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Programming your own radios, and front panel programming...


Jones
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What is the purpose/intent of the FCC Part 95 rules? It appears that the FCC aims to create a uniform standard for transmitter emissions. Following the "spirit" of the rules regarding frequencies, power output, bandwith, deviations, etc. seems to be the important aspect that allows GMRS users to have a reasonably functional band. Why does it matter how you configure or construct your transmitter if it comports with the emission standards? To a reasonable person, the "letter" of the rule would seem less important than the "spirit". Obviously, the FCC missed the common sense boat during their last rule-making session. Since I am new to GMRS, does anyone know how often they consider making changes?

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.

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Question for discussion...

 

Programming your own Part 90 radios into Part 95 service, and front panel programming...  Is this legal?

 

This may be another area that needs further clarification from the FCC, or perhaps I just cannot find the rule that applies, but in the past, all type-accepted radio transmitters had to be set up and aligned by (or under supervision of) a licensed technician before they were legal to use.  Radio owners/operators were never allowed to modify their radios in any way.  A licensed technician used to be defined as "the holder of a valid Commercial General-Class Radio-telephone Operator's License."

 

Today, we are all programming our own radios for the frequencies we would like to use, and some even modify radios for front-panel programming.  Is this even legal?

 

The only laws I can find about this today are:

 

95.319 (b.) Internal repairs. Internal adjustments and repairs to Personal Radio Services transmitters must be performed by or under the supervision of an individual who is qualified to maintain and repair transmitters.

 

95.337 No person shall modify any Personal Radio Service transmitter in a way that changes or affects the technical functioning of that transmitter such that operation of the modified transmitter results in a violation of the rules in this part. This includes any modification to provide for additional transmit frequencies, increased modulation level, a different form of modulation, or increased transmitter output power (either mean power or peak envelope power or both). Any such modification voids the certified status of the modified transmitter and renders it unauthorized for use in the Personal Radio Services. Also, no person shall operate any Personal Radio Service transmitter that has been so modified.

 

I had never really considered this before, since I do hold a Commercial GROL, and I am a qualified technician, but what about others programming their own radios with eBay cables?  What about those internal modifications that allow the front panel to essentially be used as a VFO? This is fine for ham use, but can that possibly be legal at all for GMRS?

 

Open for discussion.....

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.

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https://www.law.cornell.edu/cfr/text/47/95.319

 

§ 95.319 Malfunctioning transmitting equipment.

If the operator of a Personal Radio Services station becomes aware that the transmitting equipment is no longer functioning properly, he or she must stop making transmissions (except for emergency communications) using the malfunctioning transmitting equipment until it has been adjusted and/or repaired, as necessary, to restore proper operation.

(a)FCC request to discontinue operation. If an FCC representative informs a Personal Radio Services station operator that the technical characteristics of his or her transmitted signals are not in compliance with the applicable rules (e.g., regarding power, unwanted emissions, frequency accuracy), he or she must immediately stop making transmissions with the transmitter producing the non-compliant signals.

(b)Internal repairs. Internal adjustments and repairs to Personal Radio Services transmitters must be performed by or under the supervision of an individual who is qualified to maintain and repair transmitters.

(c )Test transmissions. The operator of any Personal Radio Services station may make brief test transmissions to verify the functional status of the transmitting equipment at any time, provided that such transmissions do not cause interference to the communications of other stations. A qualified individual maintaining or repairing a Personal Radio station transmitter in accordance with paragraph (b ) of this section may make test transmissions as necessary to maintain or repair the transmitter, provided that such transmissions do not cause interference to communications of other stations.

 

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https://www.law.cornell.edu/cfr/text/47/95.337

 

§ 95.337 Operation of impermissibly modified equipment prohibited.

No person shall modify any Personal Radio Service transmitter in a way that changes or affects the technical functioning of that transmitter such that operation of the modified transmitter results in a violation of the rules in this part. This includes any modification to provide for additional transmit frequencies, increased modulation level, a different form of modulation, or increased transmitter output power (either mean power or peak envelope power or both). Any such modification voids the certified status of the modified transmitter and renders it unauthorized for use in the Personal Radio Services. Also, no person shall operate any Personal Radio Service transmitter that has been so modified.

 

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https://www.law.cornell.edu/cfr/text/47/95.361

 

§ 95.361 Transmitter Certification.

(a) Unless otherwise provided in the subpart governing that service or in other parts of this chapter, each transmitter that operates or is intended to operate in a service of the Personal Radio Service must be certified in accordance with the governing subpart and part 2 of this Chapter.

(b ) A copy of the instruction manual specified in § 95.393 must be forwarded to the FCC with each request for certification of the relevant transmitter. If a final copy of that manual is not available when the certification application is submitted, the applicant may include with its application a draft or preliminary copy provided it forwards a final copy to the FCC when such a copy becomes available.

(c ) Equipment certification will not be issued for transmitter types where any control, switch or other type of adjustment - which, when manipulated, can result in a violation of the rules - is accessible to the user.

 

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§ 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.

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  • 3 weeks later...

It would be nice if the FCC would allows a database search for Part 95 Certification.  I manually checked a few Motorola Part 90 radios and some also list Part 95 Certification.  From what I could determine from looking at the certification files by the manufacturers, all that is required for certifying a Part 90 radio is simply a statement requesting it.

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