CogentRadios

This was sent to the FCC for clarification to start the conversation. POC GMRS rule clarification, The rules and definitions pertaining to utilizing digital to analog FM technologies are not real clear and I am seeking clarification regarding the following scenario. Utilizing POC (Push to talk over cellular) data radios bridged to an analog GMRS repeater. The POC’s do not fall into the definition of network, linking, Clear Communications or real time communications as defined by the FCC. There are multiple questions regarding this, and I hope to lay them all out to the best of my ability get the best clarification I can. The scenario would be users utilizing a POC radio with a license validated group meaning that users in that group hold a valid GMRS license, the users would access a dedicated server through digital means, not a phone system as currently specified and defined by the FCC. Once the signal reaches the bridge a conversion takes place from digital communications to analog FM just as a standard radio accessing the repeater would. The bridge, a radio would be under physical control and not operated remotely. One of the questions that needs clarification is, what is the point of “Clear Communications”, is it the point that the data stream is initiated or the point that the conversion from digital to analog FM takes place. This I feel is crucial point of the transmit chain since “Clear Communication” does not take place until conversion to FM happens and vice versa. The way I understand “Clear Communications” is for example FM to FM not digital to FM it would be unintelligible. I would also like to note in part 47 points out that GMRS or FRS devices ARE authorized to transmit data to include location and “Text Messages” essentially creating a digital network if there is more than one device. This creates confusion when part 47 states no network connections are allowed on GMRS systems or repeaters. Outside mesh networks could decipher and decode the digital location or text message essentially expanding the network between the two devices. A ruling clarification has already been rendered on linking multiple GMRS repeaters, this is not applicable since there is no repeater linking or additional spectrum use either from the end user or repeater associated with this approach. I would also like to point out that only licensed users in the designated community would have access to the system, meaning that NOT anyone with a POC radio would be able to access the Repeater as in a linked repeater scenario. According to the following rules: § 95.1749 GMRS network connection. 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. § 95.1731 Permissible GMRS uses. The operator of a GMRS station may use that station for two-way plain language voice communications with other GMRS stations and with FRS units concerning personal or business activities. (d) Digital data. GMRS hand-held portable units may transmit digital data containing location information, or request location information from one or more other GMRS or FRS units, or containing a brief text message to another specific GMRS or FRS unit 95.1733 Prohibited GMRS uses. (8) Messages which are both conveyed by a wireline control link and transmitted by a GMRS station; This brings into definition what is the legal definition of a network and at what point does clear communications take place. The FCC does not explicitly define "network" in a single, clear statement, but based on its regulations and interpretations, a network is generally understood as a system of interconnected communication points, like radio stations, television channels, or internet service providers, that can transmit signals or data across a large area, falling under the FCC's jurisdiction for regulating interstate and international communications via radio, television, wire, satellite, and cable. The follow up definition would be the definition of interconnectivity by the FCC. The Federal Communications Commission (FCC) defines "interconnected VoIP service" as a service that allows users to make and receive calls to the public switched telephone network (PSTN). Interconnected VoIP services use Voice over Internet Protocol (VoIP) technology. According to this definition a direct example of VOIP was given which clearly states switched telephone network and I present no contest on this, but by mere definition this does not apply to a POC bridge to a GMRS repeater. The POC is digital stream, controlled by a closed server which directs a digital stream to a bridge device facilitating the conversion to FM. Just to point out another perspective on network, would the GMRS repeater with the users not also be considered a network or defined as such? Although the broad definition of network could be applied to a POC radio system, I believe that at the point of conversion utilizing the “Clear Communications” principal when the conversion and transmission to the repeater takes place it would be no different than a local user accessing the system as intended and does not apply. The possibilities this system brings to communities utilizing a GMRS repeater are multifold coupling utility with safety and maintaining the integrity of the allocated frequency spectrum. The antiquated approach to GMRS management is falling short of market technologies and advancements in communication. I am grateful for your time and counsel on this I look forward to hearing from you. Frank Sellers CEO/President Cogent Radios Group +1.931.208.0484 Submit Help Request Your request for support has been received at 2025-03-11 15:57:27. FCC Support will contact you within the next 3 business days. You may track your support request online using the tracking number below. Please print or save this number! Tracking Number: HD0001478045

I see there is a bit of confusion, this repeater would only be accessed by the people in that community via poc. Lets say you travel outside of the area on vacation you can still access the community. The question is the legal definitions. This is not a linked system for everyone, like linked repeaters were. Although its a novel idea, I do not want my system accessed by every joe blow in the US with a DTMF pad. I am working on the proposal and will share when completed.

Right, so the initial transmission is active on a digital fabric through an isolated server frame then relayed to a bridge where it is transmitted to the repeater in analog FM. Yes the transmitter is type accepted, a Hytera MN360. That's the point of establishing what the FCC defines as "Real Time Communications". So the bridge is under my direct control and not remote and does not go through a phone system. I will be writing up a request for clarification this week and forwarding it to the FCC . Its going to take me a week to just cover the definitions and applicability. Once I hear back I will share the request and findings with everyone. If I am wrong then I am wrong and will comply but under part 47 rules I really do not think I am. Even the definition of remote would not apply if I have physical control over the bridge.

Yes, they are type accepted radios. They are Chinese like everything else now a days. Did I do a verification on the type acceptance, no I did not. Maybe I am not clear on your question, are you talking about the radios accessing the repeater?

Ok thanks, have a great week.

Well, the point of originating communications is not defined. Is the point of originating communications the initial digital signal or the analog FM signal from the bridge. The digital signal could not be considered "Real Time Communications" if the receiver (person or device) cannot interpret the message. So the origin of the message is established at the bridge, at point of conversion to facilitate "Real Time Communications", so the linking repeaters, voip or networking are not really a correct description or applicable.

I could not agree more. I don't think anyone would want to listen to strangers talk. But if the local community members travel outside the area and still had access to the community through the repeater, in addition to not using additional GMRS spectrum to do it I think would be a game changer.

Ok explain the originating repeater and the end repeater string? Convince me that I am linking repeaters.

Thank you, it is kind of like talk groups. You say its illegal, as this thread started out, who is the attorney that took this to court and determined it illegal instead of just being out of compliance with a ruling? Honestly, this is more a hobby than a business and have donated complete repeater systems to communities in need. I also started an animal rescue and sanctuary and don't need to peddle Hytera or any brand of radio. This seems like a tremendous opportunity for the GMRS community and would benefit a lot of folks. POC systems are everywhere Whether its Hytera, Retevis or Singhua or what ever the device is having it on GMRS would be very cool.

I agree, but I am not linking repeaters or consuming more than 1 authorized frequency pair. So in a populated area where all of the allocated repeater frequencies are utilized I can see the point they are making very clearly. All though the question is how many repeaters are in an area? There are two that I know of here in the Virginia, 50 miles from DC with low to moderate traffic, so if another repeater links into the already allocated repeater pair how is that using space. The FCC authorized specific frequency pairs to be utilized for repeaters and now the opinion is it uses up too much space? Another clear as mud opinion.

I think we have beat a dead horse and we will see. I do want to thank everyone for bringing up the points you have, certainly gave me pause to consider my approach. One final question I have is why do you think it would not be allowed to have a network, voip on a simple GMRS repeater system, I would think this is a win win for communities.

I see that but do not agree, then in the same this is considered a network "(d) Digital data. GMRS hand-held portable units may transmit digital data containing location information, or requesting location information from one or more other GMRS or FRS units, or containing a brief text message to another specific GMRS or FRS unit" but is permissible? You are correct on the ham radio part, I was looking at it from a manufacturers point.

Agreed that's my point none of this is clear and the LTE is not connected or inter-connected to the repeater, there are no digital connections enabling communications, the Digital is converted to analog prior to transmit. I am almost 100% sure that the term "repeater Links" would nullify this ruling in a court of law under closer examination. Honestly one other point of examination would be the origination point of the transmitted signal into the repeater, would it be the initial digital data, or the point of conversion to analog FM?

My question is, this ruling, linking repeaters impacted thousands of people across this country severely limiting civil communications and to my knowledge no one is challenging this ruling and accepting it as law from a a faceless bureaucrat in D.C. Now I am the bad guy for pushing back and challenging this obviously antiquated approach to a publicly allocated frequency spread. The Part 95, 94, 92, 97 are not clear and neither was the interpretation provided focusing on LINKING REPEATERS, I do have a background in law, criminal and some civil and I am not intimidated or scared of it, if a legitimate court not an panel of arbitrators decides then absolutely I will comply 100% but until then I will always question authority. Back to my previous comment how many Hams and GMRS folks are using non type accepted equipment? There is absolutely a violation of the law, or is it a ruling?

LOLOL, iron Clad? Explain to me what the risk is? The repeater owner, me assumes the liability and it would be me not the users taken to court. The FCC sends out a notice to stop and I have an appeal, due process in which the ruling gets examined. The question is what happens when rulings aren't challenged? How many hams and GMRS users are using non type accepted radios?