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Unlicensed/unauthorized bubblepack inundation on 462.600 and 725


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Several of us in California (bay area and Sacramento) have become inundated with many unlicensed business users on our repeater outputs.  Interestingly, most of these users operate the following:

 

TX/RX 462.600 D455

TX/RX 462.725 D252

 

While our repeaters can cover them in some cases, there are so many bubblepacks that they are reducing our ability to hear simplex/direct mode traffic or more distant repeaters.  None of these users have a callsign, and they are operating wideband (we can tell they are wideband due to their 4-5 kHz deviation and resulting volume; narrowband should be lower volume and 2.5 kHz peak deviation). 

 

We reached out to several users who all advised they had "RT15" radios.   

 

https://tinyurl.com/tmu48vq

 

A customer posted the frequency listing for this "FRS" radio showing the two DCS codes above (actually the inverted codes; D322 Inverted = D455 Non-Inverted, and D462 Inverted = D252 Non-Inverted).  So this confirms the user info.  But it has a few problems:

 

Defaulted wideband (essentially creating a GMRS radio)

Capable of voice encryption

Contains a non-FRS channel (462.825)

 

According to the new rules, radios marketed and Type Certified as FRS cannot operate wideband or have encryption, let alone have a Part 90 channel in them.  Of course, when asked, the seller replies that the programming cable is available, and I found the software is downloadable for free.  

 

Various violations here:

 

§95.591   Sales of FRS combination radios prohibited. (does wideband make this a GMRS radio??)

§95.575   FRS modulation limits (exceeded)

§95.587   FRS additional requirements.

 

 - (a) Transmit frequency capability. FRS transmitter types must not be capable of transmitting on any frequency or channel other than those listed in §95.563 

(462.825??)

 

 - (e) Effective September 30, 2019, no person shall manufacture or import hand-held portable radio equipment capable of operating under this subpart (FRS) and other licensed or licensed-by-rule services in this chapter (part 15 unlicensed equipment authorizations are permitted if consistent with part 15 rules).

 

The user manual that was submitted for FCC certification shows 2.5 kHz deviation, no scrambling.  The current manual now shows 5 kHz deviation and scrambling.   

 

Anyone else getting slammed with these things? 

 

post-49-0-90805600-1576280302_thumb.jpg

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It's an issue you should raise to the Commission; I bet this was an oversight by the TCB or (more likely) changes made illegally after certification. If this ended up getting handled properly, those radios would be recalled and Retevis fined. We both know those kinds of results never happen. If we're lucky (and the FCC does their job), the type certification may be revoked.

 

They're not combination FRS/GMRS radios, they're operating outside of their type acceptance. These were granted type acceptance well after the deadline for certification of combination radios.

 

You're probably best off getting a FCC representative on the phone. These rules are being violated:

  • 95.337 (additional channels made available by modification) per 95.361(c ) and 95.563
  • 95.381 (voice scrambling)
  • 95.363(c ) (additional channels can be programmed into the radio, but this may not be the manufacturer's responsibility; programming software allowing this will be the issue at hand)
  • 95.587(a) (radio can transmit on non-FRS channel/bandwidth).

As of right now, the users are in the wrong, but your only course of action is to tell them they're operating illegally and to contact the FCC about the above problems; you can't take matters into your own hands or jam their channel. You're a licensed user receiving harmful interference from unlicensed users operating equipment outside of type acceptance parameters. That alone should be enough. The manufacturer should have liability under 2.937.

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As of right now, the users are in the wrong, but your only course of action is to tell them they're operating illegally and to contact the FCC about the above problems; you can't take matters into your own hands or jam their channel. You're a licensed user receiving harmful interference from unlicensed users operating equipment outside of type acceptance parameters. That alone should be enough. The manufacturer should have liability under 2.937.

 

Its not like I want to program my repeater for their output code, with a long hangtime, and set a recurring Morse Code ID to fire off every 15 minutes at one word per minute.....

 

We used to ask the user who they purchased their radio from, and then deal with that supplier - usually local.  So here we may never find who that is in this case.   The last time the Commission dealt with this kind if thing, I believe they went after the US sales representative, not the manufacturer.  

 

Its the holidays, so I may have time to follow-up with the Commission.   This one is relatively easy. 

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