spectrum Deregulation
Alternatives, by Douglas W. Webbink, October, 1980, p. 10.

-10-



Ill.

Iv.

Technical flexibility in the GMRS

Summary of alternatives for regulation of the GMRS

The Citizens Band Radio Service (CBRS)

Creation of the CB Radio Service

General Description

Restrictions on permissible communications

Increasing disciplinary problems

Docket 20120 deregulation

Growth

Reasons for CB’s initial popularity and subsequent decline
Delicensing of CB radio

Current number of CB users indirectly estimated

Conclusion

The Amateur Radio Service (ars) :
Definition of the Amateur Radio Service

Classes of operator license

Restrictions on "business" communications in the ARS
Amateur growth

Concluding remarks

Pending personal radio proposals

PR Docket No. 86-161 (Expanding the privileges of
Novice Class amateur operators)

- iti -

38
4

43

43
44
45
45

47
49
50
51

54
54
55
61
64
64

66

66


level of difficulty would naturally object to rule changes that would have
the effect of making access to their operating privileges easier. This
attitude, while understandable, is nevertheless unreasonable and it acts to
inhibit meaningful restructuring of the service consistent with current
circumstances. Another obstacle to worthwhile reregulation may be based on
the belief of current licensees that otherwise inappropriate barriers to

access should be retained in order to inhibit frequency congestion.

Restrictions on "business" communications in the Amateur Radio Service
Limitations on so-called "business communications" in the ARS may
also discourage its use tor communications that facilitate personal

activities, thereby turther discouraging new entry.

For example, Section 97.110 of the amateur rules states that "The
transmission of business communications by an amateur radio station is
prohibited, except for emergency communications as defined in this part."
Section 97.3(w) defines emergency communications as "Any amateur
radiocommunication directly relating to the immediate safety of life of
individuals or the immediate protection of property." Section 97 .3(bb)
defines business comunications as "Any transmission or communication the
purpose of which 18 to facilitate the regular business or commercial affairs

of any party."

These rules have led to some confusion over what constitutes a
“business communication" in the ARS. Some amateurs believe that to use
amateur radio to call a towtruck for a stranded motorist is improper because

amateur radio would be used to financially benefit the towtruck company.

-~61-



Mobile relay or "repeater" operation

More than 90% of GMRS stations ordinarily operate in what is
called the mobile relay or repeater mode, where mobile stations and
“control" stations (fixed stations at the licensee’s home or place of
business) communicate through a well-situated base station ("repeater") that
receives communications on the upper frequency of the channel and
simultaneously retranemits them on the lower frequency. The mobile relay
station itself is rather expensive ($1000.00 to $5000.00 depending on age,
quality and availability of supplemental features). Many (particularly
those used by commercial licensees) are operated as “community repeaters"
by an equipment supplier or service shop.20 Personal use repeaters are
often sponsored by a club or several individuals. Many GMRS repeaters are
located at choice antenna sites where there may be a monthly fee for space
and utilities. Thus, even if the system is operated as a non-profit,
cost-sharing cooperative, service is often only available on a subscription

basis.

GMRS service area and modes of operation

A typical mobile relay station (having an antenna height 150 to
300 feet above average terrain) will have a service area radius of 15 to 25

miles. Well sited repeaters (those with antenna heights in the vicinity of

20 The term “community repeater" denotes a repeater used by more than one
licensee. It may also connote use of different transmitter access tones by
different licensees, so that they will not routinely hear each other’s
communications. Many personal systems use only one such access tone so that
communications are readily heard by all. However, there is no requirement
that this be the case. A single access tone could be used on a “community
repeater" and multiple tones could be used on a personal repeater.

- 20-


attempted, may have a high Probability of failure, Instead, it suggests
that the personal radio problem may best be resolved by further deregulation
of the existing land mobile radio services in an effort to create a more
competitive land mobile communications marketplace that would include

Personal users,

The personal radio services
Currently there are three major personal radio services: the
General Mobile Radio Service (GMRS), the Citizens Band Radio Service (CBRS),

and the Amateur Radio Service (ARS).

These services are Personal in the sense of being used principally
for one or more of the four categories of personal Communications
(emergency, expedient, educational and recreational), and because the
stations themselves are managed by individuals, Even in cases where the

responsibility for Station operation is shared (such as in the management of


of unique system call signs, as discussed below.

Congestion in the GMRS

The GMRS was compared to the Business Radio Service (a general use
commercial radio service with operational characteristics similar to those
of the GMRS, and whose principal lobbyist, the National Association of
Business and Educational Radio (NABER) has been effective in securing
additional spectrum for its use through the years) to roughly determine
whether the GMRS (which has no comparable organization) might be expected to
merit an additional frequency allocation. The comparison was made by making
a computer search of GMRS and Business Radio Service (BRS) frequencies for
the number of different call signs authorized per frequency on a nationwide
basis. The base station side of the frequency pair is the best indicator of
the number of licensees, since most licensees are expected to operate on
that frequency, and since there is typically one station per system on that
frequency. Nevertheless, in cases where multiple stations (e.g., a base and
a mobile station in a single frequency simplex system) resulted in the same
call sign being listed twice in the license record count, the repeated call
sign was ignored. Thus, the tally should closely reflect the number of
actual licensees or users per frequency, although the number of total
service users will be somewhat uncertain, since some licensees are
authorized to use more than one channel, and a small number of licensees may
be authorized mobile-only operation on the mobile side of the frequency

pair.

The small size of the GMRS made it possible to examine every

available channel, so the number of call signs shown is very close to the

-23-




a combined amateur/personal radio service operating in this spectrum. Such

a service might generate additional interest in the ARS.

4. Restructure the Amateur Radio Service for more accessible personal
operation

The 144-148 and 420-450 MHz amateur bands feature widespread
direct and repeater communications of @ conversational nature. The
Commission may wish to inquire into the feasibility of permitting extensive
personal communications in all or part of these bands, with members of the
household of a licensed amateur operator being permitted to operate that
amateur’s equipment for home-to-mobile (or portable) communications, even if
the licensed operator is not present or not a party to the conversation.
All such communications would be identified by the call sign of the
authorized amateur operator, who would have ultimate responsibility tor
proper use of the station. Interstation communications by such unlicensed
operators need not be permitted, though there may be cases (particularly in
emergencies) where they may be desirable. The operating discipline that is

characteristic of the ARS may be sufficient to minimize abusive operation.

The cost associated with this approach is a potential shift away
from the experimental/instructional communications of the ARS to more
expedient communications, or purely recreational communications.
Nevertheless, such a change in the fundamental nature of the ARS would still
be in the hands of the amateurs who, in charge of this communications
activity by members of their households, would be able to initiate
appropriate action needed to maximize the overall value of their service

(e.g-, such type of operation might be confined to less desirable frequency

~ 85 -


"repeaters"? ), the needs expressed by individual users are likely to be

given consideration.

The General Mobile Radio Service, currently numbering some 14,500
users, is the smallest personal radio service. It is a private land mobile
radio service intended primarily for short-distance two-way personal and
business communications.3 It is principally used for expedient communica-
tions by personal and commercial users. While recreational communications
by personal users are permitted, their percentage of overall traffic is
small. ‘The service offers eight paired 462/467 Miz channels. Mobile relay
or repeater use is common. The quality of service in the GMRS is similar to
that of the other shared commercial land mobile radio services. Thus,
compared to the CBRS, it is quite excellent. Many GMRS personal users

are former (sometimes current) CBRS users. However, since there are

2 The terms "mobile relay" and "repeater" are used synonymously in this
report. They indicate a station that receives communications on an input
frequency (usually the upper frequency of the frequency pair) and
simultaneously retransmits them on the output (lower) frequency. Such
stations are generally located on mountain tops, tall buildings or other
similarly favorable places in order to maximize their service areas.
“Control stations" (often inaccurately referred to as "base stations" by
their users) are immobile stations located at the office or home. They may
be in a generally unfavorable radio location, but as long as they can
communicate with their associated repeater (which they must be able to do),
then they are able to communicate with any other station (principally,
mobile stations or units) within range of the repeater. Both control and
mobile stations transmit on the repeater’s input frequency and receive on
its output frequency. Thus, they generally cannot communicate directly
with each other (i.e., without the repeater), which is a disadvantage of
this type of system. Often, mobile units are equipped to transmit on the
repeater output frequency and can thus communicate directly with each other
over short distances. Control stations cannot legally be so-equipped.

3 See 47 CFR 95.1


used to implement this objective. Thus, the service would be as
self-regulating as possible.

Docket 83-26 Report and Order

The Commission stated that "After weighing a number of factors, we
have concluded that traditional private land mobile and cellular systems, as
well as a mobile satellite service, must take priority over a personal radio
service." However, the Commission did indicate that it was soliciting
comments in two other proceedings (General Dockets 84-1231 and 84-1233)
concerning the feasibility of sharing land mobile and cellular allocations
with a personal radio service in areas outside major population centers; but
pointed out that such geographic constraints would make the service
unavailable to one-third of the population, potentially threatening its
economic viability, and requested comment on whether personal operation in
urbanized areas could be effectively precluded. Ultimately, these proposals
were not adopted.

PR Docket No. 86-38 Notice of Inquiry

Inquiry into the desirability of transforming the GMRS into a new
“Consumers Kadio Service."

Less significant actions (1980-1985):

During the pendancy of the Docket 79-140 and 83-26 proceedings,
the Private Radio Bureau declined to act on any petitions that would
significantly alter the status quo in the GMRS. Various petitions relating
to the GMRS were therefore dismissed. However, several rule making actions
of a relatively non-controversial nature were completed.

Order implementing system licensing in the GMRS (June, 1980).

The principal benefit of this action was ease in station
identification since one call sign, rather than three, was assigned to each
system. Also, the license application procedure was rendered somewhat
easier through the use of one application form, rather than the three
required previously.

Order dismissing petition RM-3830 (request to provide for radio linking of
remote GMRS repeater receivers on GMRS offset frequencies) on the basis of
uncertain interference potential to regular GMRS operations (1981).

Order denying petition RM-2425 (a proposal to add/delete repeater users by
license attachment and to amend the signal strength standard for control
stations), March, 1982.

In response to the first concern the Commission proposed the use
of a temporary operating permit that enabled new users of established
repeater systems to operate pending receipt of a regular license by
identifying with the letters "WI" followed by their telephone number. The
signal strength proposal, which requested that the long-standing policy
requiring control station signal strength to be not more than 6 dB greater
than the signal strength of a mobile unit at the same location be replaced

- 90 -



with a requirement that control station power be limited to that necessary
to obtain a specified amount of "quieting" at the repeater’s receiver, was
rejected because of the high power that could conceivably be required under
such an arrangement.

Order eliminating the requirement that Part 95 licensees have a current copy
of the rules and regulations (August, 1982).

Report and Order adopted 2n PR Docket No. 82-184 providing for the use of
the Temporary Operating Permit in GMRS for a period of up to 180 days,
subject to the availability of a suitable form (January, 1983). The
Commission announced the availability of Temporary Operating Permit, Form
574-T, September 26, 1983.

Memorandum Opinion and Order denying a PREG request for oral argument before
the Commission in the matter of elimination of the requirement that Part 95
users have a current copy of the rules and regulations (January, 1983).

Notice of Proposed Rule Making in PR Docket No. 83-330 Proposing a 10 year
license term in the GMRS (March, 1983).

Report and Order in PR Docket No. &2~84 concerning update and recodification
(revision into “Dlain language") of the GMRS rules (August, 1983),

Letter by the Chief, Private Radio Bureau, dismissing petition RM-2895 (a
Proposal to allow GMRS licensees the use of any of the available channels
and to limit the number of mobile units operated by commercial users to 6 or
less). (October, 1983).

Order dismissing petitions RM-4179, RM-4180 and RM-4592 on the basis that
they were premature in light of the pending proceeding concerning the
creation of the PRCS (December, 1983). (RM-4179 requested that licensees in
the GMRS be able to use any of the available frequencies. RM-4180 and
RM-4592 requested permission for GMRS stations to interconnect with the
telephone network.)

Recent Studies Relating to Personal Radio

Alternatives for Future Personal Radio Services, by the Personal Radio
Planning Group (PRPG), FCC Office of Plans and Policy (May, 1978).

The principal focus of this study was on CB radio and the creation
a new service of a somewhat similar nature. The study recommended no single
response to demand ror personal radio communications. Rather, it Proposed
8ix alternatives for Commission consideration in the event the Commission

decided that the creation of a4 new personal radio service was appropriate.

The Personal Use Radio Advi) Sory Committee (PURAC) Report (April, 1978).
PURAC, an FCC-chartered committee composed of interested

communications industry Professionals, personal radio users and FCC
Personnel, was formed in 1976 and in April, 1978, issued a three volume

~91-


4(A) Intermediate amateur practice and radio theory.

4(B) Advanced amateur practice and theory.

AMATEUR CLASS REQUIRED ELEMENTS
Novice 1(A) and 2

Technician 1(A), 2 and 3

General 1(B), 2 and 3

Advanced 1(B), 2, 3 and 4(A)
Extra 1(C), 2, 3, 4(A) and 4(B)

The point should be emphasized that an amateur license consists
of both an operator license and a station license. It is issued to an
individual and that individual may not further delegate the operating
authority to another person (except that one amateur may operate another’s
station, subject to the limitations of the operator’s license). Thus,
members of a family may not operate the amateur radio equipment of another
member unless they are in his or her presence. For amateur radio to be of
any use in facilitating family activities, several (if not all) of the
family members would need to be licensees. Thus, while the ARS provides
much in the way of communications capability, its use as a personal radio
service will generally be very limited because only a relatively small
percentage of the population would want to study the regulations and theory
(and learn the Morse Code) necessary to meet the eligibility requirements
(license class examination elements). However, currently there are about
415,000 amateur licensees. This number has remained relatively constant in

recent years.

-5s7 -



races, fireworks displays and the Olympic games." It concludes by saying
that "we can all agree that a businessman, who also happens to be an amateur
radio operator, should not use amateur radio facilities to call his office
about details that surround his business transactions. On the other hand,
the same businessman should feel free to use his amateur radio station if a
member of the family becomes ill, if there is a safety factor in traveling

on the highway, such as the need for a tow truck, etc."

Thus, while using amateur radio to call a towtruck appears
permissible, no such “safety factor" would pertain to ordering a pizza,
making a motel reservation while traveling, or many other utilitarian uses
of amateur radio. Yet in none of these cases would the amateur directly
intend that the communications benefit a commercial entity. Mentioning or
discussing the price of a piece of equipment, while possibly conducing to
the financial gain of an amateur (although incurring an actual loss may be
just as likely), may also be warranted as an incidental activity conducive
to the overall welfare of the service, in that it may facilitate the
acquisition of desired equipment. Neither would such use of the ARS appear
to significantly affect its experimental nature. Amateurs should not have”
to resort to questionable mental gymnastics in order to rationalize
essentially innocuous communications. Of course, since the ARS is also
an international service and subject to international regulations, there may
be limits to the extent of its further deregulation in the area of
permissible communications. Nevertheless, ongoing review of the rules and
policies relating to permissible communications is necessary to ensure their

clarity and applicability to current operating practice.

-63-


interstate highway would certainly be willing to pay something to use a
radio to call for a towtruck rather than to waste time walking miles to the
nearest telephone. More commonly, it should certainly be worth something
to a person to be advised by radio (on the way home from work) that certain
groceries are needed, rather than to arrive at home, only to find out that

that a subsequent (and possibly longer) trip is necessary.

Again, the dollar value of the Personal communication just cited
may be difficult to determine objectively. More important is the
individuals recognition of its value and willingness to pay some type of
compensation. The value of two-way radio is a judgment best made by the
radio user, whether commercial or personal, who should at least have the

opportunity of purchasing the desired communications capability .?

Ideally then, the Commission should continue to develop a

framework within which commercial and Personal radio users can express the

9 This is not intended to suggest that potential radio consumers have
some right to have their communications requirements satisfied at
unrealistically low prices. But if they are willing to pay fair market
value for a particular communications capability, they should be
accomodated. Also, while the example just cited deals with expedient
communications, recreational communications will also have some value. What
one person is willing to pay for expedient communications may be less than
what another is willing to pay for recreational communications. Regardless,
third-party judgments on the relative value of various types of communica-
tions may be unreliable and form a poor basis for deciding frequency
allocations or deciding whether or not to create new radio services.

~12-



report on the state of personal radio.

Volume 1 dealt with the state of user rule compliance in the CBRS
and recommended the implementation of ATIS and much more rigorous
enforcement of the rules in order to discourage recreational communications
and make the CBRS more utilitarian.

Volume 2 principally addressed ancillary facets of personal
communications such as the need for better operator training, disseminating
information, interference, electromagnetic compatibility, technical
standards and public safety uses of personal radio. However, a section also
addressed future personal use radio communications needs, recommending that
the Commission implement a viable VHF-FM "Personal Mobile Radio Service"
that would ve relatively noise~free and have the capability for direct-dial,
automatic trunking and selective calling, as well as other features that
might enhance rule compliance (such as ATIS, busy channel lock-out and
time-out devices).

Volume 3 was dedicated exclusively to restructuring of the GMRS.
It recommended changing the name of the GMRS to the "Personal Mobile Radio
Service", that recreational and point-to-point (fixed station)
communications be prohibited, that licensing be simplified, that offset
frequencies be made available, that open accessibility to repeaters be
encouraged, that time Limits be placed on communications, that
interconnection be prohibited except when used to facilitate emergency or
traveler’s assistance communications, that a standardized selective calling
protocol be adopted and that an aggressive user education program be
established. Relevant ancillary recommendations were also made. PURAC did
not recommend that commercial entities be precluded from operating in the
new service, but expressed confidence that such users would relocate
somewhere else when they perceived the rapid growth in personal use.

OPP Working Paper 6, Alex Felker and James Brown (August, 1981).

This report detailed the general characteristics of the Amateur,
CB, Remote Control and General Mobile Radio Services. Other semi-personal
tadio services were also discussed, such as the Maritime Radio Services, the
Rural Radio Telephone Service and the Common Carrier Services. It
recommended exploring the feasibility of using spread spectrum and
decentralized trunking in a 900 MHz personal service. Suggestions for
improvements in the current personal radio services were also made.

Additionally, Working Paper 6 favored the implementation of a new
personal radio service at 900 MHz~ preferably a mix of amateur and personal
users (at least in part of it) in order that more members of the public
might be attracted to the Amateur Radio Service. The report envisioned
competition between the new personal service and cellular service, perhaps
with sharing of some frequency bands so that either systems could be readily
adapted to changing customer demands, technologies and economic conditions.

- 92 -



effectively in the rule making process. Comments of individuals may not be
given much weight due to uncertainty as to how representative of the
majority they are. In fact, anything other than a very general consensus of
public opinion may be difficult to obtain. As a result, the Commission has
relied heavily on the opinions of the communications equipment manufacturers
for guidance on personal communications matters. Occasionally, these
manufacturers lend some support to personal radio proposals.15 However,
communications policy (personal or otherwise) ideally should not principally
depend on the success of a lobby or the support of an equipment
manufacturer; but rather, on providing opportunities for all potential

spectrum consumers to satisfy their needs.

An intermediate objective, or means to this end, is the
development of a flexible two-way radio communications marketplace in which
all who have a need for two-way radio can participate. Such a marketplace
would solve the problem of determining the value of personal communications
relative to commercial communications by providing communications
alternatives that impose an appropriate cost on the desired quality of
communications for both personal and commercial radio users. In this way,

the value of two-way radio services will be maximized.

15 General Electric initially petitioned the Commission to adopt its
Personal Radio Communications Service (PRCS) proposal, but announced its
withdrawal from that program just prior to the Commission’s decision on the
service. Other equipment manufacturers had questioned GE’s ability to
deliver PRCS radios at the low prices it had initially projected.

-l7-


reason why the other land mobile services have migrated to higher
frequencies as soon as technology permitted. Congestion is also a problem,
although users engaged in casual conversation are generally willing to let
a user with a more utilitarian need have immediate access to the channel.
All operation is in the simplex mode, with each user alternately
transmitting and receiving on the same frequency. Generally, the Citizens
Band Radio Service "...is, in effect, a reservoir for all radio uses not

provided for in other services." (1960 FCC Annual Report, p. 84).

Restrictions on permissible communications

Initially, many of the rules relating to operation in the Class D
service were restrictive in the hope of fostering the discipline necessary
if such a limited amount of spectrum was to be used on a wide basis. There
were restrictions on permissible communications intended to ensure that all
communications were expedient in nature. Communications of a "hobby"
(conversational) nature were prohibited, as were those "technical"
(amateur-like) in nature. An exchange of communications could not last more
than 5 minutes; then the licensee would have to wait 5 minutes before
transmitting again to ensure that all licensees had reasonable access to
the available frequencies. Intrastation (base-to-mobile) communications
could be conducted on any frequency, but interstation communications were
permissible only on a few frequencies. Restrictive antenna height
limitations were adopted to preclude the need for FAA tower coordination
and to limit station service areas. “Skip working” (an almost continual
temptation in view of the long-distance propagation characteristics of the
27 MHz band) was also prohibited. Many of the more conscientious licensees

posted a copy of the "10 Commandments” of CB operation, based on the ten

- 44 -



APPENDIX

REFERENCE MATERIAL ARRANGED BY SUBJECT

Greation of various Industrial Radio Services.

Report and Order in Docket 9018 (13 FCC 1224) creating inter alia, the
Special Industrial Radio Service in 1949.

The Commission indicated that it based its decisions on the need
for creation of the various land mobile radio services and their various
classes of eligibles on the following criteria: 1.) Did the service really
require the use of radio? 2.) Services necessary for the safety of life or
property deserved more consideration than those more in the nature of a
convenience or luxury. 3.) Which service would benefit the greater m
of people? 4.) Where in the spectrum should the service be located? 5.)
In the event of competing claims to the same spectrum, the Commission would
consider the number of transmitters and receivers already in use, the
investment of the industry and the public in equipment, and the cost and
feasibility of converting to different frequencies. 6.) The effect on
achieving international standardization of maritime mobile service
allocations.

Notice of Proposed Rule Making in Docket No. 11991 (22 Fed. Reg. 2593,
April 16, 1957) that, inter alia, proposed terminating the Special
Industrial Radio Service (SIRS) by including its users in a new Business
Radio Service having considerably expanded eligibility requirements.

Report and Order in Docket 11991, Industrial Radio Services-Changes in
availability of trequencies, (23 Fed. Reg. 4790, June 28, 1958).

The Special Industrial Radio Service Association (SIRSA) and
others successfully argued that the SIRS should be retained, that
eligibility tor use of the service should be revised with a view to
eliminating access to the service by many persons not having long-range
communications requirements or significant safety problems, and that the
frequencies allocated to the service be increased (para. 41). The
Commission agreed, stating that (it) "had studied the above comments in the
particuler light of the indisputable need of business generally for mobile
radio tacilities, of present usage and requirements within the Special
Industrial Radio Service, and of the administrative difficulties it has
experienced with respect to the latter service and has concluded that, at
least temporarily, the above consensus should prevail" (para. 42).

GMRS Eligibility Requirements

Order, "Licensing and administrative aspects of the Citizens Radio Service",
Docket No. 119 (14 Fed. Reg. 15%, April 5, 1949).

1954 FCC Annual Report, pp. 81-82.

- 88 -



base station frequency suggests an intention to use the more spectrum
efficient "repeater talk-around" mode of operation, where mobiles
communicate directly with each other on the base station frequency without
using the repeater. The data suggest that up to 45.2% of the BRS mobile

units and 67.5% of the GMRS mobile units may be so-equipped.

If we let the density of use be the number of licensees per
frequency times the number of mobile units, then we get a figure of 16206
(1447 x 11.2) for the BRS and 24630 (1811 x 13.6) for GMRS. Thus, if all
other operational characteristics of the two services are considered equal,
(which seems likely25 ) the congestion in the GMRS may be 52% greater than
the BRS. This is admittedly a rather simplistic comparison of the two
services, and it is intended to be suggestive rather than definitive in
nature. Nevertheless, absent the availability of information that would
suggest otherwise, the difference in congestion in the two services appears
to be significant. In conclusion, it appears that if the social cost of
congestion in the two services is similar and an additional frequency
allocation is considered necessary for the BRS, then a similarly appropriate

allocation should also be considered for the GMRS.

25 The number and length of communications exchanges could be a
differentiating factor. However, a reason for assuming a significant
difference between the two services is not readily apparent. Even

the fact that more lengthy interconnected communications are permitted in
the BRS, but not the GMRS, may be counterbalanced by the somewhat more
garrulous nature of GMRS personal communications. One-way paging is also
permitted in both services on the general use frequencies. On balance, the
two services appear quite similar, except for the personal use element in
the GMRS.

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value they attribute to the use of spectrum. 10 However, this has not been
the case. In the absence of an effective land mobile spectrum marketplace,
traditional regulation has favored the creation of various radio services
with specific (and restrictive) eligibility requirements based on the idea
that certain activities are more valuable than others, and that the FCC is
the best judge of the value of those activities. Effective arguments can be

made that this may not be the case.

Examples of regulation that probably may impair with the operation of a
communications marketplace

Consider the Business and Special Industrial Radio Services. The
Business Radio Service is available for the use of any commercial entity,
educational, philanthropic or ecclesiastical institutions, clergymen,
hospitals, clinics and medical associations. Operation in the Special
Industrial Radio Service (which because of its eligibility restrictions has

often been perceived as less congested and therefore more desirable) is

10 Any method that imposes an appropriate cost is likely to reflect the
value the user attributes to the communications service. Typical examples
are repeater use fees, SMR mobile unit charges and paging service fees.
However, absent better opportunity of access to communications services
(which generally is limited by eligibility requirements and certain
operational restrictions in the various services), these types of user fees
are likely to be artificially low. A currently unutilized method of
determining service value would be to hold a spectrum auction that would
require prospective users to pay some up-front access fee for the use of
spectrum. This would require both commercial and personal users to be more
aware of the value of radio to themselves and others. For a comprehensive
discussion of the value of spectrum auctions, see OPP Working Paper #16,
Using Auctions to Select FCC Licensees, May 1985, by Evan R. Kwerel and
Alex D. Felker.

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interference to other services are declining (about 58,000 cases in 1980
compared to about 33,000 in 1985), there is no apparent reason why CB should

not continue unchanged as a recreational/traveler’s radio service.

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VI.

RM-5058 (Restructuring the GMRS into a new
"Personal Mobility Radio Service")

GMRS restructuring evaluation criteria
Interim PMRS proposed
Description of the finalized PMRS

RM-5242 (Short-term restructuring of the GMRS to
enhance personal use)

PR Docket No. 86~38 (Consumer Radio Service proposed)

Conclusion

Other Alternatives for Personal Communications
1. Permit personal use of SMRS systems

2. Permit Personal use of commercial systems on
non-exclusive frequencies

3. Allocate spectrum in the 900 Miz ISM band or the
1.215-1.300 GHz band for Personal use

4. Restructure the Amateur Radio Service for more
accessible personal operation

5. Allocate 460 MHz Spectrum from the Industrial
Radio Services to the GMRS

Conclusion

Appendix (References)

Creation of various Industrial Radio Services
GMRS Eligibility requirements
Recent Personal Radio Regulatory Actions (1978-1985)

Recent Studies Relating to Personal Radio

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67
68
70
73

74
75
79

81
81

82

84

85

86
87
88
88
88
89
91


Conclusion

The preceding recommendations vary from the traditional (e.g.,
frequency reallocation) to the innovative (e.g., those that would further
develop a land mobile communications marketplace). Together with the
suggestions offered 1n previous sections, they offer a variety of regulatory
approaches that may be taken to satisfy the demand for quality personal
communications. However, the better recommendations pertain to the
development of a more effective land mobile communications marketplace that,
in turn, will better relate the cost and value of communications services.
Such a marketplace exists, but at a less than optimum level of effectiveness
due to systematic exclusion of potential communications consumers and the
continuation of service categories and eligibility restrictions that in many
cases have probably become outdated. The need to resolve the personal radio
problem affords an opportunity for a more comprehensive re-evaluation of all
of the private land mobile radio services to ensure that their value to

society is being maximized.

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take no other regulatory action favorable to personal radio, such a
restriction might be justified on the basis that since personal users have
access to such a small amount of land mobile radio spectrum, they should not

have to compete with commercial users for its use.

However, such an action would be inconsistent with the regulatory
objective of promoting a more competitive communications marketplace
through greater opportunity of access and greater operational flexibility.
Essentially, the Commission would be asked to foster the personal use aspect
of the GMRS by denying entry to commercial entities, some of whose use is
likely to be highly compatible with personal use. Imposing such a
restriction would be a typical example of Commission regulation in the
absence of service value information that would be available from an
effective communications marketplace. Excluding commercial users from the
GMRS would be unnecessary if alternative means of satisfying demand for high

quality two-way personal communications were found.31

License Application Procedures in the GMRS
A potential barrier to individual entry into the GMRS is the need
to use FCC Form 574 in applying for a license. As mentioned previously,

the Form 574 is the principal land mobile system application form used in

31 Meeting this demand should not necessarily entail restrictions on use
of the GMRS, the creation of some new "wonder service", or any single
“solution” to the personal radio problem. Rather, the solution should be
sought along the lines of fine-tuning regulation of the existing two-way
radio services to ensure that personal users have an opportunity of

access comparable to that of commercial users.

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First Report and Order, "Revision of Part 19, Citizens Radio Service",
Docket No. 11994 (23 Fed. Reg. 2739, April 24, 1958).

Further Notice of Proposed Rule Making, "Reducing separation between
asignable frequencies in the 450-470 Mc/s band", Docket No. 13847 (32 Fed.
Reg. 13975, October 7, 1967).

second Report and Order, Docket No. 13847 (33 Fed. Reg. 3115, February 17,
968).

Recent Personal Radio Regulatory Actions (1978-1985)
PR Docket 79-140 Notice of Inquiry, (June, 1979).

Proposed creation of a new "Personal Radio Service" in the 900 Miz
band. It requested information on desired performance characteristics of
the new service, licensing procedures and the extent of the necessary
frequency allocation. Comments were also requested on its proposed impact
on other services.

Docket 79-140 Report and Order, (January, 1983).

Affirmed PRPG and PURAC conclusions that a new Personal radio
service was needed to meet current and future personal needs; and that the
most significant personal need was for directed communications from a motor
vehicle operator to specific other parties for Personal, business-related
and/or emergency communications. The Commission indicated that it was
persuaded by che record that unfulfilled communications needs of the public
did exist and that a new Personal radio service that would primarily provide
for directed communications from vehicles at a cost the average person can
afford, merited further consideration.

Docket 83-26 Notice of Proposed Rule Making, (January, 1983).

The Commission proposed a new Personal radio service in the 900
MHz band along the lines suggested by General Electric in its comments in
Docket 79-140. Thus, it was Proposed that the new service be named the
Private Radio Communications Service (PRCS). Users would be able to
communicate with their own or other PRCS users directly over distances of up
to 5 miles. Interconnection would be permitted, but only at the users
Premises (home). An exchange of communications would be time-limited to 3
minutes except during periods of light congestion. Repeaters would be
authorized, but not permitted to link together to cover wide areas, as in
cellular systems. No license would be required to operate in the new
service. Those wishing to Sponsor repeaters, however, would be licensed.

rather than the operator.

The primary objective of the new service would be to permit the
Sreatest number of simultaneous conversations with little or no action
necessary on the part of the operator (in selecting frequencies). A
combination of centralized and decentralized trunking techniques would be

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operation .33 Many times, GMRS licensees will be traveling through areas
far from home. The ability to contact any nearby licensee for directions or
roadside assistance could be very useful and clearly enhance operational
flexibility. The chances of obtaining assistance would be increased if
users were able to try to make a contact on all eight GMRS channels. This
type of capability would not necessarily be inconsistent with the proposed
requirement that users make prior arrangements for the use of mobile relay
stations since most personal use systems are listed in PRPG’s annual
Personal Use Directory on the condition that their systems be available for
use for short periods by travelers or others requiring emergency assistance.

Thus, permission for such short-term use is effectively given in many cases.

Another reason for a band authorization is the ge facto nature of
462.675 MHz as the GMRS emergency channel. While personal users operate on
all available GMRS channels, the number on any particular channel may be

quite small in a given area. Clearly, the chances of obtaining needed

33 These operational restrictions are typical of those adopted many years
ago when, in the face of spectrum scarcity, the Commission required
applicants to thoroughly justify their proposed use of a sought-after
frequency. There was a disciplinary advantage associated with this policy;
namely, that if licensees had the use of only a single frequency (or at
least, very few frequencies), they would be forced to cooperate with their
co~channel neighbors in an attempt to optimize its use. If many frequencies
were available for use, it would be more difficult for a licensee to be
aware of the operational patterns and needs of other users. This could
result in inconsiderate users driving others off their particular channel,
creating a de facto exclusive frequency assignment, to the detriment of
those licensees who were willing to cooperate in the effective use of the
available spectrum. It is difficult to say whether the value of any radio
service is optimized by regulations of this kind. The benefits derived from
potentially more disciplined use of the spectrum mst be weighed against
those lost by being unable to use the radio service to satisfy a greater
variety of needs.

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