A Change to Our Arizona Repeater Network, and a Call to Action

A message from David Adriaanse, WQVS960, AZ License Holder, Southwest Community Radio System

In Reference to: https://docs.fcc.gov/public/attachments/DA-26-821A1.pdf

Dear members:

I want to be straight with our members about something happening in the GMRS world, and a decision I’ve made because of it in our Arizona territory.

Recently, the FCC issued a Notice of Violation to another GMRS operator over their internet-linked repeater network, alleging that the practice exceeds what the rules allow. I’ve followed this closely, and I believe there’s a real, defensible legal argument that the rule the FCC is relying on doesn’t actually say what they claim it says. But “defensible” isn’t the same as “certain,” and this is playing out against operators (some reckless, some not) in a way that makes the whole practice of linking a target nationally, regardless of how responsibly any individual group has run it.

We’ve always tried to be the kind of organization that gets ahead of what’s coming rather than reacting after the fact. Because GMRS spectrum is limited to just 8 repeater channels, we’ve stayed vigilant and proactive about coverage overlaps and channel congestion — regularly restructuring our sites and configurations to provide the best overall value to the GMRS community at large, not just our own members.

This has taken several forms: distributing spectrum usage surveys to all GMRS users and other enthusiast groups within our coverage areas (not just our members) and adjusting ourselves based on those, disabling linking on repeaters where coverage is largely redundant, working with sites that naturally shield each other’s coverage due to topography, configuring linking-on-demand in areas with higher spectrum utilization which self-resets after non usage, and voluntarily taking on the technical challenges of developing single-frequency simulcast (not multicast) systems in populated areas — all to avoid monopolizing the airwaves beyond genuinely reasonable use and be good stewards of the band we share with others.

I’ve been monitoring the regulatory environment around linked GMRS networks for almost a decade on this matter, and this recent enforcement action confirmed to me that it was time to make the shift proactively rather than reactively. So, effective Sunday night, August 9 (after that evening’s regional net) I am disabling remote modulation on the repeaters operating under my license here in Arizona. This wasn’t an easy call, a lot of you rely on and enjoy that connectivity, myself included, especially in the particular remote areas we are blessed with in this state but where cell service doesn’t reach. But, I’d rather make this change on my own terms, deliberately, than have it forced on me later.

Let me be unambiguous about why: this is risk control, not an admission of fault. I think the FCC’s current interpretation of its own rule is bogus – asserted as if it were the text of the rule when it plainly isn’t. Nothing about this change should be read as agreement that my prior configuration was unlawful. It’s a judgment call about where to spend my energy and my risk tolerance right now, not a concession that anything SWCRS or I have done is or was wrong.

The Rules, As They Are Actually Written

Source: Code of Federal Regulations, Title 47, Part 95 Subpart A and Subpart E

To be clear about my position: remote control of a GMRS station is remote control, plain and simple. Remote receive, remote carrier detection, remote transmit, remotely modulated audio: these are all facets of one thing, operating a station from somewhere other than where the transmitter sits. That’s what “linking” actually is. The FCC’s Notice of Violation submitted to NGGMRS cites § 95.1749 as the basis for the alleged violation. Here’s what that rule actually says:

Operation of a GMRS station with a telephone connection is prohibited, as in § 95.349. GMRS repeater, base and fixed stations, however, may be connected to the public switched network or other networks for the sole purpose of operation by remote control pursuant to § 95.1745.

That’s the entire operative scope of the rule. First off there is no interconnection with the telephone system involved here, and secondly it doesn’t limit “remote control” to any specific subset of control functions, doesn’t distinguish receive from transmit, and doesn’t say anything at all about audio content – the definition addresses only where the control operator is located, not what is carried over the link. The FCC’s Notice now asserts that “remote control” excludes carrying audio content between stations, but that limitation doesn’t appear anywhere in the rule’s actual text. It’s the Bureau’s opinion, asserted as if it were the rule. I think that’s a meaningful distinction, and I’m not conceding it by making this change. For reference, and in contrast with the NOV’s claimed narrow scope of Remote Control, § 95.303 actually defines remote control as:

Remote control: Operation of a Personal Radio Services station from a location that is not in the immediate vicinity of the transmitter. Operation of a Personal Radio Services station from any location on the premises, vehicle or craft where the transmitter is located is not considered to be remote control.

That’s odd – operation of a station away from the transmitter’s own premises inherently requires a two-way conveyance of audio back and forth, would it not? If “remote control” is understood to allow that basic two-way link at all, it’s difficult to see a principled reason it would permit only control signaling and telemetry but not audio, when both are required for remote operation.

The NOV also leans on the idea that GMRS is meant to be “short range” or “local only,” and that linking is fundamentally inconsistent with the service’s purpose — arguing that “the service only works as intended when local users can hear each other and cooperate in the sharing of channels,” and that linking “enables the retransmission of messages over much larger geographic areas.” Neither the rule text nor the reasoning behind it supports that.

§ 95.1703’s actual definition of the service describes it only as “a mobile two-way voice communication service, with limited data applications, for facilitating activities of individual licensees and their family members, including… voluntary provision of assistance to the public during emergencies and natural disasters.” No distance limitation, no “local” requirement, nothing about range at all — and arguably, assisting with public emergencies and disasters is proven as enhanced by linking as we’ve done it. The familiar “one to twenty-five mile” range figure comes from the FCC’s own consumer-facing website, not the CFR. It’s a general expectation-setting description, not a codified limit — the same pattern as the “remote control” argument above: an informal FCC characterization standing in for something the actual rule doesn’t say.

The FCC’s reasoning also doesn’t hold up there on its own terms.

A single, standalone repeater, no linking involved at all, exists specifically because stations can’t hear each other unaided; that’s the entire premise of a repeater. If “local users hearing each other unaided” were really the standard, no GMRS repeater of any kind would be permissible, since every repeater already extends range beyond what stations could otherwise reach. This is where the Southwest’s geography matters, and where I don’t think the people writing and enforcing this policy have much firsthand sense of what they’re regulating: due to elevation and terrain, a single unlinked repeater in this region commonly achieves reliable coverage out to 100 miles or more in some directions — natural reach that already dwarfs the FCC’s own informal 25-mile guidance. A policy built around assumptions that fit dense, low-relief terrain elsewhere in the country doesn’t map cleanly onto ours. If the Commission’s real concern is geographic reach, that concern already exists at the level of a single repeater out here; linking doesn’t introduce it.

It’s also worth a brief note on a related rule the Notice doesn’t cite: § 95.1733(a)(8) separately bars messages conveyed by a “wireline control link.” Our backhaul is overwhelmingly wireless IP connectivity, not a wireline circuit – and the FCC’s own two-decade-old distinction between “wireline” and IP-enabled services (from its 2004 Vonage Order) supports reading that term the way the Commission itself has always used it. This isn’t the rule at issue in the current Notice, and I suspect its omission is intentional because of it.

Why I’m Not Fighting This Right Now

I want to be clear with the membership about my reasoning here, because it isn’t that I think the FCC is right.

First, the practical reality: fighting this properly – through counsel, through a formal response, potentially through appeal – costs real money and real time and never truly absolves all risk, and that burden falls on the individual holding the license, myself, not the SWCRS organization as an abstraction. I’d rather put that energy into keeping this network reliable for our 1,700 members than into a prolonged fight over a rule I expect to change anyway regardless of if my interpretation would be deemed correct or not.

Second, and more importantly: I believe the FCC is very likely to open a formal rulemaking on this issue at some point in the near future, precisely because the current rule text remains ambiguous as-is; the FCC has only formalized its stance with this Notice, not necessarily made it enforceable as a settled matter. When that happens, I expect the national GMRS community’s comments to push the Commission toward resolving the ambiguity, likely by writing a rule that says plainly what linking may or may not include, closing the exact gap we’ve relied on. I’d rather not spend resources defending a reading of the rule that I expect the rulemaking process itself to settle, one way or another, in the near future. It is better to put my effort into adapting our group ahead of that outcome than into a fight over language I don’t expect to survive unchanged in the long run regardless.

To be clear about the flip side: if that eventual rulemaking clarifies the rule in all our favor, confirming that remote control includes no control limitations, we will restore this configuration as it was, without hesitation. This change is a response to present uncertainty, not a permanent retreat from a position I believe remains correct.

That said, given where enforcement is heading nationally, I’m choosing to narrow my operations voluntarily rather than wait for the FCC to draw the line for me. Going forward, systems under my license will focus on local control functions and site health monitoring, with the ability to enable or disable a site remotely as needed, consistent with the FCC’s narrower interpretation published in the NOV. I’ll share more detail on the specifics as this transition is finalized.

I am not turning off emergency traffic monitoring and alerting functions, although it will be substantially more restrictive and difficult to call up for the average user as a result of this change and response to the FCC’s stance on the matter. This capability has, on multiple occasions, allowed us to catch and respond to incidents that would otherwise have gone unheard on our more remote repeater stations. This isn’t theoretical, it has directly contributed to saving lives, and in a true emergency, that’s all that matters. That’s not something I’m willing to give up nor do I feel I need to, and I intend to preserve it within whatever configuration keeps me on solid legal ground going forward.

Why I’m Also Doing This

It’s worth saying plainly: a rule that eliminates linking outright would be a true disservice to folks out here. The vast distances and public land we contend with in the Southwest are a different world from what’s likely familiar to the people writing and enforcing these rules from DC and the other easternly field offices. Despite the substantial coverage Arizona’s topography affords, a single, unlinked repeater’s footprint makes no guarantee that anyone else is monitoring: several repeaters serving remote areas of our state have 100-mile radius footprints with usually nobody monitoring the repeater except through remote-control links. This isn’t a convenience question, it’s a coverage-gap question, in places where that gap can be the difference between someone being heard and someone not being heard at all in a time of need.

Longer term, I believe the FCC is likely to issue new rules that address linking directly – probably a few years out, after a public comment period. I am genuinely worried that period will be dominated by the recklessness of a handful of larger, higher-visibility networks nationally, making it easy for the Commission to simply prohibit linking outright rather than write something that distinguishes responsible, community-based use from the bad actors. I’m not willing to bet the existence of this network on how that plays out. I’d rather build toward ground that isn’t shaky – which increasingly means our amateur radio infrastructure, where linking is unambiguously permitted under Part 97. Expect to hear more about growing that side of the network in the near future.

What You Can Do

Maintain our Community

The majority of our repeaters each have their own community, with the connections between them going quiet; I encourage you all to find those local to you and keep using the equipment. Let us know if it’s not working right, find who else keeps an ear on them, and put together your own local nets – if you want to be formally listed on our website for these nets, all you need to do is shoot me an email: wqvs960@swcrs.org

Raise your Voice

I’ve already reached out to my representatives, and I hope you do as well, regardless of where you stand on the matter.

The FCC is a federal agency, and Arizona’s congressional delegation can raise concerns with the Commission on behalf of constituents. If this issue matters to you, particularly if you live somewhere GMRS is a real public-safety lifeline, not a convenience, I’d encourage you to reach out to your representative and senators.

Arizona’s U.S. Senators (statewide):

• Senator Mark Kelly
• Senator Ruben Gallego

New Mexico’s U.S. Senators (statewide):

• Martin Heinrich
• Ben Ray Luján

Arizona’s U.S. House Delegation (by district):

• AZ-1 — David Schweikert
• AZ-2 — Elijah Crane
• AZ-3 — Yassamin Ansari
• AZ-4 — Greg Stanton
• AZ-5 — Andy Biggs
• AZ-6 — Juan Ciscomani
• AZ-7 — Adelita Grijalva
• AZ-8 — Abraham Hamadeh
• AZ-9 — Paul Gosar

New Mexico’s U.S. House Delegation (by district):

• NM-1 — Melanie Stansbury
• NM-2 — Gabe Vasquez
• NM-3 — Teresa Leger Fernandez

Not sure which district you’re in? Use the official lookup tool at house.gov to find your representative, and contact both senators’ offices directly through senate.gov.

Sample message you’re welcome to use or adapt:

Subject: Support Needed — FCC Enforcement Threatens Responsible Rural GMRS Infrastructure in Arizona

I’m a constituent and member of the Southwest Community Radio System (SWCRS), a grassroots, volunteer-run, nonprofit GMRS communications network serving rural Arizona.

The FCC recently issued a Notice of Violation to another GMRS operator (DA 26-821, released August 5, 2026), citing 47 CFR § 95.1749, over linking repeaters to extend coverage. Even though SWCRS believes the rule doesn’t actually prohibit this, our Arizona license holder voluntarily disabled that functionality rather than wait for enforcement to reach us — a responsible, good-faith decision.

That compliance comes at a real cost. In rural Arizona, cell coverage is often nonexistent, and our linked network has been a proven public-safety resource, directly contributing to saving lives by catching emergency traffic that would otherwise have gone unheard.

I’m asking your office to raise two things with the FCC:

First, that the Commission reconsider its current interpretation of 47 CFR § 95.1749, rather than waiting years for a rulemaking to resolve the ambiguity.

Second, that the FCC recognize responsible operators like SWCRS through its existing waiver process (47 CFR § 1.925). We survey the GMRS community and conduct coverage analysis to avoid channel congestion — the exact stewardship the FCC’s own spectrum-scarcity concerns are meant to protect. A waiver would let rural Arizona keep this capability while rulemaking plays out.

A blanket rule treating reckless commercial operators the same as transparent, community-run safety networks would be a real loss for communities like ours. I’d appreciate your office’s engagement with the FCC on this, and I’m glad to provide more information if helpful.

Thank you for your time and representation.

I’ll keep members updated as this develops. Thank you for your patience and understanding as I navigate this – this network exists because of this community, and every decision we make is with that in mind.

Sincerely,

— David Adriaanse, WQVS960 / K6DSA