Midland GMRS Product updates

[berkinet]

As a former Part 90 frequency coordinator...

 

Except Part90 ≠ Part95. You have taken Part90 rules (47 CFR Chapter I - FEDERAL COMMUNICATIONS COMMISSION; Subchapter D - SAFETY AND SPECIAL RADIO SERVICES; PART 90 - PRIVATE LAND MOBILE RADIO SERVICES (§§ 90.1 - 90.1338)) and seek to apply them to Part95. While Parts 90 & 95 are both contained in Subchapter D, they are separate, independent and unrelated.

[BoxCar]

From my experience dealing with both the WTB and PSHS is they have no issues with applying rules and restrictions from one section or part to another in their interpretations of a particular rule. It is virtually impossible for laymen, such as ourselves, be aware of all the past filings and rules touching on any aspect of equipment certification or rule applicability. We may have the means, but lack the training, of searching the record for any discussion, petition, rule or interpretation that may be given in any discussion regarding how we view the applicability of one section of the rules to our discussion. The interpretation of the rules regarding equipment certifications and modifications to the stated operating parameters of equipment are best left to the Commission. The rules explicitly tell what is and isn't permissible. Changes to those permissions and restrictions must come through Commission proceedings. In the particular instance of the Midland radios certified under Part 95 it explicitly states narrow emissions only and does not imply modification to wide emissions is allowed within the confines of their certification. As end-users of the product we lack the means and equipment to ensure the radio does not generate spurious emissions exceeding Commission requirements when operating with increased bandwidth. As the final point, our interpretation of a particular rule allows the Commission to either agree or disagree with no middle ground.

[berkinet]

From my experience dealing with both the WTB and PSHS is they have no issues with applying rules and restrictions from one section or part to another in their interpretations of a particular rule. It is virtually impossible for laymen, such as ourselves, be aware of all the past filings and rules touching on any aspect of equipment certification or rule applicability. ...

 

... The interpretation of the rules regarding equipment certifications and modifications to the stated operating parameters of equipment are best left to the Commission. The rules explicitly tell what is and isn't permissible. ...

 

So, essentially we are all too ignorant to read the FCC rules, which you state explicitly tell what is and isn't permissible. That seems to be a bit of a contradiction.  Because, if we do stick to the rules, then they tell us, as noted previously, that the modulation (not Emissions Designator) cannot be changed. Explicitly, the rules prohibit: ...altering the amplitude, frequency and/or phase of a radio frequency carrier. However, the rules do not say the bandwidth cannot be changed.

 

However, if we stick to your primary premises that we are too ignorant, and must let the commission decide anything and everything, then I would ask why there is absolutely no record of anybody ever having been cited for operation of non-certified equipment in the GMRS, let alone for modifying a GMRS radio? Is that not evidence of how the FCC views the use of non-certified and modified equipment?

 

I personally believe the FCC provided the rules and regulations for a purpose, and that purpose was to guide operators and manufacturers in appropriate use of the different radio services. I would neither take it upon myself to assume something not stated in those regulations.

 

And, finally, we live in a country with a well defined legal process.  In a court of law, it is the regulations as written, plus any previous applicable court law that counts. The FCC's opinion is worth absolutely no more, and no less, than anyone else's opinion.

[BoxCar]

I'm bowing out of this discussion so let it be said we agree to disagree.

[uplander]

When I opened the the software and downloaded my MTX400 current programming as it came from the factory, channels 1-7 and 15-22 were spaced at 12.5K, the repeater channels 23-30 were already spaced at 25K .

 

The only thing I did with the software was add split tones to the repeater channels that needed split tones. Midland either always made the repeater channels 25K or changed it at some point of production. My radio was new and sealed in packaging so it had to be programmed that way from the factory

[berkinet]

When I opened the the software and downloaded my MTX400 current programming as it came from the factory, channels 1-7 and 15-22 were spaced at 12.5K, the repeater channels 23-30 were already spaced at 25K ...

Note there is a difference between channel spacing, the frequency difference between the center frequency of two adjacent channels, and occupied bandwith, the amount of deviation of the signal around the center frequency.

[Hans]

Except Part90 ≠ Part95. You have taken Part90 rules (47 CFR Chapter I - FEDERAL COMMUNICATIONS COMMISSION; Subchapter D - SAFETY AND SPECIAL RADIO SERVICES; PART 90 - PRIVATE LAND MOBILE RADIO SERVICES (§§ 90.1 - 90.1338)) and seek to apply them to Part95. While Parts 90 & 95 are both contained in Subchapter D, they are separate, independent and unrelated.

^^^ This ^^^

[Hans]

So, essentially we are all too ignorant to read the FCC rules, which you state explicitly tell what is and isn't permissible. That seems to be a bit of a contradiction.  Because, if we do stick to the rules, then they tell us, as noted previously, that the modulation (not Emissions Designator) cannot be changed. Explicitly, the rules prohibit: ...altering the amplitude, frequency and/or phase of a radio frequency carrier. However, the rules do not say the bandwidth cannot be changed.

 

However, if we stick to your primary premises that we are too ignorant, and must let the commission decide anything and everything, then I would ask why there is absolutely no record of anybody ever having been cited for operation of non-certified equipment in the GMRS, let alone for modifying a GMRS radio? Is that not evidence of how the FCC views the use of non-certified and modified equipment?

 

I personally believe the FCC provided the rules and regulations for a purpose, and that purpose was to guide operators and manufacturers in appropriate use of the different radio services. I would neither take it upon myself to assume something not stated in those regulations.

 

And, finally, we live in a country with a well defined legal process.  In a court of law, it is the regulations as written, plus any previous applicable court law that counts. The FCC's opinion is worth absolutely no more, and no less, than anyone else's opinion.

This is awesome. I don't even have to post.

[Hans]

When I opened the the software and downloaded my MTX400 current programming as it came from the factory, channels 1-7 and 15-22 were spaced at 12.5K, the repeater channels 23-30 were already spaced at 25K .

 

The only thing I did with the software was add split tones to the repeater channels that needed split tones. Midland either always made the repeater channels 25K or changed it at some point of production. My radio was new and sealed in packaging so it had to be programmed that way from the factory

Thanks for that. It's a good data point.

 

It would make sense that, at least by now, they made those repeater channels WFM.

 

Edited: Oops. I didn't read that through. Thankfully, berkinet caught the possible snag.

[uplander]

Note there is a difference between channel spacing, the frequency difference between the center frequency of two adjacent channels, and occupied bandwith, the amount of deviation of the signal around the center frequency.

 It shows the channel step as 25K and the channel spacing at either 12.5K or 25K. I have to assume you never looked at the video linked in the post that you pointed out that that info was posted earlier in July except the video was not on that post.

[mbrun]

I am thinking this thread has run its course. Perhaps a new thread with a new focused question or point of discussion is appropriate.

 

YMMV.

 

Michael

WRHS965

 

 

Sent from my iPad using Tapatalk

[marcspaz]

This thread was DOA thanks to the OP. Not sure it matters what we discuss now.

 

LoL

[Hans]

I am still curious if uplander found the more current Midlands to have the repeater channels set actual WFM from the factory. Confirmation of such a detail would be important.

[marcspaz]

Agreed. It would be a smart move for Midland and a win for entry level operators.

[Elkhunter521]

Would advertising make them admit they were wrong?

 

Or would they just change and NOT mention it?

[marcspaz]

I highly doubt they would make a big deal about it.  Mostly because I think most people who buy their gear have no idea what they would even be talking about. 

 

If I were to guess, I would suspect that it will be quietly released as either V3 or MXT400a (etc.) and just update the bulleted feature list.  Of course... just a WAG.

[tweiss3]

So is there a new certification or did they just make their product non compliant with part 95?

[berkinet]

So is there a new certification or did they just make their product non compliant with part 95?

...Or, did they change anything at all?

[Hans]

That is the question.

[marcspaz]

Like I mentioned, I have not found any new certifications in the database. Pending, approved or otherwise.

 

I guess someone is going to have to call them.

[berkinet]

...I guess someone is going to have to call them.

 

Or, put a radio on a test bench.

[uplander]

I am still curious if uplander found the more current Midlands to have the repeater channels set actual WFM from the factory. Confirmation of such a detail would be important.

All I can add to this is that I bought the Midland 400 not knowing much accept is was FCC type certified. Like a lot of new users we buy a unit and then start to research more about the usage. This case being GMRS. I really bought the unit to put in my Jeep for trail communications not wanting to buy into a dead horse IE CB. 

 

I have a brother who has been into HAM since the 70's and so I understood in a basic way of repeaters and such. GMRS has so much more to offer than just a trail radio and I wanted to use it to its fullest extent. That is how I found its shortcomings in the areas of using it with repeaters.

 

I overheard a discussion on the radio one night ( on a repeater channel) of how someone got software and instructions from a Midland engineer and how he was going to post a video on how to do it along with a link for the programming software on the Midwest GMRS forum. I had found snippets of this before of this but no definitive "how to". 

 

Anyway I'm getting off point here. I watched that video and downloaded the software. I bought the programming cable from Midland. The original video was taken down because it had repeater codes showing in the video. 

 

he redid the video without the codes showing.

 

In the video he showed how the change the bandwidth from 12.5K to 25K. When he had the software read and download its current settings , the repeater channels as well as all the other channels were set to 12.5K. 

 

When I read and downloaded my radios settings I was surprised to see the repeater channel band width already set to 25K. This is how it came from the factory. I ordered that radio on August 10th. I didn't do anything to this radio up to then except turn on the repeater channel function and load tones for use from the front panel of the radio. Yes from the front panel of the radio you can only load one tone for both the input and output of said repeater channel. That tone had to be the same for input and output so that limited me to only repeaters using the same tone in and out.

 

In the end I now have a radio that functions within the limits set for GMRS radios. I fail to see how using the software to use split tones or change the bandwidth ( which I didn't as it came from the factory that way) would make this radio illegal. It may invalidate the FCC type certification but I really doubt it. 

 

I would think type certification is really just a bonus for the manufacturer in terms of marketing. 

 

How many of you in this discussion are using radios not certified but within the rules?  It sounds to me like most of you are using commercial radios programmed to within the GMRS parameters. Are they type certified? 

[Hans]

All I can add to this is that I bought the Midland 400 not knowing much accept is was FCC type certified. Like a lot of new users we buy a unit and then start to research more about the usage. This case being GMRS. I really bought the unit to put in my Jeep for trail communications not wanting to buy into a dead horse IE CB. 

 

I have a brother who has been into HAM since the 70's and so I understood in a basic way of repeaters and such. GMRS has so much more to offer than just a trail radio and I wanted to use it to its fullest extent. That is how I found its shortcomings in the areas of using it with repeaters.

 

I overheard a discussion on the radio one night ( on a repeater channel) of how someone got software and instructions from a Midland engineer and how he was going to post a video on how to do it along with a link for the programming software on the Midwest GMRS forum. I had found snippets of this before of this but no definitive "how to". 

 

Anyway I'm getting off point here. I watched that video and downloaded the software. I bought the programming cable from Midland. The original video was taken down because it had repeater codes showing in the video. 

 

he redid the video without the codes showing.

 

In the video he showed how the change the bandwidth from 12.5K to 25K. When he had the software read and download its current settings , the repeater channels as well as all the other channels were set to 12.5K. 

 

When I read and downloaded my radios settings I was surprised to see the repeater channel band width already set to 25K. This is how it came from the factory. I ordered that radio on August 10th. I didn't do anything to this radio up to then except turn on the repeater channel function and load tones for use from the front panel of the radio. Yes from the front panel of the radio you can only load one tone for both the input and output of said repeater channel. That tone had to be the same for input and output so that limited me to only repeaters using the same tone in and out.

 

In the end I now have a radio that functions within the limits set for GMRS radios. I fail to see how using the software to use split tones or change the bandwidth ( which I didn't as it came from the factory that way) would make this radio illegal. It may invalidate the FCC type certification but I really doubt it. 

 

I would think type certification is really just a bonus for the manufacturer in terms of marketing. 

 

How many of you in this discussion are using radios not certified but within the rules?  It sounds to me like most of you are using commercial radios programmed to within the GMRS parameters. Are they type certified? 

 

That's exactly what we needed to know and it is very good news. Awesome post! Thanks.

 

[Hans]

All I can add to this is that I bought the Midland 400 not knowing much accept is was FCC type certified. Like a lot of new users we buy a unit and then start to research more about the usage. This case being GMRS. I really bought the unit to put in my Jeep for trail communications not wanting to buy into a dead horse IE CB. 

 

I have a brother who has been into HAM since the 70's and so I understood in a basic way of repeaters and such. GMRS has so much more to offer than just a trail radio and I wanted to use it to its fullest extent. That is how I found its shortcomings in the areas of using it with repeaters.

 

I overheard a discussion on the radio one night ( on a repeater channel) of how someone got software and instructions from a Midland engineer and how he was going to post a video on how to do it along with a link for the programming software on the Midwest GMRS forum. I had found snippets of this before of this but no definitive "how to". 

 

Anyway I'm getting off point here. I watched that video and downloaded the software. I bought the programming cable from Midland. The original video was taken down because it had repeater codes showing in the video. 

 

he redid the video without the codes showing.

 

In the video he showed how the change the bandwidth from 12.5K to 25K. When he had the software read and download its current settings , the repeater channels as well as all the other channels were set to 12.5K. 

 

When I read and downloaded my radios settings I was surprised to see the repeater channel band width already set to 25K. This is how it came from the factory. I ordered that radio on August 10th. I didn't do anything to this radio up to then except turn on the repeater channel function and load tones for use from the front panel of the radio. Yes from the front panel of the radio you can only load one tone for both the input and output of said repeater channel. That tone had to be the same for input and output so that limited me to only repeaters using the same tone in and out.

 

In the end I now have a radio that functions within the limits set for GMRS radios. I fail to see how using the software to use split tones or change the bandwidth ( which I didn't as it came from the factory that way) would make this radio illegal. It may invalidate the FCC type certification but I really doubt it. 

 

I would think type certification is really just a bonus for the manufacturer in terms of marketing. 

 

How many of you in this discussion are using radios not certified but within the rules?  It sounds to me like most of you are using commercial radios programmed to within the GMRS parameters. Are they type certified? 

 

Although the claim is made, even as recently as a page or so back in this thread, that LMR certified (Part 90) radios may be used, that does not appear to me to be the case at all. What is typically quoted is § 95.335 but something is missing from the language to allow LMR only certified radios to be used in GMRS.

 

While § 95.335 ( a ) does make the exception, it also qualifies the exception with "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." § 95.1761 gives no exception parameters in GMRS and the example reference, § 95.1735, no longer exists. It is now reserved. Therefore, it is my opinion that there is no exception for LMR certified radios that are not also GMRS certified to be used in the GMRS service.

 

 

§ 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.

 

( c ) 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.

§ 95.1761 GMRS transmitter certification.

( a ) Each GMRS transmitter (a transmitter that operates or is intended to operate in the GMRS) must be certified in accordance with this subpart and part 2 of this chapter.

( b ) A grant of equipment certification for the GMRS will not be issued for any GMRS transmitter type that fails to comply with the applicable rules in this subpart.

( c ) No GMRS transmitter will be certified for use in the GMRS if it is equipped with a frequency capability not listed in § 95.1763, unless such transmitter is also certified for use in another radio service for which the frequency is authorized and for which certification is also required. No GMRS transmitter will be certified for use in the GMRS if it is equipped with the capabilities to operate in services that do not require equipment certification, such as the Amateur Radio Service. All frequency determining circuitry (including crystals) and programming controls in each GMRS transmitter must be internal to the transmitter and must not be accessible from the exterior of the transmitter operating panel or from the exterior of the transmitter enclosure.

( d ) Effective December 27, 2017, the Commission will no longer issue a grant of equipment authorization for hand-held portable unit transmitter types under both this subpart (GMRS) and subpart B of this part (FRS).

( e ) Effective December 27, 2017, the Commission will no longer issue a grant of equipment authorization under this subpart (GMRS) for hand-held portable units if such units meet the requirements to be certified under subpart B of this part (FRS).

 

§§ 95.1735-95.1739 [ Reserved ]

[marcspaz]

 

 

Although the claim is made, even as recently as a page or so back in this thread, that LMR certified (Part 90) radios may be used, that does not appear to me to be the case at all.

 

We have had this conversation several times in the past year or so. We have repeater owners on this very forum using part 90 equipment that have had several site inspections done by the FCC and found in full compliance. Part 90 LMR radios are allowed.