[MRIC] RACES 72-hour rule

[BrettHam at aol.com]

Maryland RACES Officers:
 
Please find below the complete exchange between the FCC and I to clarify  the 
debate we had earlier this year at MRIC about whether or not RACES  drills 
exceeding one hour require state (MEMA) approval. The short answer  is that a 
drill over 1 hour does requires MEMA approval. Please see details  below if you 
are interested. Feel free to share this with others, but please do  not edit 
it or excerpt parts. Keep the comments in proper context. Thank  you.
 
Brett Hammond
Chairman, MRIC
 
--------------------------------------------------------------
In a message dated 7/19/2007 3:23:01 P.M. Eastern Daylight Time,  
William.Cross at fcc.gov writes:

Yes--the last sentence of the rule allows exceptions, up to twice a  year and 
capped at 72 hours per time, to the hour-per-week rule, when the chief  
officer for emergency planning in the applicable State, Commonwealth, District  or 
territory, approves. The rules does not distinguish between local drills and  
state, regional, or some other geographic area drills.  It distinguishes  
between drills that do not exceed 1 hour per week and those that  do.     


-----Original Message-----
From:  brettham at aol.com [mailto:brettham at aol.com] 
Sent: Thursday, July 19, 2007  2:24 PM
To: William Cross
Cc: Riley Hollingsworth
Subject: Re: RACES  72-hour rule

Mr. Cross,

Thank you very much for your prompt  response.

Suppose, instead, I was conducting a local drill just involving  Talbot 
County, but that exceeded 1 hour per week. Would I also need to get prior  approval 
from the state of Maryland? Sorry if this sounds redundant, but I want  to 
make sure there is no confusion. Thank you.

Brett  Hammond


-----Original Message-----
From: William Cross  <William.Cross at fcc.gov>
To: BrettHam at aol.com
Cc: Riley Hollingsworth  <Riley.Hollingsworth at fcc.gov>
Sent: Thu, 19 Jul 2007 11:26  am
Subject: RE: RACES 72-hour rule

Mr. Hammond:

Riley asked  that I respond to your question.  The rule that you are 
referring to is  Section 97.407(e)(4).  It states:

(e) All communications  transmitted in RACES must be specifically authorized 
by the civil defense  organization for the area served. Only civil defense 
communications of the  following types may be transmitted:

(4)  Communications for RACES  training drills and tests necessary to 
ensure the establishment and  maintenance of orderly and efficient 
operation of the RACES as ordered by  the responsible civil defense 
organization served. Such drills and tests may  not exceed a total time 
of 1 hour per week. With the approval of the chief  officer for 
emergency planning in the applicable State, Commonwealth,  District or 
territory, however, such tests and drills may be conducted for a  period 
not to exceed 72 hours no more than twice in any calendar year  
(emphasis added.)

The rule allows a lot of flexibility for management  of civil defense 
communications at different levels of organization in that  it allows 
"the responsible civil defense organization served" which, in  turn, 
depends on how civil defense is organized in a particular area, to  
decide what communications RACES stations are authorized to transmit 
for  tests and drills not exceeding 1 hour per week.  The last sentence  
allows exceptions, up to twice a year and capped at 72 hours per 
time,  to the hour-per-week rule, when the chief officer for emergency 
planning in  the applicable State, Commonwealth, District or territory, 
approves.   Because civil defense was and still is overseen at the 
State, Commonwealth,  District or territory level, the 
Commission decided that the chief officer  for emergency planning at 
that level should be the one to decide whether  exceptions to the the 
hour-per-week rule are appropriate.  

In  that Talbot County RACES will be participating in the state-wide 
DHMH  pandemic drill, the "area served" appears to be the State of 
Maryland and  the "responsible civil defense organization for the area 
served" appears to  be the  DHMH, a state agency, in collaboration with 
the Maryland  Emergency Management Association.  As written, the rule 
allows only  "the chief officer for emergency planning in the State" to 
approve drills  and tests in excess of 1 hour per week.  The rule does 
not allow a  local jurisdiction's emergency manager to approve drills 
and tests that  exceed 1 hour per week.  Note that in other paragraphs 
of the rule the  phrase, "a [or the] civil defense organization" is 
used.  This is  broader than "State, Commonwealth, District or 
territory" in that it  includes local or national civil defense 
organizations, thereby comporting  with the definition of RACES in 
Section 97.3(a)(37)-- A radio service using  amateur stations for civil 
defense communications during periods of local,  regional or national 
civil emergencies (emphasis added.)   

William T. Cross
Mobility Division
Wireless Telecommunications  Bureau
Federal Communications  Commission

------------------------------------------------------------------------------
--------
From:  BrettHam at aol.com [mailto:BrettHam at aol.com]
Sent: Thursday, July 19, 2007 9:53  AM
To: Riley Hollingsworth
Cc: William Cross
Subject: RACES 72-hour  rule

Hello Riley,

Let me introduce myself:  I have a  commercial radio license (GROL) and 
professionally maintain public safety  radio systems in Maryland. I am 
also an Amateur Extra and volunteer as RACES  Officer for Talbot County 
for the past 5 years. I got into amateur and  commercial radio because 
of my desire to get involved in emergency  communications after 9/11. 
Prior to that I was a telecommunications software  engineer.

Early this year, the Maryland Emergency Management Association  created 
a new subcommittee called the Maryland RACES Interoperability  Committee 
(MRIC), and I was appointed Chairman. It consists of all the RACES  
Officers in the state and so far this year we have unanimously agreed 
on  a standard message form for communicating across jurisdictions 
(ICS-213),  coordinated all our RACES frequencies, and compiled contact 
information for  RACES Officers state-wide. We are currently working on, 
and expect to have  completed a state-wide HF RACES net by November (as 
a backup to repeaters on  towers) and will start work on a state-wide 
digital network  then.

Talbot County RACES will be participating in the state-wide DHMH  
pandemic drill in two weeks, and will exceed the 1 hour per week  
exercise rule. It is my understanding from the FCC rules that we can  
exceed 1 hour, two times per year, up to 72 hours each time. I applied  
for, and was granted permission from MEMA to exceed 1 hour for the  
Eastern Shore Evacuation exercise a few months ago, and was going to  
request permission for the Pandemic drill as well, but there was some  
discussion from MRIC members that permission from the local  
jurisdiction's emergency manager is all that is required (i.e. we do 
not  need permission from MEMA). Again, my understanding is that the 
state,  territory, commonwealth, etc, must give permission. Can you 
please clarify  this for us?

I will forward this email and your response to all Maryland  RACES 
Officers so we are all on the same page. Also please tell us about  your 
responsibilities at the FCC so everyone understands your  authority.

Thank you very much for your time. I know you are a busy man,  but your 
guidance here would help us greatly.

Brett Hammond -  K3TAL
Talbot County RACES Officer
Chairman, MRIC
410-829-6749  (cell)
_brettham at aol.com_ (mailto:brettham at aol.com) 






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