JLeikhim

§ 95.335 Operation of non-certified transmitters prohibited.Except as provided in paragraph (a) of this section, no person shall operate a transmitter in any Personal Radio Service unless it is a certified transmitter; that is, a transmitter of a type which has obtained a grant of equipment certification for that service, pursuant to part 2, subpart J of this chapter. Use of a transmitter that is not FCC-certified voids the user's authority to operate that station. See sections 302(a), (b ), and (e) of the Communications Act (47 U.S.C. 302(a), (b ), and (e)). (a)Exceptions. Under certain exceptions, non-certified Personal Radio Service transmitters, or transmitters certified for use in the land mobile radio services may be operated. Any such exceptions applicable to stations in a Personal Radio Service are set forth in the subpart governing that specific service. See e.g.,§§ 95.735 and 95.1735. (b )Revoked or withdrawn certification. In the event that the FCC revokes or withdraws a grant of equipment certification for a type of Personal Radio Service transmitter, existing transmitters already in service may continue to be operated unless and until the FCC determines otherwise and gives Public Notice of that decision. ©Grantee permissible modifications. Only the grantee of the equipment certification may modify the design of a certified Personal Radio Service transmitter type, and then only pursuant to and in full compliance with the requirements and procedures for permissible changes and modifications in part 2 of this chapter. See §§ 2.932 and 2.1043 of this chapter. The subparts 95.735 and 95.1735 (GMRS) are shown as "reserved" in their respective sections.

95.319 (b ) does not hold much water. It does not specify who those folks might be. However I like that the rule exists. More below. I am also a GROL. Years ago, the FCC under pressure of a certain Radio Vendor Evil Batwing Corp, removed the requirements for a GROL to perform tuning, repairs and service of LMR equipment. They did this no doubt, so they could pay technicians a smaller wage and to reduce liability. The FCC rewrote Part 90, putting the responsibility on the licensee to ensure the equipment worked as required. 95.337 as underlined, describes the condition under which a modification becomes a violation. You can modify if it still meets rules. So lets say you want to install a wire into the radio to tap the discriminator or grab COR logic. That's a modification, but it is benign. Or you are a bench tech and the radio comes in with a blown final and you determine that no OEM part exists, but you are aware that an MRF123X is same part, install it, test the radio for spurs and harmonics. That is technically a modification, but not a violation. Then comes Sparky McSpark with his golden screwdriver. He goes into the 40 watt Midland and twists some coils and turns a pot and now his bird wattmeter shows 60 magical watts! That is potentially a violation. As far as Part 90 and FPP. I am OK with running Part 90 radios within the rules. I think the FPP sort of pushes the envelope however. You can accomplish same thing with a small laptop computer and RIB. I was programming Saber Radios with an HP200LX palmtop and DOS RSS long before FPP became a thing. Back to 95.319 (b ) . If you read the new rules closely (I can't cite off my head) there is as mentioned above, a rule that hints at the use of non part 95 certified equipment and it refers to "reserved sections" within the RC and GMRS rules. I think that a reasonable rule change could acknowledge that certain Part 90 radios are technically compliant with Part 95 GMRS and that 95.319 (b ) could be the qualification required to use Part 90 radios within GMRS.

The Certification rules are written as much for the manufacturers of new radios as they are for the licensee. If you look at the history of FCC enforcement of equipment certification you will see little of it has been directed at the licensee. What does all this mean? If you have a radio that was certified in 1989 under much less stringent rules, it is still certified. I have some Motorola Systems Saber radios. They are dual certified Part 90 and Part 95. They also have some features that if activated clearly violate some rules, like encryption. But the radio is still certified and if programmed and operated correctly complies with present rules. If the FCC were to crack down on the use of part 90 equipment used in GMRS, they would be very busy. I think that even though you may be driving an automobile with a helicopter turbo jet engine, violating all EPA and NHTSA standards, as long as you stay between the lines and watch your speed, the police won't bother you. Now the problem is, that there are a lot of newbies buying some pretty dodgy and cheap Chinese radio gear and they may be inclined to install an equally cheap 50 watt Chinese power amplifier to this gear. If they do that, and a spurious signal bothers the local air traffic control tower, they will be in a heap of trouble.

"(ii) On a non-profit basis, with contributions to capital and operating expenses including the cost of mobile stations and paging receivers prorated equitably among all participants" This says you can charge, but you would really have to form a legitimate non profit and get a CPA involved in the books. And Corey is right, you may have some hassles. I am considering a no-fee arrangement with tones for private use, but with some certain operating rules so that if, frankly, I don't want someone using it because of their behavior, I can send them a certified letter telling them they have violated rules and must go away.. I would send a nice letter first. I just don't want to have to punish everybody by pulling the plug.

This is an interesting question. There may be some overlap where the rules permitted part 90 radios and the age of some older equipment. Hopefully your license is likewise that old.

I have searched the FCC NAL listings going back many years and I have never seen an NAL for either type certification or for linking via any means. Honestly, the only NAL's I found were for corporate businesses blatantly using GMRS or that Bundy guy in California who happens to be a GMRS licensee jamming Part 90 users. GMRS has a pretty good record with the FCC.

Interesting! See e.g., §§95.735 and 95.1735." Those sections are actually reserved. Could it be the FCC contemplates allowance for Part 90 equipment? This has been raised during the NPRM. To be honest, to be fully compliant with certification and to have a proper 50 watt 16K03FE or 20K0F3E emission as intended, requires one to choose from a small number of obsolete products. Some of them quite good, like Motorola Systems Sabers or Kenwood TK-8302H . I am actually building a repeater that will be 99% compliant. The PA is the 1 % problem.

Ritron has some older radios that are indeed part 95A certified. The DTX-450 RF Modem for one. If you want certified mobiles I would recommend the Kenwood-TK8302HU-UHF-TK-8302HU https://www.ebay.com/itm/Kenwood-TK8302HU-UHF-TK-8302HU-16-Ch-450-520-Mhz-40-Watts/132633983732?hash=item1ee199faf4:g:b1UAAOSwY3tbNSiF:rk:11:pf:0

I found uploads dont work as well.

Is this proceeding still open? Any resolution. It worries me when Motorola asks for something. There is usually some over reach. Having 30 of those GPS gadgets on a channel at a national park will be a mess. And yes, at bubble pack prices, folks will be attaching them to their cars and motorcycles as a poor mans lojack.

The effect of this rule is that you don't violate rules to begin with. There is no distinct prohibition on attaching a Part 95 approved amplifier to Part 95 exciter/transmitter. § 95.339 Operation of transmitter with external device causing rule violation prohibited.No person shall operate any Personal Radio Service transmitter to which an external device or accessory has been added such that operation of the combination results in a violation of the rules. The reality is that a lot of Part 90 equipment is routinely used on Part 95 and the FCC is fully aware of this. It is inevitable that high performance Part 95 equipment will cease to be manufactured. I say inevitable but reality is that the crap being sold as Part 95 by the manufacturers is narrow band and that in itself renders GMRS impotent. Licensees need to choose equipment carefully and petition the FCC to permit certain Part 90 equipment (that meets Part 95 specs) be permissible. At same time, reject manufacturers who see GMRS as FRS on 15 watt steroids.

I don't think you have to go to fancy extremes to be compliant. Just don't operate with a balloon tailing behind you on the 417!. "perceived toxicity in the culture surrounding amateur radio" I am a ham and have seen this time and again. Folks ask on the board how they can get reliable two way communications for family and the answer right away is to get a ham license for every member of the family. I know of a few families where that is the case, but they are unicorns. Then there are the FCC "Nazi's" who look for an infraction in every sort of activity not positively supported by the rules, or twist wording to favor their prohibition de jour. Fact is If it is not specifically prohibited it is probably OK, The FCC's GMRS infraction filing cabinet buried deep in warehouse 13 in Gettysburg is mostly an empty drawer. The few NAL's they write are commercial users on GMRS channels. Or GMRS operators that are jamming part 90, well one guy from California basically. The filing cabinet for Ham radio infractions takes up three floors.

Oh god, I will have to put my flame suit on. Here it is. I am a licensed ham, have been for years and have pushed the state of the art in many venues. Built an amateur radio satellite station, worked the world, constructed a 98 foot tower etc. Spent a lot of money at AES. However every so often I get the bug to build a repeater. I am building a repeater for GMRS and not for ham as my immediate family will not benefit. This is something my neighbors might benefit from as we are in a hurricane area and power and communications are out at least a few days every year. So I am building a 50 watt (wide band ) GMRS repeater with quadruple receiver diversity. Yes folks I intend to push the state of the art forward. All parts will be Part 95 certified. The four receivers will each have a separate diversity antenna mounted with separation to exploit the uncorrelated multipath signals. One of the four receive antennas will be a horizontally polarized loop to exploit angle diversity. Why am I doing this? To improve the reception form a 5 watt handheld so that talk back reliability approaches talk in. The heart of this is the repeater shelf I am assembling and the brains are a surplus JPS SNV-4 voter which has DSP S/N voting and DSP noise reduction. Will it work well? I think so, that is part of the fun. Once the fun is over I will have a powerful GMRS repeater in my town.

If I read correctly what Ian is describing, it is a repeater to be used at a fixed location on a temporary basis. And using a balloon hoisted antenna. There is no prohibition in the rules for such a station.The fact that it is installed in a vehicle does not preclude lawful operation of the station when deployed at temporary locations. A fixed location is not a specific location. It is simply a stationary one. Further the FCC no longer licenses fixed GMRS stations by site so there is no expectation of a protected service area other than using care to operate without interference. § 95.303 Definitions. Repeater station. A station in a fixed location used to extend the communications range of mobile stations, hand-held portable units and control stations by receiving their signals on one channel (the input channel) and simultaneously retransmitting these signals on another channel (the output channel), typically with higher transmitting power from a favorable antenna location (typically high above the surrounding terrain).

Greg; If you have repeaters on the band edge, be aware the FCC now permits part 90 NXDN operations INSIDE the lower and upper edges of Part 95, they did this against there own previous practices and despite objections. Unfortunately the GMRS community kind of snoozed on this "guard band intrusion" and now it is here. If you operate a repeater on the upper and lower pairs, and especially if you have an AFC (Micors), there may be interference. Because the FCC no longer license GMRS repeaters by site, who is to say who is the incumbent should there be a part90 vs part 95 shooting match.

That is certainly good to hear. I am building a new repeater and trying to comply with Part 95 . Finding a PA has been a worry. Aftermarket PA's are commonly used with Part 90 equipment and as such, I have not seen any concern as to specific certifications. It is the exciter that does the heavy lifting as to modulation emissions. The PA if well designed and terminated into a proper load should do fine.

Some of those random attempts might be folks with "low parts count" radios from China. Many don't provide adequate deviation and the CTCSS tone might be weak.

That is so excellent!

Years ago, the FCC approved maritime "port operations" on UHF channels with non standard repeater pairs. some of these operations are simplex as well. It is all supposed to be low power.(2 watts) Some of the frequencies are in the GMRS band. It is not unusual for cruise ships to be on these frequencies. If you call the ship on the radio, be polite and simply indicate interference and request the vessel name and or to talk to the captain to get company contact information. Be sure to ID your GMRS station properly. Use simplex, don't use their input frequency! Mostly I would listen for clues as to what ship it is coming from and contact the IT or Telecom director at the Cruise company by writing a letter (and CC your local FCC field office) and simply request the use an alternate tone.

I have a bunch of RITRON DTX-450 modules I need to program for a GMRS repeater project. It is a one time deal so I intend to cobble up the 3.5 mm programming plug and wire to a Motorola RIB box. The problem is that the documentation is unavailable to determine which of the tip, ring or sleeve are for TX and RX data. I am assuming the sleeve is data ground. The only schematics I can find are for a cable that terminates in an RJ plug for use with RITRON's proprietary RIB, and the data labels are missing. I am using a Motorola RIB, so any help would be appreciated. I assume the same cable is used for Jobcomm and Patriot radios. I am in Orlando Area if anyone is willing to loan out their programming kit for a day. Thanks

I want to point out that the FCC is once again proposing to encroach inside the band edges of the GMRS band . Recently the FCC has approved waivers for several commercial part 90 operators to encroach in this manner. I apologize in advance for cross posting this on other boards, but this is important and is likely not to be noticed by many. This started in about 2013 when Mobile Relay Associates of California requested to encroach on Part 95 band edges in LA and Miami. The GMRS community did not react and the FCC subsequently awarded waivers to permit MRA do do this without any reservation, nor any technical data in support that doing so would not cause interference to incumbent 25 KHz GMRS operations. At a later date MRA attempted to obtain similar waivers to encroach on other spectrum and has been denied because "the assignment of non Part 90 spectrum to Part 90 licensees was contrary to FCC procedures". So in one case the FCC ignores their own procedures and assigns GMRS Part 95 spectrum to MRA and in another case, the FCC denies MRA access to spectrum which was part of the auctioned Radio Common Carrier band. If you are a GMRS licensee, I urge you to respond vociferously to this FCC NPRM and make your voice heard, "On its own motion but suggested by recent waiver requests, the FCC proposed to make available for PLMR use frequencies that are on the band edge between the industrial/business (I/B) pool and either general mobile radio service (GMRS) or broadcast auxiliary service (BAS) spectrum, to make certain frequencies that are designated for central station alarm operations available for other PLMR uses. The FCC also made certain updates and corrections and amended its rules to accommodate certain railroad operations. Specifically in the I/B pool, the FCC proposed to amend the frequency table to add frequency pairs 451/456.00625 MHz and 451/456.0125 MHz, with the limitation that the authorized bandwidth not exceed 6 kilohertz. The commission also proposed to amend the I/B pool frequency table to add frequency pairs 462/467.5375 MHz and 462/467.7375 MHz, with the limitation that the authorized bandwidth not exceed 4 kilohertz. “We tentatively conclude that it would be in the public interest to make additional frequencies available to PLMR applicants that can be utilized without overlapping the occupied bandwidth of currently assignable frequencies and without causing harmful interference,” the NPRM said." Link to article http://www.radioresourcemag.com/News...s/NewsID/14610 See also: http://transition.fcc.gov/Daily_Rele...A-16-966A1.pdf

I seem to recall that T1504 was a four bandpass/reject cavity duplex filter. It may have been sold as a kit of parts. But in any event depending upon the frequency band you got a set of critical length interconnect cables and a "T" connector. The duplexer is band pass with reject notch filters. The band pass is wider than the reject notch so after first tuning band pass, then tuning reject, you could fine tune the reject with the pass knobs. That is how I did it and they worked well. The trick was that the screws on the slotted reject loop had to be almost tight so they made reliable connection and then I would "rap" the screws one direction or the other in the slot to tune the notch. A couple Excelite nut drivers were the ideal tools to move the knurled nut. Use one as a "hammer" and the other as a "chisel" and tap their plastic heads together to move the nut just enough. Then hand tighten,

You might take a look at the responses to NPRM 10-106 and find a style and preamble that you are comforable with. Tell FCC who you are, why GMRS is important to you, and then explain why it is detrimental to have commercial operators inside the now protected 25 KHz bandwidth of the band edge GMRS channels. You might cite the existing guard band the FCC has in place as being good engineering practice. Whatever you do, don't get caught up in copycat letters. In 10-106 there were a slew of essentially form letters sent by well intended folks. However, one of those mailings had a technical error which implyed the respondents were pro something they were likley not. Additionally the letters lacked the vitality of individuals who were passionate about the cause. Unlike NPRM 10-106 which required dozens of pages to respond, this filing can be dealt with in a few paragraphs unless someone wants to make an engineering argument.

I am surprised I haven't seen more comments on this topic as in the end it has a direct impact on how the FCC treats GMRS. If you recall the NPRM 10-106 in 2010 (Comments still open by the way), what happened then was the FCC got a floodgate of responses, mostly knocking down the proposed rules. I don't think the FCC was prepared, and rather expected a non showing of interest. Had that been the case, the NPRM would have essentially eliminated GMRS and in its stead, an FRS like environment of low power bubble pack radios and no repeaters. It is no doubt to me that the big names in industry (the ones who no longer type accept their high power radios for GMRS) would like GMRS to fade away so that a few more channels would be come available for commercial customers. I don't think it is any coincidence, the FCC eliminated station licensing for repeaters. To the FCC the repeaters don't exist. If they don't exist, the FCC does not have to protect them. If GMRS becomes "refarmed", nobody will get a check for moving to a new frequency band. This NPRM is equally important, both from the standpoint of interference, and from the showing of continued interest in GMRS and GMRS repeaters.

The fallacy in this comment (quoted below) is that regardless of whether CTCSS or DPL/DCS is being used, a significant degradation will occur to the reception of the GMRS signals. Yes, having CTCSS or DPL/DCS will eliminate the probability (in most cases) of hearing the interfereing signal, but valid signals will be subjected to noise interference. This could be a very distant signal just noticible at 3 dB of degradation, to the extreme of a repeater being entirely blocked by the signal 12.5 KHz off the channel center from a mobile transmitter in the same City.. Back in the 1980's, I was responsible for UHF repeaters on the Sears (Willis) Tower rooftop. We had a room full of UHF community repeaters which were fed from a master receive antenna at the very top of one of the wjite pylons. This was a tremendous receiver system. On one occasion,. I found a repeater that was totally deaf. The culprit was a hospital cardiac telemetry transmitter of less than 10 milliwatts, inside a hospital room, operating 12.5 KHz offset from the repeater input frequency. Bottom line is you don't want these part 90 folks inside GMRS bandwidth any more than they want us. "In conclusion: Will this affect GMRS services who use 550 and 725? YES, if they are wideband and trying to use simplex or duplex on 550 and 725 without CTCSS or DPL codes. However, one thing I would like to note: How many users of GMRS use these channels without CTCSS or DPL codes? I am thinking very few."