Tuning In: March 2002

Half-Baked Ham

By Harold Ort, N2RLL, SSB-596

One of the interesting things about our government is that you never know just what they’ll do next. Yes, they work for us — on paper at least, but for the most part I’ve come to believe that although human beings work “there,” the “there” allows “them” to take on some strange, out-of-step-with-reality form that neither your nor I can recognize, except when they issue an edict or respond to a rational, well-thought-out request from those they serve. Strange, isn’t it that we’ve come so far with technology, yet when it comes to the people aspect and decision-making in the 21st Century, in many ways we’re still swinging from tree branches.

So, I wasn’t terribly surprised the other day when, once again, my official Washington BS Meter went off scale. Many of you will remember years ago when the FCC officially designated CB Channel 9 as the “official” emergency channel. Sure, they did a dumb thing by putting a “citizen’s” radio band in an area of the radio spectrum that supports worldwide communication and then in the same breath made it illegal to talk “skip,” but that aside, their hearts and bureaucratic brains were in the right place by finally making Channel 9 the official emergency channel. During its heyday, thousands of calls were taken and countless lives were saved because of the selfless efforts of unpaid volunteers handling calls for assistance (and yet, amazingly the FCC recently refused to relinquish the 155-mile communications limit on CB when it comes to working emergency calls — RM-9807 — essentially thumbing its nose at today’s CB radio volunteers) on the nationwide emergency channel.

FRS To The Rescue

The number of Americans using those little Family Service (FRS) radios to stay in touch around the home, at the mall or on vacation has skyrocketed in the past couple of years. They’re so popular — and inexpensive — that many families are buying one for each of the kids; they offer crystal clear communication up to a mile or so, it’s license-free, and they’re small enough to fit in a shirt pocket or purse. Many even offer a selective calling feature, and alert tones that can be programmed to “ring” when another user in your group wants to talk with you. All in all, they’re pretty nifty stay-in-touch gizmos in our very wireless world.

There’s currently no provision for selecting or informing people about using one of the 14 VHF FRS channels for the calling/emergency channel. While it’s certainly true that the original concept of FRS was a short-range communications tool for families and friends to stay in touch, there have been numerous instances where these little half-watt marvels have indeed saved lives. In some cases it has, frankly, been sheer luck that the call was heard — not because of the low power of the FRS unit, but because other radio users just happened on the channel the person calling for help was using. Recall for a moment, the citizen’s radio service where the famous Channel 9 exists, not just on paper, but on many radios as well. Push a button or flip a switch, and you’re instantly at the emergency channel, where on any given day your chances of getting help are a whole lot better than picking another CB channel number out of a hat and calling for help. It’s common sense that monitors should know where to look for emergency calls.

When Alan Dixon and Bob Leef petitioned the FCC (RM-10019) back in 2000 to establish FRS Channel 1 as the official emergency calling channel I really thought the FCC would look at it as an opportunity to do the right thing — the common sense thing. Key words: common sense. But, once again I was wrong.

Some days I really believe there are people serving us in Washington (and even locally in government for that matter) that aren’t drinking the same water we’re drinking. You know what I mean? You and I sit down with our families and talk about our day and helping others, fixing problems and working toward some common goal. Then there’s the “other world,” unseen by us regular folks, where they’re quite possibly still eating their baked beans and Lucky Charms with their fingers. (I saw it firsthand in the Army — frequently at the field-grade officer level — that scary look that tells sane humans there’s a DNA problem somewhere. You’re honest, sincere, you speak English, your lips move and they see you, but they hear and see something else — something only they can see.

A Classic Example

I’ve never met the FCC’s Kathleen O’Brien Ham, Deputy Chief, Wireless Telecommunications Bureau, but I’m sure she’s a well-meaning, nice person. Personally, I don’t think she could distinguish an FRS radio from a roll of duct tape if it were labeled with neon-glow letters. I call it the DolanPloog Syndrome. Those that know me will understand. (If you don’t, please bear with me, substitute your own odd name, and laugh anyway). Dixon’s and Leef’s original petition sought to amend Part 95, Subpart B of the FRS rules to establish 462.5625 as a National Calling Channel in order to, as their petition stated, “To better facilitate communications involving personal safety, traveler’s assistance, and emergency communications, and to enhance the functionality of the Family Radio Service.” Pretty decent request, I’d say. Even though it was submitted to the FCC in October 2000, a full year before the tragic events of September 11, 2001, Ms. O’Brien Ham’s denial was adopted December 5, 2001 (and released two days later), a full three months after 9/11. Chalk it up to another missed opportunity at the FCC, and a chance to wave the flag — not just Old Glory, but a unity flag, saying, “we’re in agreement with Alan and Bob, that there are so many of these radios out there, what a grand time to come together and recognize that emergencies can happen anywhere, anytime, and ANYTHING we can do to help people, we should do.” Nope, once again, the DolanPloog syndrome takes over, and we’re given the following explanation from Ham: “The Commission noted that because the universe of potential users of the FRS is the American public, it believed administration of the FRS should be accomplished primarily through establishing transmitter technical standards rather than complex operating rules.”

Can Ham explain what would be so complicated about merely informing FRS users that FRS Channel 1 would have been set aside as a national calling/emergency channel, and that it shares a common bond with the General Mobile Radio Service (GMRS) by the FCC’s own rules (GMRS — FCC Part 95, Subpart A) allowing for monitoring and communications between FRS and GMRS units, should an emergency occur? In their petition, Dixon and Leef note that, “ . . . the establishment of FRS Channel 1 as a calling channel imposes no burden on existing FRS users since all existing FRS radios capable of Channel 1 operation may continue their normal, routine operation on said channel, yet may immediately utilize the channel as a calling channel, and . . . future design and manufacture of FRS radios capable of multichannel scanning with Channel 1 as the priority scan channel will open new equipment marketing opportunities for manufacturers.”

It only seems logical (oops, there I go again!) that with the 14 available FRS channels and with the 38 CTCSS squelch codes offering a possible combination of 532 communications channels to establish contact, that in telling the public, “OK, folks, if you need help or wish to call another unit, we’d recommend using Channel 1 with no programmed CTCSS privacy tones because you’ll greatly increase you chances of making that necessary contact.” Period. Their petition required no action on the part of manufacturers, although let’s face it, future FRS radios (the FCC themselves has left open additional operating modes other than standard FM), could incorporate a simple red-colored Channel 1 pushbutton which would certainly get folks’ attention if they’re thinking about emergencies. Remember, families buying these radios for staying in touch and for safety reasons!

So, let’s look at the rest of Ham’s explanation (and frankly one has to wonder if she’s operating unilaterally, not just because of this decision, but a couple of others as well) for her denial. I’m also not sure Ham actually thoroughly read (or understood) the petition because in her denial she says, “As noted above, the Commission previously considered whether, as a transmitter technical standard, to require manufacturers to include certain specific features in FRS units. We disagree with the petitioners that additional FRS transmitter technical or operational rules are needed.”

Did I miss something or did Ham? The petition is NOT asking for any new “transmitter technical standard.”

She further says, “The petition has not established that the current technical rules are inadequate in some way or that the purpose of transmitter technical standards is not being met.”

You’re kidding, right? Let’s go back to the original petition for a moment and read it together. In their summary, the petitioners said, “A common calling channel, with standard, default carrier-operated squelch use, and standard Frequency Modulation (FM) F3E emissions would immediately enable rapid emergency contact for all FRS users with no retrofit or obsolescence of existing multichannel FRS radios.” It seems to me that if the rule had existed in the first place, the petitioners wouldn’t have filed their request, right?

Now, her next sentence, in Section Number 8 is most troubling and probably direct evidence that what I’ve said for years is true: There’s something funny going on in Washington; the air, water, and Twinkies or cheeseburgers aren’t made of the same things as those in the rest of America. Ham says, “ . . . we believe that such a channel in the FRS is unnecessary given that FRS is intended to be used by small groups of persons and that the transmissions from FRS units would be receivable only over a very small area. For these reasons, we do not believe that establishing FRS Channel 1 as a universally recognized common calling channel is necessary or consistent with the purpose of the FRS.”

I remember years ago — and perhaps you do too — how the FCC held onto those CB rules vehemently stating over and over how people engaging in long-distance communications and even conducting “hobby-like” communications on CB was “inconsistent” with the rules and regulations. Nevertheless, it took many years for the FCC to do an about face, finally allowing the use of “handles” and hobby radio communications.

Later, in Number 11, Ham says, “We also disagree with the Petitioners’ claim that the proposed rule changes would impose no measurable burden on any party concerned. To the contrary, the proposed rule changes would impose a burden on manufacturers of FRS units because a manufacturer would have to design its FRS unit to include specific new features and capabilities that are not mandated by the Commission rule today.”

Not so, Ms. Ham. Once again, was the original Petition even read and understood? I think not. The Dixon and Leef petition said that “ . . . this petition seeks immediate official recognition of the use of default carrier-operated squelch as the proper operating technique for those stations wishing to monitor FRS Channel 1 for calls from any other FRS station . . . seeks immediate official recognition of the use of standard Frequency Modulation F3E voice modulation . . . as the proper operating mode for those stations wishing to initiate contact on FRS Channel 1 to other FRS stations.”

Clearly, the petition doesn’t seek to require folks to use Channel 1, nor does it seek to require manufacturers to really do anything. All they asked was a little common sense and caring, and what they got was a door slammed in their face. Ham’s inaccurate interpretation of the request and therefore, inaccurate Order is unfortunate at a time when people are up to their ears with bureaucratic mumbo-jumbo.

Ham, in speaking for the FCC, apparently shares that steadfast near death-grip on those FCC rules and regulations, and an absolute reluctance to rewrite them once they’re established. I seriously would have thought that even they would have become more sensitive to peoples’ needs after September 11. I see I was wrong.

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