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Repeater ID change?


gscanter

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§ 95.1751 GMRS station identification.

Each GMRS station must be identified by transmission of its FCC-assigned call sign at the end of transmissions and at periodic intervals during transmissions except as provided in paragraph (c) of this section. A unit number may be included after the call sign in the identification.

...

(c) Any GMRS repeater station is not required to transmit station identification if:

(1) It retransmits only communications from GMRS stations operating under authority of the individual license under which it operates; and,

(2) The GMRS stations whose communications are retransmitted are properly identified in accordance with this section.

 

"GMRS station" includes repeaters.  But read subpart (c)(2).  That seems to state that, as long as every user is operating under the license associated with that repeater, or every user on a repeater is ID'ing correctly, then the repeater itself does not have to ID.

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My suggestion is to study the FCC statement carefully and make your own decision because around here you'll get conflicting views. I cite this thread for example, where I questioned the need for an auto ID but was quickly told that you absolutely have to have one;

BTW, when I get a repeater up and running I am not putting an ID on it. I will however make the repeater private and not hand out any PL tones until the person wanting to use it submits a form that reiterates that he or she comply by all FCC rules including the proper call sign usage. This isn't a firewall by any sense because anyone with a tone scanner can figure it out and secondly, anyone can submit bogus information on my request form. At the minimum it shows that I have made the effort to control who access the repeater.

 

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A repeater transmits only when a signalis received on its input meeting the proper conditions, A repeater transmitter is no different than a handheld, mobile or base station none of which are required to transmit a periodic identification signal. What is required is the signal sent through, not by, the Part 95 repeater be identified by the signal originator. The point being is the rules are predicated on an operator originating a transmssion.

The real issue with the rules and their interpretation is the rules are written with the assumption there is a physical operator (person) operating a station when it transmits. Automated stations do not have a physical operator to initiate a transmission so therefore, under a strict interpretation of the Part 95 rules a repeater does not have to initiate a transmission for identification but, in order to cover all situations, an identifier transmission is a prudent operational necessity. This goes back to the requirement that repeater users are both authorized and follow the rules for identification.

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OK I just realized that I missed something important when I looked at that section:  "and"!

(1) It retransmits only communications from GMRS stations operating under authority of the individual license under which it operates; and,

(2) The GMRS stations whose communications are retransmitted are properly identified in accordance with this section.

Notice that it also says "under which it operates", so it's talking about the repeater, not about the stations using the repeater.  So if you stand up a repeater that is only going to be used by your family, under your GMRS license, and all the users identify as required, the repeater does not have to ID.

Otherwise, the repeater is required to ID every 15 minutes as described in that same section, although it is implied that this is only while the repeater is in use.

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Quote

under authority of the individual license under which it operates

It's my repeater licensed by me and under my authority I will allow you to use it as long as you have a license and use your call sign as required. If that's not the case then there's hundreds perhaps thousands of repeaters no meeting requirements.

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On 12/16/2021 at 6:54 PM, wrci350 said:
§ 95.1751 GMRS station identification.

Each GMRS station must be identified by transmission of its FCC-assigned call sign at the end of transmissions and at periodic intervals during transmissions except as provided in paragraph (c) of this section. A unit number may be included after the call sign in the identification.

...

(c) Any GMRS repeater station is not required to transmit station identification if:

(1) It retransmits only communications from GMRS stations operating under authority of the individual license under which it operates; and,

(2) The GMRS stations whose communications are retransmitted are properly identified in accordance with this section.

 

"GMRS station" includes repeaters.  But read subpart (c)(2).  That seems to state that, as long as every user is operating under the license associated with that repeater, or every user on a repeater is ID'ing correctly, then the repeater itself does not have to ID.

Read this carefully.  If you have a repeater and everyone is properly IDing on it, you are fine.  If they are NOT properly IDing, then they are violating the regulation but so are you by "allowing" them to access the repeater.  If the repeater does ID then you are covered on that front.  Now what that means is if you don't have the ability to immediately down the repeater (sort of hard with JUST a back to back cable) then you are allowing them to operate on your repeater illegally.  This is a common thing with HAM and why every repeater controller has a disable function.  It's YOUR responsibility to control your transmitter, including the transmitter on your repeater. 

And remember that while part 95 specifically pertains to GMRS, there are other regulations outside of part 95 that apply to all radio services. 

If you don't want to program your call sign into your repeater, or you have two mobiles with a back to back cable between them and are calling that a repeater and are too cheap to buy a CW ID board or build one up with a Raspberry Pi or an Arduino, that's on you.  Because ONE of those regulations that applies to overall radio communications and all services is if you get your license pulled for being dumb..... it's not JUST your GMRS license they take away.  You can loose the ability to have ANY FCC issued license.  SO no part 90 commercial, ham radio, or broadcast license either. 

I said what I said to cover your butt and mine.  Because in truth, it's MY call sign on the profile... and if you get dinged and are all crying to a lawyer about it, saying you heard it on the interwebs from me.  It may or may NOT be a winnable case if you sue me,,, but the FCC will get their money first and lawyers to defend dumb lawsuits are not cheap. 

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I am going to break in down in a different way.

- Every GMRS radio that transmits a signal is a “station”.
- Every station is required to ID using the callsign of the station licensee, according the rules.
- When a simplex radio transmits the operator is required to ID and it is carried on the frequency they are transmitting on. Any listener to that frequency can hear the ID.
- When a duplex operator transmits from their station, the operator is required to ID. That ID is carried on their transmit frequency and it will be picked up by the repeater and any other listener to that frequency.
- When a repeater owner transmits through their repeater, their ID is first carried on their radio’s transmit frequency. When the repeater receives and retransmits their signal, their ID is then carried on the frequency that the repeater sends out, thus the repeater can also be said to have identified. All stations operating under the authority of that licensee thus have been identified.
- When a repeater owner is not using the repeater, but instead it is being used exclusively by others during any given 15 minute usage interval, the required ID of the station owner never occurs. While those using it may have ID’d themselves, the repeater station has technically never ID’d itself. If repeater owner is one vacation and the repeater is used by others for a whole week, then the station has, according to the rules, not identified in a week.

Hope this helps some.


Michael
WRHS965
KE8PLM

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8 hours ago, Lscott said:

Your last point above is VERY important and a source of confusion with repeater owners. If a repeater is used by anyone not using, operating under, the repeater owners license the repeater MUST self ID using the owners call sign.

Yes, and that owner/operator is the 'manager' of that transmitter.  He has control of the repeater the same as the non-owner system user has control of his radio via the PTT button.  If I have a repeater located at my home or a tower that I have access to where MY equipment is installed, I need to have positive control of that equipment.  That is for when the equipment has a failure and gets stuck in transmit, is off frequency and causing interference on an adjacent channel or someone that is operating without regard to the regulations for GMRS then I as the owner need to shut down that repeater. 

The reason that you are allowed to NOT have an ID be transmitted on a private repeater that is ONLY used under the owners license is THEY are required to ID.  When they ID, since it's the repeaters call sign that covers the ID for the subscriber radio (mobile, portable or base station) AND the repeater. 

 

If ANYONE else is on that repeater, that repeater has to ID.  And the reason is simple.  Unlike commercial repeater licenses that indicate WHERE a repeater is located, when a GMRS repeater is at a remote location, there is no FCC record of that transmitter.  And if it's not IDing, the FCC has no idea who's repeater it is.  That's why the repeater has to ID if others are using it. 

I ain't the FCC and I ain't your daddy.  Do what you want.  But don't blame ME when you get dinged.

 

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Repeater ID can be done in many ways but it doesn't need to be automated and broadcast when not relaying a transmission. The repeater would be properly identified if I stated this is call sign using repeater call sign or the repeater did transmit a CW id after carrying a transmission but otherwise remained silent. The reuirement is met.

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2 hours ago, BoxCar said:

Repeater ID can be done in many ways but it doesn't need to be automated and broadcast when not relaying a transmission. The repeater would be properly identified if I stated this is call sign using repeater call sign or the repeater did transmit a CW id after carrying a transmission but otherwise remained silent. The reuirement is met.

Interesting point. However if the station(s) using the repeater forgot or deliberately don’t include the owners ID said owner will have some explaining to do with the FCC if they come asking questions. If the ID is automated the owner doesn’t have to constantly monitor it to ensure people are including the owners ID. Just makes life simpler for the repeater owner that way.

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10 hours ago, BoxCar said:

Repeater ID can be done in many ways but it doesn't need to be automated and broadcast when not relaying a transmission. The repeater would be properly identified if I stated this is call sign using repeater call sign or the repeater did transmit a CW id after carrying a transmission but otherwise remained silent. The reuirement is met.

 

7 hours ago, Lscott said:

Interesting point. However if the station(s) using the repeater forgot or deliberately don’t include the owners ID said owner will have some explaining to do with the FCC if they come asking questions. If the ID is automated the owner doesn’t have to constantly monitor it to ensure people are including the owners ID. Just makes life simpler for the repeater owner that way.

I think what he is getting at is if the repeater is dormant for 10 days, it wouldn't need to ID. It's the reason many ham repeaters push the ID rate out to 30 or 60 minutes instead of every 10 minutes, and it changes when there is traffic.

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5 hours ago, tweiss3 said:

 

I think what he is getting at is if the repeater is dormant for 10 days, it wouldn't need to ID. It's the reason many ham repeaters push the ID rate out to 30 or 60 minutes instead of every 10 minutes, and it changes when there is traffic.

The repeater doesn’t need to ID if it isn’t actively being used, agreed. 

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