Petitioning to get a few VHF frequencies added to GMRS

[Hans]

Yeah, it's a pipe dream but since there is discussion on petitioning the FCC for changes to GMRS...

 

It would be very nice to get some VHF frequencies channelized into GMRS with the express allowance for cross-band repeating. These could be from somewhere around MURS (or even MURS itself; I'm not picky.) Under the proposed rule changes, the VHF channels could be limited to simplex and cross-band repeat "local" side only, 2 watts maximum. Even just one VHF channel addition would increase the usefulness of GMRS, IMHO.

 

I know that something like this has probably a snowball's chance. However, I don't think there is harm in putting the idea into GMRS user's heads now, in case an opportunity to propose it comes up later.

 

What say ye?

[Elkhunter521]

I would like to see the cross band work both directions given the advantages of VHF frequencies. Lets not sell your idea short with a 2 watt limitation on the VHF side. In addition, allow simplex VHF usage.

 

Thanks, Keith T

[Hans]

True. I was sneaking up on the problem but there's no reason not to look all the way.

[Jones]

All it would take is a ruling allowing cross-coupling of the part 95 services above 30 MHz.  That would allow for GMRS to MURS links, or GMRS to the old 46/49 MHz band (is that still active?) while limiting it to above 30 MHz would eliminate CB. (I don't want to hear skip from channel 6 repeated on 462.500 all day.)

 

Allowing a 2-Watt VHF handheld to remote into a GMRS mobile would solve that guy's problem on that other thread - the guy who seems to want a wireless speaker-mic that works for 3 blocks from his mobile rig.

 

I doubt this will happen, but we can ask.

[Hans]

I was thinking something in the 150 MHz range because of handheld antenna length. Although, 46/49 MHz would work.

 

Allowing a 2-Watt VHF handheld to remote into a GMRS mobile would solve that guy's problem on that other thread - the guy who seems to want a wireless speaker-mic that works for 3 blocks from his mobile rig.

Yep. That thread finally got me to post this thread that I've been putting off.

 

I've wanted to crossband repeat with GMRS since first using the service but have been frustrated by part 95.

[quarterwave]

That would be a nice add, although with the equipment available I think GMRS gets looked at more like a consumer grade hobby, rather than a technical grade hobby. However, I like the concept simply because I have done MRE's in commercial work. Both Public safety and Utilities. In utilities and LE, we sold and serviced PAC-RT's that were connected to low band mobiles, and those were VHF Hi, the PAC was .6 (6/10ths of a watt) on the mobile side and 2 watts on the handheld (HT600 Motorola). We also did it 450 handhelds to VHF mobiles for an ambulance district. 

 

For those of us who are adept...sure, I'd setup a VHF cross in my vehicle. 

[WRAF213]

There's several reasons I don't see this even being considered:

- Crossbanding into Part 15 equipment should be fine anyways. The FCC made a point of this in the 2017 report regarding wireless CB microphones.

- VHF spectrum is incredibly valuable around large cities, and there isn't enough spectrum to add new services.

- There's already a service for low-power simplex VHF: MURS.

- GMRS is not a service for experimenting, that is what Amateur is for. Remember that we're all supposed to be using Part 95 type-accepted equipment without exception. Seriously, half of the non-standard stuff people do on GMRS (linking, illegal phone patching, PTT-ID, begging for digital voice) is better off done on Amateur where it is already legal but ends up being done on GMRS for the sake of doing it somewhere other than Amateur. Just because we can build a repeater doesn't mean we're in a second Amateur service.

- The lack of mandating a minimum level of RF knowledge for licensing is something to consider. The FCC wants radios that work out-of-the box to communicate with other GMRS radios. Adding new spectrum will prevent some radios from working with others, raise technical operating knowledge requirements, create new interference scenarios, and may even prevent distress messages from being heard. In the 2107 report, the FCC made it clear that all GMRS radios must be interoperable to earn type acceptance.

 

Mobile repeaters are EXPLICITLY PROHIBITED in Part 95.303. Repeater stations must be in a fixed location, they cannot be part of a mobile station. You'd have to establish a fixed operating location on-site and leave the repeater there until you're done with it. I'm posting from my phone, I'll give a better explanation of that in the appropriate thread when I get home tomorrow. Just know that mobile repeater use is invalid grounds for requesting crossbanding spectrum.

[Hans]

I would think a parked vehicle would be a fixed location for the purposes of GMRS repeater operation. It's no different than a portable repeater since the location is not part of the FCC license application for GMRS. You get to a location. You park. You turn on the repeater. Of course, one could not legally drive down the road with a repeater operating. However, I don't *yet* see a distinction between carrying a boxed repeater, setting it down, firing it up and driving the repeater, parking it, and firing it up. Both are portable. One is removed from the vehicle and the other stays in the vehicle. It's a difference of structure around the repeater, no? One is a box and the other is a vehicle.

[WRAF213]

From a regulatory standpoint, how do you keep people from driving around with the repeater still active? A warning label is not sufficient. Such a mobile repeater would not be Part 95 accepted.

[Hans]

From a regulatory standpoint, how do you keep people from driving around with the repeater still active? A warning label is not sufficient. Such a mobile repeater would not be Part 95 accepted.

Basics of English Common Law; that which is not prohibited, is permitted. Besides, from a regulatory standpoint, how does the FCC keep anyone from doing anything that it is illegal? The short answer is that it cannot. Any other system is unrealistic and tyrannical, but wholesale prior restraint systems are unethical and doomed to failure. Rather, it typically works like this; if Johnny commits a crime and if Johnny is caught and if Johnny's guilt is proven beyond a reasonable doubt, a proscribed penalty against Johnny is enacted. Where the FCC has an upper hand in this system is through licensing. By taking a license, either overtly or through license by rule, one operates under granted privilege. That makes the burden of the FCC lower than it would without a licensure scheme. Those operating under a license are assumed to have accepted being regulated. That's how all licenses work.

 

Regarding the question as to if a GMRS repeater in a parked vehicle is legal...

We can take a part 95 legal repeater for GMRS, place it in the car with mobile duplexer and mobile antenna, and drive it to a location. Then we can park and turn on the repeater. Is that prohibited? I don't see where it is but I am very open to the possibility that something in the language clearly makes it verboten.

[WRAF213]

Basics of English Common Law; that which is not prohibited, is permitted. Besides, from a regulatory standpoint, how does the FCC keep anyone from doing anything that it is illegal? The short answer is that it cannot. Any other system is unrealistic and tyrannical, but wholesale prior restraint systems are unethical and doomed to failure. Rather, it typically works like this; if Johnny commits a crime and if Johnny is caught and if Johnny's guilt is proven beyond a reasonable doubt, a proscribed penalty against Johnny is enacted. Where the FCC has an upper hand in this system is through licensing. By taking a license, either overtly or through license by rule, one operates under granted privilege. That makes the burden of the FCC lower than it would without a licensure scheme. Those operating under a license are assumed to have accepted being regulated. That's how all licenses work.

 

The FCC does not permit all equipment capable of operating on 462-467 MHz to operate under a GMRS license. Type acceptance ensures that equipment built for GMRS is intended to be used within the rules for GMRS. Mobile repeaters are not allowed within the rules of GMRS, so any device that is a repeater intended for mobile installation won't get type acceptance. This has little to do with the licensee, because there's no 'insurance policy' of a test of good operating procedure knowledge with a GMRS license. The responsibility falls upon the manufacturer to prevent misuse of GMRS radios, such as mobile installation of a repeater or the interconnection of a simplex repeater controller. The licensee would have to go out of their way to circumvent protections against misuse, such as nonstandard connectors or designs for a fixed operating location. Having protections in place is usually enough to shift blame for the rule violations from the equipment manufacturer to the licensee, and a type acceptance procedure mandates certain protections and guarantees manufacturer responsibility. Look at what happened with FRS. The 2017 report blamed the manufacturers, not the users, for misuse of equipment. And the FCC held the manufacturers (somewhat) accountable for their actions, with the change in marketing. They added the extra channels to FRS because they knew the users wouldn't change their behavior. In Part 95, equipment is expected to work with minimal configuration, and the type acceptance procedures for each service under Part 95 also provide some guidelines for the user interface. Repeaters, crossband or not, are not simple devices, and that's one reason we don't see many Part 95 repeaters.

 

Allowing crossband repeating is not in the intentions of GMRS. What does it accomplish? The users will be in simplex range of each other already. For remotely controlling a station, network interconnection is permitted for this purpose; it doesn't have to be done over-the-air. It's just more spectrum pollution to solve a problem that doesn't exist.

 

 

Regarding the question as to if a GMRS repeater in a parked vehicle is legal...

We can take a part 95 legal repeater for GMRS, place it in the car with mobile duplexer and mobile antenna, and drive it to a location. Then we can park and turn on the repeater. Is that prohibited? I don't see where it is but I am very open to the possibility that something in the language clearly makes it verboten.

 

That depends on the FCC's definition of a Part 95 fixed station. I believe the antenna has to be mounted to a permanent structure, but the Enforcement Bureau decides that.

[Hans]

The FCC does not permit all equipment capable of operating on 462-467 MHz to operate under a GMRS license. Type acceptance ensures that equipment built for GMRS is intended to be used within the rules for GMRS.

Type acceptance ensures nothing. It does is make it more likely that equipment will be used within the rules because the technical aspects of the device are being certified as operating in a way which conforms to the rules.

 

Mobile repeaters are not allowed within the rules of GMRS, so any device that is a repeater intended for mobile installation won't get type acceptance.

You are missing the point. Even though I might have (or might not, I would have to look back) unintentionally played fast and loose with the term mobile repeater, we are talking about a part 95 repeater installed in a vehicle with the intention of parking and then using the repeater from a fixed location. Is that a violation of part 95? If so, please cite text.

 

This has little to do with the licensee, because there's no 'insurance policy' of a test of good operating procedure knowledge with a GMRS license.

Type acceptance and license are a bit different. One is from the manufacturer's perspective and the other is from the user's perspective. Not all licensing involves a knowledge or skill test. Does that not make them licenses anymore?

 

You aren't addressing my assertion about the nature and function of licensure. The fact that FRS is license by rule and GMRS is license by application means that the bar to enacting penalties is set lower for the FCC than it would be without licensing; by rule or application.

 

The responsibility falls upon the manufacturer to prevent misuse of GMRS radios, such as mobile installation of a repeater or the interconnection of a simplex repeater controller.

No, that responsibility is not on the shoulders of the manufacture. This is a myth that I've seen far too much out there. The responsibility of the manufacturer is to honestly present their product for certification and to continue to manufacture their product in accordance with the parameters and rules of that certification. If they should change their product in any way that it no longer fits the original parameters and rules of the certification, they have a responsibility to follow FCC procedures in amending, withdrawing, or re-applying. Manufacturers have no responsibility for the misuse of their product when they have honestly submitted their design for certification in good faith.

 

The licensee would have to go out of their way to circumvent protections against misuse, such as nonstandard connectors or designs for a fixed operating location. Having protections in place is usually enough to shift blame for the rule violations from the equipment manufacturer to the licensee, and a type acceptance procedure mandates certain protections and guarantees manufacturer responsibility.

No, that is a choice of manufacturers (i.e. Motorola). If they enter into certification in good faith and continue to manufacture in good faith, having been granted certification; that is the totality of their responsibility. There is no need to "shift blame" as their responsibility does not encompass your or my possible violations. That is what the certification process is all about; the FCC approving the design. If anything, the FCC might have a teeny-tiny sliver of responsibility for having potentially lax certification procedures. However, responsibility ultimately lies squarely on the shoulders of the individual.

 

Look at what happened with FRS. The 2017 report blamed the manufacturers, not the users, for misuse of equipment. And the FCC held the manufacturers (somewhat) accountable for their actions, with the change in marketing.

Please link the report as I would have to read it before commenting.

 

They added the extra channels to FRS because they knew the users wouldn't change their behavior.

This calls for speculation unless supporting evidence is provided. Are their any admissions of this on record?

 

EDIT: I thought you meant manufacturers added channels to facilitate user's errant behavior. I misunderstood. Yes, the FCC probably did make that decision for that reason. But it is still speculation unless it is on record; which it might very well be. However, let us not conflate the responsibilities of a regulatory agency and those of a manufacturer.

 

In Part 95, equipment is expected to work with minimal configuration, and the type acceptance procedures for each service under Part 95 also provide some guidelines for the user interface.

If a manufacturer honestly submits their design in good faith for certification and the FCC grants that certification, how is misuse the responsibility of the manufacturer?

[Hans]

Repeaters, crossband or not, are not simple devices, and that's one reason we don't see many Part 95 repeaters.

Yes, they are complex devices but this is more speculation without evidence. With more modern electionics, it can be a relatively trivial thing to lock firmware down to part 95 operation. The Chinese did it with the UV-82 and the GMRS V1.

 

One could argue that there isn't the potential profit in designing and submitting part 95 repeaters. This, especially since so many part 90 repeaters are currently being used as GMRS repeaters. How big do you think the GMRS repeater market is?

 

Allowing crossband repeating is not in the intentions of GMRS.

That's one of the things we are discussing. What are the intentions of GMRS per the FCC and how can crossband repeating fit within those intentions.

 

What does it accomplish? The users will be in simplex range of each other already.

Crossband repeating can extend the distance two simplex users can communicate. It can also allow a user to reach an otherwise unreachable repeater.

 

For remotely controlling a station, network interconnection is permitted for this purpose; it doesn't have to be done over-the-air.

What about when network interconnection is not available to that individual user? If crossband repeating had zero utility, it wouldn't still be a thing.

 

It's just more spectrum pollution to solve a problem that doesn't exist.

I respect your opninon. However, I and others have been in situations where crossband repeating would've solved a problem for us and it is not currently available in the rules of GMRS. That's what we are here to discuss.

 

That depends on the FCC's definition of a Part 95 fixed station. I believe the antenna has to be mounted to a permanent structure, but the Enforcement Bureau decides that.

You asserted that such a repeater is a violation of the rules so it is upon you to provide the evidence. Do relevant regulations specify what constitutes a fixed station? Does the repeater in question (driven to a location and parked) violate that definition in light of the fact that a location for a repeater is not part of the GMRS license application? I do not know the answers yet but intend to research when I get a chance.

 

The enforcement arm of the FCC does make such determinations but they are predicated upon what the actual regulations state. Now, the task is to find the relevant regulations.

[Hans]

Does this...

 

Repeater stations must be in a fixed location, they cannot be part of a mobile station. You'd have to establish a fixed operating location on-site and leave the repeater there until you're done with it.

... conflict with that?

 

That depends on the FCC's definition of a Part 95 fixed station. I believe the antenna has to be mounted to a permanent structure, but the Enforcement Bureau decides that.

If I take a part 95 repeater in a trailer or in a Pelican box to a location and string up an antenna or put an antenna on a tripod or have an antenna on the trailer; is that a violation of part 95? There is no permanent structure.

[quarterwave]

From a regulatory standpoint, how do you keep people from driving around with the repeater still active? A warning label is not sufficient. Such a mobile repeater would not be Part 95 accepted.

 

Right. Just like selling GMRS capable radios at Walmart and putting in the fine print that people have to get a license. 1 nerd in 100,000 buyers reads that. So, yes to say a warning label is not sufficient is an under statement! 

[Hans]

Right. Just like selling GMRS capable radios at Walmart and putting in the fine print that people have to get a license. 1 nerd in 100,000 buyers reads that. So, yes to say a warning label is not sufficient is an under statement! 

However, as I was reasoning earlier, the manufacturer's responsibility lies in them honestly pursuing FCC certification in good faith for their designs and sticking to those designs. The FCC's responsibilities include making sure that it is not certifying non-compliant designs. The licensed individual's responsibilities, license by rule or by application, is to adhere to the parameters of relevant regulations.

 

With FCC certified hybrid bubble pack radios, I don't fault the manufacturers. Rather, I fault the FCC for certifying them and I fault the user for not reading and following the requirements.

[Elkhunter521]

The main problem with the bubble pack radios is the price. The low price for two radios put them in the realm of toys for children. Prior to the last rule change this "toy status" guaranteed that licencing and regulation compliance never happened. The FCC answer was to make Frs / gmrs bubble pack radios all FRS radios, and begin to phase them out. Sounds suspiciously like phasing out the licence requirement for CB radios.

[Ian]

Hans, I'm going to slyly take what you're doing here and run with it.

 

Let's rationalize the entire Personal Radio Service.

 

MURS becomes part of FRS.  They're both allowed two watts, business use, and no repeaters, yes?

 

GMRS gains the ability to listen to repeater inputs (a blindingly obvious solution, in hindsight, from my ham radio study guide) and … let's call it eight 50 watt VHF channels.  Half will be repeater inputs, half will be repeater outputs.  Preferentially taken from the color-dot pool, since the market has matured, and business radios aren't sold with all of the available channels programmed in any more.

 

All it would take is a ruling allowing cross-coupling of the part 95 services above 30 MHz.  That would allow for GMRS to MURS links, or GMRS to the old 46/49 MHz band (is that still active?) while limiting it to above 30 MHz would eliminate CB. (I don't want to hear skip from channel 6 repeated on 462.500 all day.)

 

Allowing a 2-Watt VHF handheld to remote into a GMRS mobile would solve that guy's problem on that other thread - the guy who seems to want a wireless speaker-mic that works for 3 blocks from his mobile rig.

 

I doubt this will happen, but we can ask.

Yeah, actually, that'd be perfect.  In the mean time, Uniden (may) have me covered.  

 

Quarterwave:  The hardware's the problem.  What do you think about starting up group-buys on Massdrop for legal-but-unprofitable custom kit like better wireless mics?

 

If anything I said here would be done, merging FRS and MURS would be the golden ticket.  It'd reduce the number of boxes I carry every day.

[Hans]

Yep. I was thinking taking from the color-dot pool as well but was hoping some spectrum gurus would know of a niche VHF group in that region that could be sacrificed easier. Additionally, I was also playing with the idea of merging MURS and FRS. I like both ideas.

[Hans]

In the mean time, Uniden (may) have me covered.

What do you think about starting up group-buys on Massdrop for legal-but-unprofitable custom kit like better wireless mics?

I'd rather it be that penetration and range that we could see from 2 watt handhelds. Wireless microphones are going to be weak by comparison. Also, that doesn't solve the handheld <-> mobile <-> handheld range increase from cross band repeating.

[quarterwave]

However, as I was reasoning earlier, the manufacturer's responsibility lies in them honestly pursuing FCC certification in good faith for their designs and sticking to those designs. The FCC's responsibilities include making sure that it is not certifying non-compliant designs. The licensed individual's responsibilities, license by rule or by application, is to adhere to the parameters of relevant regulations.

 

With FCC certified hybrid bubble pack radios, I don't fault the manufacturers. Rather, I fault the FCC for certifying them and I fault the user for not reading and following the requirements.

 

I agree.

[jimndfw]

Obviously, the current rules and interpretations prohibit crossband mobile repeater at this time as the rules are currently written.

 

However, a low power (1 to 2 watt) crossband mobile repeater channel would be an interesting ideal to petition the FCC for.

 

I think/assume if we ask Rich or the staff here at GMRS they could provide some guidance, assistance in drafting a formal petition, as well as suggest the best verbiage needed to give the petition the best chance of getting the current rules changed to allow a low power crossband mobile repeater in the GMRS.

[PastorGary]

FYI - That would be a project for Rich - if he could find the time to assist.   The Mod Staff at MyGMRS will not be involved in any type of legal or procedural advisories due to individual liability issues.

[Hans]

I think, at this stage, it would be a gigantic reach and likely to fail. IMHO, it's something that should stew for a bit in the GMRS community.

 

My intention was to kick off some discussion about what GMRS licensees might like to see along these lines and how best to shape a pitch for it eventually.

[Wrjy836]

Someone asked what the benefit would be. It would be nice to be able to set up a repeater without having to buy expensive bandpass/notch filters. A one-way crossband repeater using VHF as the input is a lot easier to successfully set up.