[MRIC] RACES 72-hour rule

Thu Jul 19 22:59:03 EDT 2007

Brett,

To clarify, ONLY in a STATE-RUN Drill, does this apply because the STATE 
is asking Talbot County RACES to activate.  In the case of a Talbot 
County ONLY exercise, then the 72 hour exception is granted by the 
Talbot County EM.

73,

Pat Scolla, wb0egr

BrettHam at aol.com wrote:
> 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) 
>
>
>
>
>
>
> ************************************** Get a sneak peek of the all-new AOL at 
> http://discover.aol.com/memed/aolcom30tour
>   
> ------------------------------------------------------------------------
>
> ______________________________________________________________
> This email list is for the use of RACES Officers and Emergency Managers. Only email related to the Maryland RACES Interoperabilty Committee (MRIC) of the Maryland Emergency Management Association should be sent to this email reflector list. All emails must be in plain text format (no HTML).
> MRIC mailing list
> Home: http://mailman.qth.net/mailman/listinfo/mric
> Help: http://mailman.qth.net/mmmain.htm
> Post: mailto:MRIC at mailman.qth.net
>   