[MRIC] RACES 72-hour rule
BrettHam at aol.com
BrettHam at aol.com
Fri Jul 20 06:25:00 EDT 2007
Pat,
I believe you are mistaken. In my second email to him, I specifically asked
if I just held a local Talbot County Drill just involving Talbot County, do I
need permission from the state to exceed 1 hour, and Mr. Cross responded
"Yes". He said it doesn't matter the scope of the drill, it is only the time
that matters. If you exceed 1 hour per week, you need state permission. He also
specifically said in his first response: "The rule does not allow a local
jurisdiction's emergency manager to approve drills and tests that exceed 1 hour
per week."
Brett Hammond
In a message dated 7/19/2007 10:59:51 P.M. Eastern Daylight Time,
wb0egr at comcast.net writes:
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)
>
>
>
>
>
>
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> ------------------------------------------------------------------------
>
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______________________________________________________________
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).
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