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Seeking logical rationale for Type 95


WRDD237

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Frankly, I want to know the real reason why the FCC requires you to use a Type 95 radio for GMRS. Suppose you're a licensed ham AND have your GMRS license. This rule just means I've got to purchase additional radios to lug around. Who is this rule benefiting and why?

There was a petition in 2014 to add exception to the Type 95 rules to ham operators but it failed miserably.

 

Thanks

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GMRS is for families. No test, covers your whole family. No tinkering, grab a pre programmed radio and go.

 

The downside is that the FCC limits the equipment that can be used to prevent people from plugging numbers into a radio and causing interference.

 

There would be a lot more confusing regulations to follow if the FCC started putting all kinds of equipment exceptions for various other services, which then creates more problems than it was trying to solve for a family jist grabbing a set of radios and going.

 

My wife and kids are not interested in Amateur radio. This allows us all to communicate with few issues.

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GMRS is for families. No test, covers your whole family. No tinkering, grab a pre programmed radio and go.

 

The downside is that the FCC limits the equipment that can be used to prevent people from plugging numbers into a radio and causing interference.

 

There would be a lot more confusing regulations to follow if the FCC started putting all kinds of equipment exceptions for various other services, which then creates more problems than it was trying to solve for a family jist grabbing a set of radios and going.

 

My wife and kids are not interested in Amateur radio. This allows us all to communicate with few issu

 

I might add that GMRS has tolerances as far as frequency that are far lower then most HAM gear. With GMRS being smack in the middle of the part 90 portion of the band it is important to maintain some type of standard as to not cause interference to the adjacent service. Requiring a type accepted and certified transmitter is the best way to do this.

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GMRS is for families. No test, covers your whole family. No tinkering, grab a pre programmed radio and go.

 

The downside is that the FCC limits the equipment that can be used to prevent people from plugging numbers into a radio and causing interference.

 

There would be a lot more confusing regulations to follow if the FCC started putting all kinds of equipment exceptions for various other services, which then creates more problems than it was trying to solve for a family jist grabbing a set of radios and going.

 

My wife and kids are not interested in Amateur radio. This allows us all to communicate with few issues.

 

And nothing that the OP suggested would change any of that.  Adding an exception for already licensed HAMs to use their already existing and perfectly capable gear wouldn't change anything that's happening in GMRS currently for non HAM types using it.  Just means that we would have to spend less money on redundant equipment to stay within the letter of the law.  

 

Though I'm sure there's already plenty of combo HAM/GMRS guys running around with Amateur gear programmed for GMRS use.........

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And nothing that the OP suggested would change any of that.  Adding an exception for already licensed HAMs to use their already existing and perfectly capable gear wouldn't change anything that's happening in GMRS currently for non HAM types using it.  Just means that we would have to spend less money on redundant equipment to stay within the letter of the law.  

 

Though I'm sure there's already plenty of combo HAM/GMRS guys running around with Amateur gear programmed for GMRS use.........

 

This is exactly my thinking as well.  I currently have GMRS, 2m/70cm, and a 10m radio in my Jeep.  And an antenna for each radio. I really want to add 6m, too, but 3 radios and antennas are already too much.

 

I am thinking about getting a Yaesu FT-8900R, which is a quad-band.  That will get me down to two radios and two antennas... but if we could get a radio like that to run on GMRS too, then I would be down to one radio.  Instead of looking like a mobile SETI station, my Jeep would look like a Jeep.

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Honestly, if they thought of GMRS as a subset of amateur, where someone else (a ham, or a company) had to set your stuff up for you, and you were limited to "novice" bands, that wouldn't be so bad.

 

If GMRS were bolted to business bands still, that wouldn't be so bad.

 

The problem is that fragmentation of the bandplan - and moreso the market - means network effects can't take off.

 

Even Motorola is pitching LTE as the new answer to trunked radio deployments.  "Pay us a per-unit monthly fee, and we'll handle all the infrastructure for you". I can't help but wonder if this is aimed mostly at "FirstNet" users who don't need a smartphone, or who need something that can be operated without looking at it.

 

The problem with that is, ultimately, that it's rent-seeking.  I want to pay $40 per radio, not $40 per month per radio.

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Even Motorola is pitching LTE as the new answer to trunked radio deployments.  "Pay us a per-unit monthly fee, and we'll handle all the infrastructure for you". I can't help but wonder if this is aimed mostly at "FirstNet" users who don't need a smartphone, or who need something that can be operated without looking at it.

 

The problem with that is, ultimately, that it's rent-seeking.  I want to pay $40 per radio, not $40 per month per radio.

 

I would never buy solely into commercial networks.  Don't get me wrong... I love my smartphone, but the regular failures and lack of coverage, even when everything on the commercial networks work correctly, are the very reasons "radio" comms are alive and well.

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Honestly, if they thought of GMRS as a subset of amateur, where someone else (a ham, or a company) had to set your stuff up for you, and you were limited to "novice" bands, that wouldn't be so bad.

 

If GMRS were bolted to business bands still, that wouldn't be so bad.

 

The problem is that fragmentation of the bandplan - and moreso the market - means network effects can't take off.

 

Even Motorola is pitching LTE as the new answer to trunked radio deployments. "Pay us a per-unit monthly fee, and we'll handle all the infrastructure for you". I can't help but wonder if this is aimed mostly at "FirstNet" users who don't need a smartphone, or who need something that can be operated without looking at it.

 

The problem with that is, ultimately, that it's rent-seeking. I want to pay $40 per radio, not $40 per month per radio.

I just switched over to FirstNet on my smartphone yesterday. Not sure id want my radios on it

 

Sent from my SM-G892A using Tapatalk

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Frankly, I want to know the real reason why the FCC requires you to use a Type 95 radio for GMRS... ...Who is this rule benefiting and why?

 

There was a petition in 2014 to add exception to the Type 95 rules to ham operators but it failed miserably....

I had assumed the first couple of responses had adequately addressed the original post. But, that seems to not be the case. So, I will give it a try...

 

#1) GMRS and Amateur radio are two completely separate services with different applications, users and purposes. In particular, the US Amateur Radio service is based on International agreements:

The amateur radio service (amateur service and amateur-satellite service) is established by the International Telecommunication Union (ITU) through the Radio Regulations. National governments regulate technical and operational characteristics of transmissions and issue individual stations licenses with an identifying call sign. Prospective amateur operators are tested for their understanding of key concepts in electronics and the host government's radio regulations.

#2) As the FCC made clear in its response to the 2014 petition, allowing non-certified radios to be used in the GMRS "would allow for the proliferation of home-built, non-standardized transmitters in the GMRS, with no practicable way for the Commission to monitor and enforce regulatory compliance for these devices." Further, allowing licensed amateurs to operate non-certified equipment in the GMRS would provide special privileges for users of one service operating in another, completely unrelated, service. This would be an extremely slippery slope, one any regulatory agency would want to avoid.

 

#3) Amateur Radio and GMRS each have their place in the world. I believe the FCC made the right decision. Blurring the boundary between the two would not result in any real benefit for anyone and might cause a lot of problems for both services.

 

#4) If you really want/must use ham gear on GMRS, go ahead, nobody is really going to stop you. Take responsibility for your action and operate accordingly. Just do not expect the FCC to officially condone your actions.

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I would never buy solely into commercial networks.  Don't get me wrong... I love my smartphone, but the regular failures and lack of coverage, even when everything on the commercial networks work correctly, are the very reasons "radio" comms are alive and well.

They're literally the reason I got into GMRS, too.

 

I just switched over to FirstNet on my smartphone yesterday. Not sure id want my radios on it

Any particular reason?  From what I heard, they're building out a boatload of "excess" capacity for that network.

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They're literally the reason I got into GMRS, too.

 

Any particular reason? From what I heard, they're building out a boatload of "excess" capacity for that network.

Its nothing against first net but i would prefer my radios to be on their own dedicated system seperate from the cell network. Or at least have a way to easily and quickly and easily switch off to a dedicated system.

 

My department just switched last year from analog to digital. Its been a rocky switch and some of the old timers have had a hard time changing their radio habits to better suit the digital system and radios.

 

Sent from my SM-G892A using Tapatalk

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FirstNet or FedNet as it should truly be called is another cellular  telephone system with its emphasis on data rather than voice. What ATT rightly understood about the win to build the network is it will/has turned into a money sink for the users. Even with the ability to ruthlessly preempt other Band 14 users and access to ATT's other bands the envisioned bandwidth will not be available at the scene of a major incident. There are a little over 12 million "first responders" and another 18 million other emergency responders as defined by the Homeland Security Act of 2001. The present governance is almost entirely in the hands of law enforcement who don't always play nicely in the sandbox with fire and EMS. Don't even ask them if the utility companies deserve to be included, they are very much opposed. In a disaster situation the two things most needed are water and electricity and you can't get that from law enforcement, fire or EMS. If I sound a little bitter about it, it's because I spent a good many years arguing that no responder or class of responder does their job alone but was not truly heard by the first responders or the Commission.

 

What the system lacks, and has been pointed out, is mission-critical voice communications. The cellular devices in use are a peer-to-peer connection while LMR or radio is a one-to-many. Say something on a channel and everyone on that channel in range hears that same message. That doesn't happen with cellular and, if and when it does come about it will be at the cost of the bandwidth needed for data.

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And nothing that the OP suggested would change any of that.  Adding an exception for already licensed HAMs to use their already existing and perfectly capable gear wouldn't change anything that's happening in GMRS currently for non HAM types using it.  Just means that we would have to spend less money on redundant equipment to stay within the letter of the law.  

 

Though I'm sure there's already plenty of combo HAM/GMRS guys running around with Amateur gear programmed for GMRS use.........

 

I might add that GMRS has tolerances as far as frequency that are far lower then most HAM gear. With GMRS being smack in the middle of the part 90 portion of the band it is important to maintain some type of standard as to not cause interference to the adjacent service. Requiring a type accepted and certified transmitter is the best way to do this. Posted this again just to be clear, I am a HAM but use part 90 gear for UHF and VHF. If the chart below posts you will see that typical HAM banded gear can allow error rates as high as 10ppm, With GMRS being a wide band service in the middle of the narrow banded part part 90 service its important to use certified transmitters. I have had plenty of HAM gear on my Aeroflex 2975, very little would pass 2.5ppm tolerance. 

 

http://mwgmrs.com/mygmrs/error.jpg

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Wideband equipment on GMRS allows 5ppm error, but stuff operating on the 467 interstitials requires 2.5ppm. I have seen ham gear off by 20ppm or more, and drifts of 10ppm per transmission. That's not really important since there is no type acceptance for Part 97; as long as the equipment stays in-band and doesn't have excessive out-of-band spurs. Running 30kHz deviation is fine. Running 4 kHz off-center is fine, but not optimal.

 

That's not really why there's type acceptance. Ham gear can generate nearly every emission. Part 90 gear can generate a good number of emissions, like TDMA digital voice or packet data. Both services allow for transmit power above 5 or 50 watts. None of those are allowed on GMRS, which is why there are type acceptance procedures in place. It also establishes a set of guidelines for manufacturers to follow when designing and marketing equipment to ensure interoperability across manufacturers.

 

Why there's a prohibition of having amateur and GMRS channels together on the same Part 90-certified and 'otherwise compliant' radio, I don't know. I would expect it to be a prohibition of marketing dual-service radios, given the difference in intended use and operational procedures between the two services.

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  • 5 months later...

Why there's a prohibition of having amateur and GMRS channels together on the same Part 90-certified and 'otherwise compliant' radio, I don't know. I would expect it to be a prohibition of marketing dual-service radios, given the difference in intended use and operational procedures between the two services.

 

https://transition.fcc.gov/oet/ea/presentations/files/nov17/54-Part-95-Misc-Eqpt-Filing-r1-TH.pdf

 

Page 13, second bullet.  Emphasis mine:

 

n149 Several commenters are concerned that the proposal to prohibit combination radios would prevent GMRS licensees from using surplus Part 90 equipment in GMRS. ... This is not our intent. We will continue to certify equipment that meets the respective technical standards for Part 90 (land mobile) and Part 95 (GMRS) in both services, if requested. However, we are amending the language in new section 95.1761© to clarify the requirement in old section 95.655(a) that Part 95 GMRS radios will not be certified if they are equipped with the capabilities to operate in services that do not require equipment certification, such as the Amateur Radio Service.
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Why there's a prohibition of having amateur and GMRS channels together on the same Part 90-certified and 'otherwise compliant' radio, I don't know. I would expect it to be a prohibition of marketing dual-service radios, given the difference in intended use and operational procedures between the two services.

 

This point is interesting.

 

Consider the following. I have a Kenwood TK-370-1 (wide band only) and a couple of Kenwood TK-370G-1 (wide and narrow band) radios. Both by the way are certified for Part 95 by the way. The TK-370-1 has an FCC ID of ALHTK-370-1 which shows a Part 95 certification. The TK-370G-1 has an FCC ID of ALH29473110 with a Part 95A certification which under the old rules was GMRS. You will also notice both radios also have a Part 90 certification too.

 

Both radios have a stated spec of 450 to 470 MHz frequency range but will program down into the upper section of the Ham 70cm band, 440 to 450 typically for the main FM operations, and will work there.

 

Since nether radio was physically modified, which would invalidate the certification, just programmed for both services, the FCC should not have a problem with using the same radio for both services. Hams are allowed to use radios for other services on the Ham bands so long as they meet emission requirements.

 

So the point here is if you want to have access to both services you need to look very carefully for radios that have the Part 95 certification and can be programmed for the Ham 70cm band. With a Part 95 certification in addition to the Part 90 which should not be a disqualification.

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That FCC publication strongly implies that part 90 radios may be used on part 95 without specific certification; it also implies that 90/95 dual service certification will continue to be available.

 

The way I see it, the golden radio is something like the GD-77s -- part 90 certified ham radios.  They'll tune the whole 70cm band, and the 90 cert implies it may be used on GMRS, per that publication.

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The FCC has tested/certified an independent test facility report the radio used for this service meets the technical requirements for emission type, stability and power. It benefits other users of this service by  ensuring radios will not cause undue interference to other users and those in adjacent services.

Frankly, I want to know the real reason why the FCC requires you to use a Type 95 radio for GMRS. Suppose you're a licensed ham AND have your GMRS license. This rule just means I've got to purchase additional radios to lug around. Who is this rule benefiting and why?

There was a petition in 2014 to add exception to the Type 95 rules to ham operators but it failed miserably.

 

Thanks

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That FCC publication strongly implies that part 90 radios may be used on part 95 without specific certification; it also implies that 90/95 dual service certification will continue to be available.

I disagree with the part about part 90 radios are "legal" to use for part 95. Their (FCC) statement about the Boufang (sp?) debacle was to make it clear that "IF" a part 90 radio was submitted, it would be considered for part 95, unlike the part 90/frs/ham radios (they won't be considered).

Regardless, I don't think anyone would find fault with using a part 90 radio on GMRS. :) 

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