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The never-ending Part 90/95 debate, and my discussion with the FCC


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On 6/15/2021 at 11:55 PM, wayoverthere said:

so...one other tidbit i noticed when reading poking around 95e (https://www.law.cornell.edu/cfr/text/47/95.1761) is (c), which seems to imply 95e/90 dual certification is still POSSIBLE, but can't overlap with ham (being a non-certified service).

 

also found some interesting (good) suggestions on radioreference, for text to go into 95.1735, since that section is currently "reserved".

This document is often referred to support what you're saying.

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

Attached the 3 mainly relevant slides regarding GMRS.

In the notes the OET says

Quote

Per n149 of FCC 17-57, the preceding serves to “clarify” the preceding/replaced 95.655(a):

– 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(c) 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.

 

54-Part-95-Misc-Eqpt-Filing-r1-TH1.jpg

54-Part-95-Misc-Eqpt-Filing-r1-TH2.jpg

54-Part-95-Misc-Eqpt-Filing-r1-TH3.jpg

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4 hours ago, WRNA236 said:

This document is often referred to support what you're saying.

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

Attached the 3 mainly relevant slides regarding GMRS.

While I've seen the document before, seeing it combined with the code really adds some context, as the wording in the document fits with the bit of the code I was pointing out.   I know it doesn't say QUITE what we want it to, in being able to equate part 90 approval with part 95 approval, but it's kind of interesting to see the statement they made in the document about dual approval being reflected in the code.

The fact remains that, though there IS still some avenue for dual approval (would the 450-512 split radios qualify, since they'd officially fall entirely outside amateur bands?), it doesn't seem that any of the major manufacturers are making the effort.

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17 hours ago, wayoverthere said:

The fact remains that, though there IS still some avenue for dual approval (would the 450-512 split radios qualify, since they'd officially fall entirely outside amateur bands?), it doesn't seem that any of the major manufacturers are making the effort.

I suspect this the case. I’ve looked at the FCC grants for several of my Kenwood HT’s. They come in several different band splits. The models where the lower “official” frequency limit is 450MHz had Part 90 and 95 certification while the 400MHz-470MHz models did not, typically just Part 90.

 

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18 minutes ago, Lscott said:

I suspect this the case. I’ve looked at the FCC grants for several of my Kenwood HT’s. They come in several different band splits. The models where the lower “official” frequency limit is 450MHz had Part 90 and 95 certification while the 400MHz-470MHz models did not, typically just Part 90.

 

Interesting, I also may have jumped the gun then...i'd be curious how their certification dates compare to the implementation dates of that presentation and/or revised wording in the code, and whether theyre certified under 95a or 95e.

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2 hours ago, wayoverthere said:

Interesting, I also may have jumped the gun then...i'd be curious how their certification dates compare to the implementation dates of that presentation and/or revised wording in the code, and whether theyre certified under 95a or 95e.

Just spot checked a few IDs and their FCC listed ranges.  The only non-95 I knew was the TK-3170 but I can't say whether it is ever used for GMRS or not.  Does seem to support the intent to not grant 95 for radios covering amateur bands.  These grants date back prior to 2017 I think in all cases.  Anything newer than this will be likely not submitted by Kenwood/Vertex/Motorola and might not be strictly the book (e.g. suspect for use as reference).  Midland probably submits valid data but they wouldn't have any models with the necessary features for consideration.

 

Kenwood TK-3170 ALH34713130 400-430 22, 74, 90, 90.21
Kenwood TK-3180 ALH37333110 450-490 22, 74, 90, 95A
Kenwood TK-3130 ALH33293110 460-470 90, 95A
Kenwood TK-3180 ALH37333110 450-520 22, 74, 90, 90.210, 95A
Kenwood TK-3200 ALH36923130 450-470 90, 90.210, 95A
Kenwood TK-3230 ALH383200 460-470 90, 95A
Kenwood TK-8150 ALH32283110 450-500 90, 90.210, 95
Kenwood TK-8180 K4437313110 450-520 22, 74, 90, 90.210, 95A
Kenwood TK-8180-H K4437313210 450-520 22, 74, 90, 90.210, 95A
Kenwood TK-860H ALH29383210 450-490 22, 74, 90, 90.210, 95
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