Why really some folks say GMRS repeater linking is illegal

[jwilkers]

 

 

The applicable rule in this matter is §95.1733(a)(8) which prohibits any messages which are both conveyed by (any form of) wireline control link (which will include internet connections) and transmitted by a GMRS station.

 

GMRS was created with the intent of being a short range service not a bunch of interconnected repeaters for worldwide use (that’s the realm of amateur radio, common carrier services, and the internet).

 

https://www.ecfr.gov/current/title-47/chapter-I/subchapter-D/part-95/subpart-E/section-95.1733

 

Sent from my SM-A136U using Tapatalk

 

 

[Lscott]

Here is another analysis. Just another point of view.

http://www.nsea.com/Linking.pdf

[KAF6045]

Non-sequitur comment: If KAA8142 truly is the oldest extant individual GMRS license going back to 1970, and if the FCC issued sequential calls, there must not have been much activity over the 20+ years to my call... 10 thousand for the numeric, and only going from A to F -- that's about 50,000 calls issued in 20 odd years...

FCC must not be using sequential calls, or it has a separate pool (since class D/CB used to get the same AAA9999 format).

 

[JeepCrawler98]

Define wireline using the CFR Title 47 definitions please. Same for where the rules state it must be a short range service.

Edited September 10, 2022 by JeepCrawler98

[WROZ250]

It's difficult to know with all the legal double-talk in the rules, leaving it open to multiple interpretations. 

The internet, in its current from, did not exist when the original rules were created, and so I've always (cautiously) interpreted this as a prohibition against the, as it is referred to, "Public Switched Telephone Network".  The internet is a slightly different animal, where the PSTN was/is, literally speaking, a switched analog network (albeit does in traverse trunked lines), the internet is a packet switched network.  A technical but perhaps also a significant difference.

Yes, this technicality could be seen as splitting hairs in pointing out that technical difference and, there is no denying the internet today, is a 'public network'.

There are timed when I look at the rules as written and wonder if the feds are giving us enough rope to hang ourselves! LOL!

Lastly, it is difficult to assume that lack of enforcement by the FCC is a sign that linking is now legal, because the reality is the FCC rarely enforces any of the rules these days.  Perhaps their attitude about linking is not unlike their apparent attitude about other rule violations (if modern repeater linking is truly a violation as some argue) in that as long as it isn't causing problems for other licensed services, it's not a problem worth their investigating.

Just an observation/opinion.

[BoxCar]

The PSTN, or telephone network, has evolved over the past 30 years to where it is also a packet switched network as it changes its transport medium from copper to fiber. The changes began before the breakup of the Bell network with the Long Lines or long distance service replacing microwave links with fiber. This has been going on since the late 70's. I doubt if there are any microwave links carrying interstate traffic anymore. There may be a few links remaining for local and intrastate but even local service is being converted to fiber with the copper retirement programs going on in many of the companies.

[Lscott]

2 hours ago, JeepCrawler98 said:

Define wireline using the CFR Title 47 definitions please. Same for where the rules state it must be a short range service.

I tried looking that up to see if there is any definitive definition by the FCC. Nothing immediately popped up that wasn't confusing. I guess that's why we have lawyers and courts to argue the issue. Maybe some court will reach an opinion, then later elsewhere another court will reach a different opinion. Oh well, use your own best judgement.

[JeepCrawler98]

2 hours ago, Lscott said:

I tried looking that up to see if there is any definitive definition by the FCC. Nothing immediately popped up that wasn't confusing. I guess that's why we have lawyers and courts to argue the issue. Maybe some court will reach an opinion, then later elsewhere another court will reach a different opinion. Oh well, use your own best judgement.

Agreed, and this also what I ran into years ago when trying to figure out what the heck this limitation meant, ultimately I took the "if it's not illegal it's legal" school of thought.

The point of the wire-line definition exercise is just to allude that it's an inconclusive argument at best - you can't exactly cite the rules verbatim but then use anecdotal definitions where the rule is not clear. Lots of folks consider wire-line as just remote control over a dedicated twisted pair (such as dispatch consoles), some consider it phone, some consider it everything that comes out of a cable, the FCC has a wireline bureau which explicitly is for communications that are non-wireless, and then there's the whole debate on how this ties in if you use private non-IX reliant IP networking (such as p2p microwave. which is wireless), but there is no clear definition of the term that I could find within the scope of part 90/95.

The rabbit hole deepens when you consider you can't carry messages over wire-line, but then you are allowed to to use PSTN and "other networks" for remote control under 95.1749, when the definition of remote control is explicitly just remotely using the station not within physical proximity to the transmitter, and makes no limitation to not include audio, nor does it imply it's only keying/unkeying/disabling control as yet some other folks will say:

Quote

95.303 - Remote Control: Operation of a Personal Radio Services station from a location that is not in the immediate vicinity of the transmitter. Operation of a Personal Radio Services station from any location on the premises, vehicle or craft where the transmitter is located is not considered to be remote control.

It again just comes back to not using the service to make phone calls to a phone number, which is where this debate always ends up.

Edited September 10, 2022 by JeepCrawler98

[Lscott]

Not very reassuring without firm legal ground to support the practice. At least people should be aware that it could be ruled as prohibited at some point so one shouldn’t get their panties in a twist “if” it ever happens.

[KAF6045]

22 hours ago, JeepCrawler98 said:

Define wireline using the CFR Title 47 definitions please. Same for where the rules state it must be a short range service.

For "short range" you have to go back to the oldest version available in eCFR... January 2017 (some months before the big reorganization. Working forward, this was still the regulation in September 2017). The "short-range" clause fell out in the October 2017 reorganization. My suspicion is that the "short-range" clause got lost during editing by an assumption that it didn't need to be stated; after all, at the UHF frequencies involved, communication is line-of-sight (to a repeater on a tower, or to effective horizon barring vegetation and buildings) and maybe a belief that linking of repeaters was inhibited by the wireline restrictions. Also, clauses about (immediate) family members remains and that sort of assumes said family members are within range that the license holder can ensure proper radio usage -- not halfway across the country on a linked system.

From early 2017:

Quote

§ 95.1 The General Mobile Radio Service (GMRS).

(a) The GMRS is a land mobile radio service available to persons for short-distance two-way communications to facilitate the activities of licensees and their immediate family members. Each licensee manages a system consisting of one or more stations.

 

In passing, I would also note that, per the definitions in the current regulations

Quote

§ 95.303 Definitions.

The following terms and definitions apply only to the rules in this part.
<SNIP>

Control station. A station at a fixed location that communicates with mobile stations and other control stations through repeater stations, and may also be used to control the operation of repeater stations.

a mobile station does not constitute a "control station" with regards to the operation of a repeater...

The only changes in GMRS regulations since October 2017 were two typos, and a rephrasing of the digital data transmission segment.

 

[gortex2]

So I'm all for reading the rules but GMRS is a mess now. Even if it is totally illegal and the FCC puts out a report and order or rulemaking paper saying it can't happen that will change nothing as there is no enforcement. Its no different than DMR, P25 and other modes being used on GMRS daily. All we can do is help make GMRS useable. To be honest I'm hoping this is a fad and all these CCR Linking folks will loose interest and go away....Sadly I dont think that will happen. 

[WRKC935]

1 hour ago, gortex2 said:

So I'm all for reading the rules but GMRS is a mess now. Even if it is totally illegal and the FCC puts out a report and order or rulemaking paper saying it can't happen that will change nothing as there is no enforcement. Its no different than DMR, P25 and other modes being used on GMRS daily. All we can do is help make GMRS useable. To be honest I'm hoping this is a fad and all these CCR Linking folks will loose interest and go away....Sadly I dont think that will happen. 

I really don't see the linking efforts going away.  What I DO think, and I have done, is provide a secondary repeater in my area with the same coverage footprint so that two or more users in my coverage area have a manner to communicate that they are not tying up 30 other repeaters in 3 states while they talk about nothing specific.  To me doing that is a waste of resources.  And I have the ability to run multiple repeaters for the same antenna system. 

Now the operating of digital modes, God I would love that.  And encryption too. For specific applications, and situations.  But not as a constant thing, unless it was a closed repeater.  But I don't understand the idea of a club, or public repeater being legal and linking NOT being legal.  If it's specifically meant to be family comms only, then limit the antenna height to 50 feet and the power to 5 watts and not 50.  Because my power level out of the building is 18 watts and I can talk on the thing 30 miles away from it.  And even at 5 watts with 180 foot of antenna height, I am not gonna have that much less coverage footprint. 

I guess the real question is this.  Does the FCC even care what we do as operators and repeater owners if we are not interfering with other services outside GMRS?  CB radio is limited to 4 watts AM and 12 watts SSB.  But there are videos on YouTube of guys running so much power that they have corona discharges and maintain huge electrical arcs on their antenna systems and yet there are NO report and orders issued about anyone operating with increased power levels on 11 meters.  And when was the last time you saw ANY enforcement issues with GMRS.  I looked and I couldn't find a single one in the last 15 years. 

And has anyone actually contacted the FCC and gotten an opinion from them about using the Internet as a link path to do interconnect with?   Now I will say that there are no devices that are specifically marketed to the GMRS community that are used for linking.  I am not seeing radios with Ethernet ports show up that could be used as nodes to connect to an IP network for remote operation.  So there is that.  But is there a market for them and do the manufactures see it as being a viable market? 

I am not a lawyer, or an FCC field agent.  Government regulations are typically written in double speak and are notoriously difficult for laymen to understand.  So I will NOT question what John said or his stance on the legality of it.  Many of us in the radio hobby have stretched the rules at one time or another.  Done dumb stuff on purpose or by accident like putting GMRS frequencies in a 100 watt mobile and forgetting to turn the power down to 50 watts.  But I don't personally believe that the linking thing is going to be a primary enforcement issue from the FCC either.  Just like the discussions of type accepted radios.  If they come at you for something else, and your radio ain't legit, they will throw that on top of what they came down on you for, but it's not a primary offense that they will come inspect you station for. 

And I have worked with the FCC directly in the past.  Looking for malicious interference on an homeland security licensed frequency and about interference to a navigation radar system used by an International airport.  They were equally serious about the enforcement of the problems but were very easy to work with.  And at the time they wondered if I was the one causing the interference with the radar system due to dishes we had on the tower.  

[KAF6045]

4 hours ago, WRKC935 said:

Now the operating of digital modes, God I would love that.  And encryption too. For specific applications, and situations.  But not as a constant thing, unless it was a closed repeater.  But I don't understand the idea of a club, or public repeater being legal and linking NOT being legal.  If it's specifically meant to be family comms only, then limit the antenna height to 50 feet and the power to 5 watts and not 50.  Because my power level out of the building is 18 watts and I can talk on the thing 30 miles away from it.  And even at 5 watts with 180 foot of antenna height, I am not gonna have that much less coverage footprint. 

I suspect you will never see encryption allowed -- so far the only services that seem to permit encryption are the portions that fall into Land-Mobile Public Safety licenses. Their licenses are for specific frequencies, not the shared-use frequencies of CB/GMRS/MURS/FRS (and Amateur) [cf: 95.381]

As for antenna height etc. There is the problem of the grandfathered /business/ licenses. Prior to the October 2017 reorganization, base stations were restricted to 20 feet above the building or structure on which the antenna was mounted. Difficult to restrict an antenna to 50 feet if it is mounted on top of a 10 story hotel or government building.

The difference between 5W and 50W (if memory serves) is only 2 S-units on a calibrated S-meter, and translates to only ~twice the potential distance (taking into account line-of-sight obstructions). Most of the (business sponsored) repeaters in my 1997 GMRS Repeater Directory are using antennas with enough gain to have a 250W ERP.

4 hours ago, WRKC935 said:

I guess the real question is this.  Does the FCC even care what we do as operators and repeater owners if we are not interfering with other services outside GMRS?  CB radio is limited to 4 watts AM and 12 watts SSB.  But there are videos on YouTube of guys running so much power that they have corona discharges and maintain huge electrical arcs on their antenna systems and yet there are NO report and orders issued about anyone operating with increased power levels on 11 meters.  And when was the last time you saw ANY enforcement issues with GMRS.  I looked and I couldn't find a single one in the last 15 years. 

4W /carrier/ on AM, 12W PEP on SSB -- different measurement schemes... Probably similar actual power if one considers a 4W carrier with two sidebands each carrying 4W of signal; SSB just gets to shove all that power into one sideband

4 hours ago, WRKC935 said:

And has anyone actually contacted the FCC and gotten an opinion from them about using the Internet as a link path to do interconnect with?   Now I will say that there are no devices that are specifically marketed to the GMRS community that are used for linking.  I am not seeing radios with Ethernet ports show up that could be used as nodes to connect to an IP network for remote operation.  So there is that.  But is there a market for them and do the manufactures see it as being a viable market? 

There was a thread somewhere on this forum that did reference a response from the FCC with regards to connections... As best as I could interpret that response, an internet connection using a TV Cable system cable [copper or fiber] was deemed acceptable, but a DSL-type modem on a phone line [again, copper or fiber] was not acceptable, for purpose of linking repeaters. The mere physical connection to the PSTN system seemed to be the hanging point, less than if it had the ability to "patch" into the telephone voice system.

 

[WRKC935]

Yeah, I don't expect that we will ever see encryption on GMRS.  It's been deemed legal in certain situations on Ham, but the key has to be posted sort of removing the security of operating secure.  I don't know that we will see digital modulation in GMRS in the future either.  It's getting along fine without it and the number of license holders continues to grow.  If enough people were to write letters requesting it be reviewed, it might get looked at but I doubt it's gonna happen.

To the comment about linking.  The regulation says the PSTN (public switched telephone network).  Now that gets defined by the FCC during an enforcement action.  Is the Internet (due to VoIP) now considered part of the PSTN?  That would be for them to consider, and argue to a judge during legal proceedings.  But there first has to be an enforcement effort to even begin to have the discussion.  Leading back to the question of when was GMRS looked at for enforcement of any kind. 

Now the difference between 5 watts and 50 watts is 10dB.  One S-unit is 6 dB of change from one level to the next, so it's actually less than 2 S-units. 

 

The height restriction.  This is similar to the control station height limit spelled out in part 90.  That states that a control station antenna, meaning an antenna for a radio that is communicating to a repeater and NOT another station, can be no higher than 20 feet above the highest point of the nearest structure.  Now, a base station is defined as any fixed station that is NOT a repeater in part 90.  Meaning a base station is setup to communicate SIMPLEX with mobile and portable radios directly without a repeater being involved in the communication.  So again, what are they defining as a base station with GMRS, is it ANY fixed station that is not a repeater, or is it only a fixed station that communicates through a repeater?  That is another double speak regulation that deserves a layman's explanation of the written regulation. 

Now here's a thought.  I wonder if you could get an FCC attorney to write a layman's explanation of the GMRS regulations so that it was a bit more cut and dried and not so confusing. 

Lastly, ERP.  there's where the rubber hits the road.  If you were to stick a GMRS repeater on a tower.  Have 10 feet of feed line between the duplexer and the antenna with 40 watt's of output due to losses in the duplexer with a 50 watt radio.  Connect that to a DB-420 antenna with 8dBi of gain. Your ERP is 250 watts.  Park that 200 feet in the air and you are legal in all aspects and talking for miles.  But damn few are gonna do that.  Maintenance on the repeater required a tower climb.  Rigging and lifting the repeater and duplexer up there is gonna be difficult at best and the tower is gonna need to be sturdy enough to support the weight and wind load of the cabinet that it's in.  If you put 300 feet of 7/8 line in there and locate the repeater in the building, you loose 2.4 dB of signal.  Dropping you down to 144 watts of ERP.  Which sounds like a bunch, but since I have an antenna at 180 feet and am only getting 20 watts out of the duplexer (actually a combiner which has higher loss) and it talks 30 miles, I don't believe it's that big of a deal. Now on some tower this is absolutely possible.  But it's a pain to work on the thing.  We discussed it and decided against it and have both the room and the tower to be able to do it.  And that picture is ONE corner of the top deck taken from the center of the deck.  And those posts are 6 feet apart.

 

[KAF6045]

15 hours ago, WRKC935 said:

Yeah, I don't expect that we will ever see encryption on GMRS.  It's been deemed legal in certain situations on Ham, but the key has to be posted sort of removing the security of operating secure.  I don't know that we will see digital modulation in GMRS in the future either.  It's getting along fine without it and the number of license holders continues to grow.  If enough people were to write letters requesting it be reviewed, it might get looked at but I doubt it's gonna happen.

Hmmm... I don't recall encryption, per se, being allowed in Amateur. Experimental Frequency Hopping Spread Spectrum I do recall -- and the hop sequence had to be public.

15 hours ago, WRKC935 said:

The height restriction.  This is similar to the control station height limit spelled out in part 90.  That states that a control station antenna, meaning an antenna for a radio that is communicating to a repeater and NOT another station, can be no higher than 20 feet above the highest point of the nearest structure.  Now, a base station is defined as any fixed station that is NOT a repeater in part 90.  Meaning a base station is setup to communicate SIMPLEX with mobile and portable radios directly without a repeater being involved in the communication.  So again, what are they defining as a base station with GMRS, is it ANY fixed station that is not a repeater, or is it only a fixed station that communicates through a repeater?  That is another double speak regulation that deserves a layman's explanation of the written regulation. 

Now here's a thought.  I wonder if you could get an FCC attorney to write a layman's explanation of the GMRS regulations so that it was a bit more cut and dried and not so confusing. 

See

Quote

§ 95.1763 GMRS channels.

The GMRS is allotted 30 channels - 16 main channels and 14 interstitial channels. GMRS stations may transmit on any of the channels as indicated below.

(a) 462 MHz main channels. Only mobile, hand-held portable, repeater, base and fixed stations may transmit on these 8 channels. The channel center frequencies are: 462.5500, 462.5750, 462.6000, 462.6250, 462.6500, 462.6750, 462.7000, and 462.7250 MHz.

(b) 462 MHz interstitial channels. Only mobile, hand-held portable and base stations may transmit on these 7 channels. The channel center frequencies are: 462.5625, 462.5875, 462.6125, 462.6375, 462.6625, 462.6875, and 462.7125 MHz.

(c) 467 MHz main channels. Only mobile, hand-held portable, control and fixed stations may transmit on these 8 channels. Mobile, hand-held portable and control stations may transmit on these channels only when communicating through a repeater station or making brief test transmissions in accordance with § 95.319(c). The channel center frequencies are: 467.5500, 467.5750, 467.6000, 467.6250, 467.6500, 467.6750, 467.7000, and 467.7250 MHz.

(d) 467 MHz interstitial channels. Only hand-held portable units may transmit on these 7 channels. The channel center frequencies are: 467.5625, 467.5875, 467.6125, 467.6375, 467.6625, 467.6875, and 467.7125 MHz.

Note that "base station" is NOT in the list allowed to transmit on the 467MHz main (repeater input) channels. This section considers a "base" station as something other than a "fixed" station. Fixed stations are limited to 15W output.

(This also reinforces my view that just /using/ a repeater via PTT does NOT make that user/radio a "control station" -- to my interpretation a control station must have the ability to shutdown a malfunctioning or misused repeater, not just make it retransmit signals as part of normal operations. Otherwise EVERY user of a repeater is a control operator of that repeater -- rather than the licensee and those authorized by the licensee.)

 

15 hours ago, WRKC935 said:

Lastly, ERP.  there's where the rubber hits the road.  If you were to stick a GMRS repeater on a tower.  Have 10 feet of feed line between the duplexer and the antenna with 40 watt's of output due to losses in the duplexer with a 50 watt radio.  Connect that to a DB-420 antenna with 8dBi of gain. Your ERP is 250 watts.  Park that 200 feet in the air and you are legal in all aspects and talking for miles.  But damn few are gonna do that.  Maintenance on the repeater required a tower climb.

You practically described the one repeater I know is in my area -- and is a grandfathered license belonging to the government of Grand Rapids, with CTCSS tone posted (in the 1997 GMRS National Repeater Guide) for Emergency/Traveller Assistance only.

290 feet above average terrain (769 above sea level), 200W ERP with 50W transmitter. (WXMI-17 used to have on on their tower at over 500ft, but only 60W ERP, claimed 40 mile range, I'm only 25 miles from it... EMERGENCY ONLY in the guide book, not even traveller assistance)

[SteveShannon]

 

 

17 hours ago, KAF6045 said:

Hmmm... I don't recall encryption, per se, being allowed in Amateur. Experimental Frequency Hopping Spread Spectrum I do recall -- and the hop sequence had to be public.

On 9/11/2022 at 8:57 PM, WRKC935 said:

Encryption is allowed for remote control of satellites in the amateur bands. That’s the only exception that I know of. 

[gortex2]

Yet its used all the time as it is in GMRS. This is what keep bringing up. The only thing GMRS users can control is those who want to follow the rules. Half of this forum talks about using non part 95 radios (CCR HAM stuff) and how to modify this or that or how to get out of the rules. If we concentrated on promoting the proper use of GMRS radios the hobby could be better. We can't control stuff people are doing who are not on this forum. 

 

Oh and was at a ham fest Sunday in NJ. 146.580 was used and encrypted as it was blinking on my APX. No clue who but it happens all the time. 

[Lscott]

That's true. I occasionally catch some DMR traffic on one of the GMRS simplex channels where I work. I verified that by using the digital monitor function on my D878UV  I took into work one day just to see if I could identify the source. Nothing was said that I could use to figure out who was responsible. It doesn't happen often enough to bother checking frequently.

About the rules you have a point. There are several people on this forum who have the attitude if the FCC hasn't busted anybody for an obvious rule violation then they mustn't care so it's OK to continue doing so. The worst part is when they encourage other users to do the same.

[WRKC935]

On 9/12/2022 at 2:06 PM, KAF6045 said:

290 feet above average terrain (769 above sea level), 200W ERP with 50W transmitter. (WXMI-17 used to have on on their tower at over 500ft, but only 60W ERP, claimed 40 mile range, I'm only 25 miles from it... EMERGENCY ONLY in the guide book, not even traveller assistance)

Well, I am a BIT higher.

antenna height is 550 HAAT and 1560 above mean sea level.

 

[WRKC935]

On 9/12/2022 at 2:52 PM, Sshannon said:

 

 

Encryption is allowed for remote control of satellites in the amateur bands. That’s the only exception that I know of. 

WiFi when you are using your call sign as your SSID and transmitting or exceeding the ERP allowed in part 15.  You also have to be using the correct channels.

This is a sticking point with MANY hams but the question has been asked directly to the FCC a number of times and they have said it was acceptable to encrypt data links that were ONLY supporting ham radio activities. 

[Lscott]

Some other view points on the matter. There are some specific caveats pertaining to data encryption. It's not a blanket permission either.

https://www.rrmediagroup.com/News/NewsDetails/NewsID/17804

https://www.qsl.net/k/kb9mwr/projects/wireless/Data Encryption is Legal.pdf

[WQAI363]

I maybe rambling on and not staying on the Topic, but seems as a little simularity here. Connection VoiP on GMRS, sort a like back in the day, when CBers would add extra channels on their radios. Known as Free Banding, which remains illegal. Howerer, we're not talking about adding extra channels. What we're talking about using VoiP on FRS or GMRS, which was bond to happen at some point. I really don't see the harm with connecting FRS or GMRS to the internet via VoiP and extend coverage a little.  Beside until GMRS regained  it's popularity with recent Part 95 A & 95 E radios out there on the market, GMRS Iicensees were breaking rules & regulations anyway. Only there wasn't really a stink from the FCC, at least not from my prospective.  I'm refering to the use of Part 90 radios rather than Part 95. Feel Free to shut me up and put me out of my misury, because it probably sounds as if I'm not too intelligant. 

I apologize & 73s 

[WRUM335]

This is a very thought provoking discussion and raises lots of good points.  Before I say much, I feel it necessary to clarify something first.  I'm not here to debate the legality of the issue, that is for the courts to decide if and when it comes before them.  That said, I do have a point to consider, from my comfort zone of being a subject matter expert in a specific area being discussed:  The Internet.

As others have correctly pointed out, the FCC regulations predate (to a large extent), the internetworking of computers and the explosion of data being transmitted "over the wire" of this new technology.  As many have also pointed out, this newer technology doesn't always transit a pair (or more) of wires any longer.  This blending of the wired vs. the wireless world intrudes upon the realm of the FCC, but it is, at the same time, separate.

The FCC has the authority to regulate "how" devices are employed to transmit and receive communications, both through a wired medium as well as over the air (RF), however, it's authority has limits.  The first limit is the entity that grants it the authority, the United States.  Because RF transmissions can exceed the boundary of this geographical location, this limit can only be enforced upon the individuals that claim citizenship and corporations wishing to offer products to it's citizens.  Through agreements with other nations, this can be extended, but only with the cooperation of the other nations governmental agency with a similar jurisdictional area.  Some nations lack such an agency and international regulation is spotty at best, particularly when it comes to the technology that makes up the Internet.  The second limit is that of specific boundaries for both the frequencies used and the technologies employed.  Their authority is strictly limited to what the U.S. government has authorized them to regulate.  To date, they have very limited authority when it comes to wireless technologies in use in the digital data world.  Specifically, their authority is limited to only defining emissions limits and what frequencies can be utilized.  They cannot regulate who uses the equipment nor what (from a content perspective) is transmitted and received.

What this boils down to is the somewhat correct statement that the Internet is unregulated.  For purposes of this particular topic, this statement introduces an interesting component.  What happens when a particular transmission transitions from a regulated and known state to an unregulated and different state?  A complimentary question also exists in the reverse scenario, when a transmission transitions back from an unregulated and different state to the regulated and known state.

I'm not going to go down the rabbit hold of citing specific regulations, nor offer interpretation or definition of terms, but I will say this:  context matters, so does intent.  The original intent of the prohibition was to limit the burden on public switched networks (at the time, this was primarily the telephone network).  The Internet was never intended to be regulated, is not considered even today to be a public service, and it is very difficult to see how the slow and small size of a radio transmission packet would be a burden on it.

VoIP is a technology that takes an analog audio wave, digitizes it, and encases it into IP packets, regardless of how the analog audio wave originates.  As soon as it becomes encased, it ceases to have any meaning under part 95 until it reverts back to an analog audio wave and again is transmitted by a station under the part 95 regulation.  It follows that while it is in the form of an IP packet, part 95 has no authority.

Let us supposed, for a minute, that a licensed station's speaker is setup in such a way that a listening device, separate from the roster of equipment is within range to pick up that audio wave.  That listening device is configured in such a way as to transmit anything it hears to a specific destination using VoIP.  The destination is then configured to play, in real time, anything it receives through a connected speaker.  Within range of that speaker, a GMRS repeater station, under automatic control, is configured to start and stop transmission when an audible audio wave is detected.  What is different about this scenario vs. directly connecting a GRMS transmitter to a solid circuit designed to do the same thing?  I'm not trying to stir up a hornets nest here, this is an honest question.

[jwilkers]

Define wireline using the CFR Title 47 definitions please. Same for where the rules state it must be a short range service.

I guess wireline is any non RF mode of transport of intelligence. Again...a guess.

There is no "must be". I believe it is more of a "designed as" or "originally intended for". Similar to where GMRS wasn't designed as a hobby service; but you know how that ended up.

Sent from my SM-A136U using Tapatalk

[BoxCar]

Wireline refers to two locations connected by a physical, terrestrial connection. Telephone networks communicate between points using a physical hard-wired connection hence the term wireline. The term can also trace its beginnings back to the early days of telegraphy where physical wires connected each station to the other. The term predates radio and its modern equivalent wireless.