Fixed station - what does that mean to FCC?

[gortex2]

3 pages of arguing over a control station, fixed station....yet we help guys use non certified radios for use......im baffled...

 

[WRUU653]

1 hour ago, Sshannon said:

I apologize if I am making this more complex than it should be.  I have no idea why FCC has defined these different types of stations.

I see I got some of that wrong, not enough coffee this morning. I was trying to sort it out before asking if I got it right so not to waste anyones time.  No apologies nessasary. I thank you for taking the time and effort to set me straight.  I don't think you made this more complex than it needs to be, we can give that credit to the FCC. 

[SteveShannon]

7 hours ago, KAF6045 said:

I would deem it a MOBILE station being used from a stationary location

All through the regulations, control station is called out separately from mobile, base, on hand-held. Personally, I do not interpret using PTT to access a repeater to be a control function -- to me control station must have the ability to SHUTDOWN a malfunctioning (or one under malicious interference by someone trying to spam the world with religious/political statements, and not allowing other access) station/repeater (otherwise /every user of a repeater is considered a control operator).

What would you deem a control station? What differentiates it from a mobile station in a stationary location? Is it the hardware design or the usage?  What hardware features must a station possess for you to deem it a Control Station?  The ability to send DTMF?

If it’s mounted on a desk in building, with a 120Vac power supply and a roof mounted folded dipole antenna, is that still just a mobile in a stationary location?

In the definitions, only the usage varies.  The definitions don’t require different features or capabilities; they just describe different uses of the same physical radio features.

As far as the manufacturer marketing is concerned, there are only two configurations of radios being sold: hand-held portables and mobiles. Every radio has the ability to send DTMF tones, so every radio has the potential to be a Control Station.  Every radio has the ability to be used from a fixed location. Every radio has the ability to be used from a vehicle, while moving or from a stationary location. The only type of radio that is easily distinguishable is the hand-held portable.

FCC type certification is the only limitation to the capabilities of a radio.  Once a radio has been certified to 95E, the only difference is usage and user intent and it’s highly doubtful that a well behaved licensee will ever hear from the FCC and even less likely that they would be singled out for a violation. 

Edited November 17, 2022 by Sshannon
Couldn’t sleep ?

[Lscott]

11 hours ago, Sshannon said:

... it’s highly doubtful that a well behaved licensee will ever hear from the FCC and even less likely that they would be singled out for a violation. 

The FCC doesn't have the man power, but they did spend $80Billion on 87,000 more IRS agents. Things could change.

[SteveShannon]

50 minutes ago, Lscott said:

The FCC doesn't have the man power, but they did spend $80Billion on 87,000 more IRS agents. Things could change.

To target well behaved licensees?  You seem almost giddy at the prospect, but the fact is the FCC has never been eager to prosecute innocent mistakes.

[UncleYoda]

16 hours ago, Sshannon said:

I have no idea why FCC has defined these different types of stations.

But if they gave a good enough definition and description then you would know why and what their function is.

[UncleYoda]

15 hours ago, KAF6045 said:

someone trying to spam the world with religious/political statements

Religious and political statements are not, and cannot be, legally prohibited.  It's just HAM tradition to not talk about anything meaningful other than your equipment.

[UncleYoda]

14 hours ago, Sshannon said:

What would you deem a control station? What differentiates it from a mobile station in a stationary location? Is it the hardware design or the usage?  What hardware features must a station possess for you to deem it a Control Station?  The ability to send DTMF?

If it’s mounted on a desk in building, with a 120Vac power supply and a roof mounted folded dipole antenna, is that still just a mobile in a stationary location?

In the definitions, only the usage varies.  The definitions don’t require different features or capabilities; they just describe different uses of the same physical radio features.

As far as the manufacturer marketing is concerned, there are only two configurations of radios being sold: hand-held portables and mobiles. Every radio has the ability to send DTMF tones, so every radio has the potential to be a Control Station.  Every radio has the ability to be used from a fixed location. Every radio has the ability to be used from a vehicle, while moving or from a stationary location. The only type of radio that is easily distinguishable is the hand-held portable.

FCC type certification is the only limitation to the capabilities of a radio.  Once a radio has been certified to 95E, the only difference is usage and user intent and it’s highly doubtful that a well behaved licensee will ever hear from the FCC and even less likely that they would be singled out for a violation. 

Sorry, I haven't yet figured out how to break a quote into multiple parts here.

A control station is a remotely located station that exercises (or has the ability to) control over another station. [my wording not quoting regs]  DTMF is the main way I know of but I believe there are others including through an interface with a computer.

Mounted on a desk with rooftop antenna is a base station to most folks.

Simply being able to send DTMF does not make you a control station the same way being able to post here doesn't make you a moderator.  In my state, we have a statewide linking network of 2m and 440 HAM repeaters and when the statewide link is not already activated ordinary users can send DTMF codes to link two repeaters and to unlink.  We are not control stations in doing so, which becomes obvious when there is a problem like noise interference on the linked system.  I know that's a HAM example but I'm sure the technology is similar on GMRS.

Regarding your last paragraph about the FCC, yes they may not come after us but for some of us the point is we're trying to follow the rules.  We just want them to make their meaning clear.

 

[WRUU653]

45 minutes ago, UncleYoda said:

Religious and political statements are not, and cannot be, legally prohibited.  It's just HAM tradition to not talk about anything meaningful other than your equipment.

what he said was 

 

16 hours ago, KAF6045 said:

malicious interference by someone trying to spam the world with religious/political statements, and not allowing other access) station/repeater

And yes if it’s your repeater you can legally prohibit anyone for any reason you want. 

[SteveShannon]

1 hour ago, UncleYoda said:

But if they gave a good enough definition and description then you would know why and what their function is.

I understand that you want more, but the regs are good enough for me.  The fact that FCC hasn’t locked it down more leaves us with greater latitude. Yes, they seem confusing, but I have no problem complying with the as written regulations.

[Lscott]

3 hours ago, Sshannon said:

To target well behaved licensees?  You seem almost giddy at the prospect, but the fact is the FCC has never been eager to prosecute innocent mistakes.

Never thought they would beef up the IRS with so many people, but surprise, they did. Am I "giddy" at the prospect of a clamp down by the FCC? No. Remember when Hams were begging the FCC to start enforcing Part 97 reg's?  Nobody thought "anything" would happen, it did, not much, but there was some action taken. The way things are now I wouldn't dismiss anything, however, we're living in the Twilight Zone at the moment.

[SteveShannon]

Quote

 

 Sorry, I haven't yet figured out how to break a quote into multiple parts here.

 

There are at least two ways. You can select just the part you want to quote and then click “quote selection” or you can copy and paste the message and then select the part you want placed in a quote box and click on the quotation mark format symbol.

Quote

 

A control station is a remotely located station that exercises (or has the ability to) control over another station. [my wording not quoting regs]  DTMF is the main way I know of but I believe there are others including through an interface with a computer.

 

I think most people would agree with you, but again, the regulations can only be enforced based on what is written and the definition of a Control Station doesn’t go that far. To make this easier I’ll insert the definition of a Control Station here:

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. 

Clearly the word “may” in that definition means that the control station has the technical capability to control a repeater. Simply being able to talk through a repeater doesn’t imply control.  To your point, within Subpart E, the FCC makes a point of distinguishing between “Using” and “Operating” a station. I think we can agree that talking through a repeater is simply using it, but if you have the ability to change the way it operates you are an Operator. Operating a station is controlling it.

Quote

Mounted on a desk with rooftop antenna is a base station to most folks.

Again, I agree; most folks would call a radio in a house with a rooftop antenna a base station. But the regulations simply say:

Base station. A station at a fixed location that communicates directly with mobile stations and other base stations. 

Base stations do not communicate through repeaters.

Quote

Simply being able to send DTMF does not make you a control station the same way being able to post here doesn't make you a moderator.  

If those DTMF tones shut down the repeater or change the operation of it, that’s certainly control, far more than simply using a repeater, but even so, that ability isn’t necessarily required by the regs.

Quote

 

In my state, we have a statewide linking network of 2m and 440 HAM repeaters and when the statewide link is not already activated ordinary users can send DTMF codes to link two repeaters and to unlink.  

 

If you’re linking and unlinking repeaters, of course you are controlling them.

Quote

 

We are not control stations in doing so, which becomes obvious when there is a problem like noise interference on the linked system.  I know that's a HAM example but I'm sure the technology is similar on GMRS.

 

The technology is identical.  The regs aren’t.

Quote

Regarding your last paragraph about the FCC, yes they may not come after us but for some of us the point is we're trying to follow the rules.  We just want them to make their meaning clear.

I agree, and I want to be compliant, but I don’t want to invite additional regulations. It’s a case of being careful what we ask for.

[UncleYoda]

1 hour ago, Sshannon said:

There are at least two ways. You can select just the part you want to quote and then click “quote selection” or you can copy and paste the message and then select the part you want placed in a quote box and click on the quotation mark format symbol.

I think I got it.

 

Quote

 

I think most people would agree with you, but again, the regulations can only be enforced based on what is written and the definition of a Control Station doesn’t go that far. To make this easier I’ll insert the definition of a Control Station here:

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. 

 

Well, I hate to complicate things more since this topic is about fixed station.  But, there is a glaring problem with that definition.  Control station, as I'm familiar with it, does not have to be "at a fixed location".  Mobiles and HTs can be control stations if they can exercise control.  And for that matter, control stations can communicate with base stations and portable, not just mobile (they don't control them necessarily but do communicate).  So this is another crappy definition.

Quote

Operating a station is controlling it.

I don't know how fine-grained they define it.  But the linking I mentioned was part of normal use.  There was something for HAM that was referenced in the test questions about what constituted a control station but I can't recall it exactly.

Quote

Base station. A station at a fixed location that communicates directly with mobile stations and other base stations. 

What about portables?  You really think they don't allow bases to talk with portables?  Seems ridiculous.

Quote

Base stations do not communicate through repeaters.

That's a conclusion in your words, not their wording, right?

Quote

If you’re linking and unlinking repeaters, of course you are controlling them.

My understanding (from the HAM side of things) from memory is that a control station has the ability to turn off or disable the repeater if it's causing a problem.  Normal users doing linking do not have that ability, just unlinking.  I don't know of a test case about this though.

Quote

The technology is identical.  The regs aren’t.

I know but the GMRS regs leave out a lot that's needed for clarity.  So, what do we do, call FCC?  It definitely should not be this complicated for a simple pay your fee license.

[KAF6045]

22 minutes ago, UncleYoda said:

That's a conclusion in your words, not their wording, right?

Don't think one can state that as a conclusion when it directly based upon the permitted frequencies for "base" stations. (emphasis mine)

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" stations are only mentioned in the 462MHz segment -- they are explicitly NOT named in the 467MHz repeater input section.

[SteveShannon]

9 hours ago, UncleYoda said:

I think I got it.

Yes, you got it.  It really does help with clarity.  I still haven't figured out how to get out of the quotes though, when I accidentaly post a reply with my comments inside them.

Quote

Well, I hate to complicate things more since this topic is about fixed station.  But, there is a glaring problem with that definition.  Control station, as I'm familiar with it, does not have to be "at a fixed location".  Mobiles and HTs can be control stations if they can exercise control.  And for that matter, control stations can communicate with base stations and portable, not just mobile (they don't control them necessarily but do communicate).  So this is another crappy definition.

 

Quote

I don't know how fine-grained they define it.  But the linking I mentioned was part of normal use.  There was something for HAM that was referenced in the test questions about what constituted a control station but I can't recall it exactly.

 

Quote

What about portables?  You really think they don't allow bases to talk with portables?  Seems ridiculous.

Portables are a subset of mobiles.  It's in the definition:

Hand-held portable unit - A physically small mobile station that can be operated while being held in the operator's hand.

Quote

That's a conclusion in your words, not their wording, right?

1. It's a requirement embodied by the wording of the definition.  The definition lists what types of stations base stations communicate directly with. Base station.  A station at a fixed location that communicates directly with mobile stations and other base stations. Repeaters are not listed. 
2. It's a requirement of the requirements of the channels. Base stations are not allowed to transmit on the 467 Main channels that are inputs to repeaters. 467 MHz main channels. Only mobile, hand-held portable, control and fixed stations may transmit on these 8 channels... (I snipped the rest, but it doesn't change this answer.)

 

Quote

My understanding (from the HAM side of things) from memory is that a control station has the ability to turn off or disable the repeater if it's causing a problem.  Normal users doing linking do not have that ability, just unlinking.  I don't know of a test case about this though.

That just doesn't exist within the GMRS regulations. 

Quote

I know but the GMRS regs leave out a lot that's needed for clarity.  So, what do we do, call FCC?  It definitely should not be this complicated for a simple pay your fee license.

That's up to you.  I would hope they have someone on staff who answers these kinds of questions and I would really be interested in whatever response you get, but I doubt you will walk away less frustrated. I think your frustration stems from a desire to have a nice tidy set of rules that make sense to you, but we all think differently. What makes perfect sense to me might not make sense to you and vice versa.  I just want to know if a "station" can fluidly change from one station type to another based on usage. 

I like rules. I like understanding rules.  Ever since I started doing compliance work I sort of wished I had gotten a law degree in addition to my engineering degrees. Obviously you appreciate clear rules also. GMRS has relatively few rules though and those it has are sometimes difficult to fathom. There's no test of knowledge or qualifications and very little control over who can operate under one person's license. There's no limit on who in my immediate family can operate (not just use) a station under my license. My three year old grandkid can be a station operator (not just user). Of course I still bear the responsibility, but station operation by minors is permitted.  Anyone can set up a repeater - no coordination required.  Anyone can create a network using Fixed Stations.  The FCC literally knows nothing about what each station is because stations are not licensed. And they know nothing about the capabilities of each licensee. 

I found this in the regulations:

§ 95.329 How to contact the FCC.

For information about the Personal Radio Services, see the FCC's internet Web site (www.fcc.gov). To speak with an FCC representative about the Personal Radio Services, call the FCC's information line 888-CALL-FCC(888-225-5322). To write the FCC about these services, address the Federal Communications Commission, Attention: Mobility Division, Wireless Telecommunications Bureau, at the address of the FCC's main office indicated in 47 CFR 0.401(a). 

[82 FR 41104, Aug. 29, 2017, as amended at 85 FR 64411, Oct. 13, 2020]

D

[Photoman5k]

This is why you should never use the word/term that you're defining in the definition of it... You would think the FCC would stay away from doing such things to avoid confusion. But then again government agencies aren't known for doing things that make sense...

[SteveShannon]

2 minutes ago, Photoman5k said:

This is why you should never use the word/term that you're defining in the definition of it... You would think the FCC would stay away from doing such things to avoid confusion. But then again government agencies aren't known for doing things that make sense...

But the way they used the words in the definition doesn’t make it confusing. Saying that a Fixed Station may only communicate with another Fixed Station. They could have just as easily said “A Fixed Station may not communicate with mobile stations, base stations, control stations, or hand-held portables.”

[Photoman5k]

3 hours ago, Sshannon said:

But the way they used the words in the definition doesn’t make it confusing. Saying that a Fixed Station may only communicate with another Fixed Station. They could have just as easily said “A Fixed Station may not communicate with mobile stations, base stations, control stations, or hand-held portables.”

For as smart as you seem to be I cannot believe that what I said went over your head the way it did. A definition should not include in it the word/term/object being defined. 

 Thats what the FCC did. That makes the definition clear as mud.

That definition tells you what a "fixed station" can or cannot do, not what it is.

If I ask you to define what a door is you can define it without using the word door in the definition can u not? Ok then so lets define a fixed station or give an example that would be a bit easier to understand rather than just keep regurgitating the same FCC definition that doesn't actually define what it is, but only tells us what it is allowed to do or not do.

@UncleYoda I found this on an old thread on radioreferance.com forums thought i'd share it with you maybe it will help you a bit.

Quote

There used to be a GMRS-specific definition for fixed stations. It
defined a station that transmitted from one specific geographic point
as identified on the license, to another specific geographic point as
identified on the license. A fixed station could not communicate with
any other class of station. It was strictly limited to point-to-
point. They were also not permitted within a 75-mile radius of large
urban areas. The 15 watt power limit, along with a limitation that
you could only use a directional antenna, existed for fixed stations
between 75 and 100 miles of a large urban area. There is a link to
the older, pre-ULS rules on the PRSG website where you can find
further information.

 

[WRUU653]

“Fixed station.” Merriam-Webster.com Dictionary, Merriam-Webster, https://www.merriam-webster.com/dictionary/fixed station. Accessed 20 Nov. 2022. 

 

[UncleYoda]

8 hours ago, Photoman5k said:

For as smart as you seem to be I cannot believe that what I said went over your head the way it did. A definition should not include in it the word/term/object being defined. 

 Thats what the FCC did. That makes the definition clear as mud.

That definition tells you what a "fixed station" can or cannot do, not what it is.

If I ask you to define what a door is you can define it without using the word door in the definition can u not? Ok then so lets define a fixed station or give an example that would be a bit easier to understand rather than just keep regurgitating the same FCC definition that doesn't actually define what it is, but only tells us what it is allowed to do or not do.

@UncleYoda I found this on an old thread on radioreferance.com forums thought i'd share it with you maybe it will help you a bit.

 

Thanks for making the point I've been trying to get across and most of the guys here don't understand (and probably never will).  Yea, that reference to something that used to be different may explain why it is not clear.  I don't know what the PRSG website is, but looking at outdated information is not the best option for interpreting current rules.  The current rules need to stand on their own with sufficient detail and proper wording for clarity and consistent interpretation (which it's obvious we don't have here).

[UncleYoda]

12 hours ago, Sshannon said:

They could have just as easily said “A Fixed Station may not communicate with mobile stations, base stations, control stations, or hand-held portables.”

That's what they should have said (you make regulations explicit).  But even that would still not tell us what a fixed station is.  They could say a base station may only transmit between 7am and 10 am on Tuesdays but that wouldn't tell me what a base station is.  Can you not see the difference between specifying limits on usage and actually defining/describing what something is? (rhetorical, I don't need an answer)

[MichaelLAX]

On 11/11/2022 at 10:30 AM, UncleYoda said:

This affects any purchase I may decide to make for a mobile with more power and/or an antenna with higher gain so I don't want to buy more than I can use as a dual-use mobile and base station.

So, we're all waiting with bated breath: what mobile are you going to buy?!?

[SteveShannon]

1 hour ago, UncleYoda said:

That's what they should have said (you make regulations explicit).  But even that would still not tell us what a fixed station is.  They could say a base station may only transmit between 7am and 10 am on Tuesdays but that wouldn't tell me what a base station is.  Can you not see the difference between specifying limits on usage and actually defining/describing what something is? (rhetorical, I don't need an answer)

But it’s not.  In my post I made a mistake.  I forgot to include repeater stations in the list of stations that a fixed station may not communicate with.  Also, it isn’t as immediately understandable. “A fixed station may only communicate with a fixed station” is simple and clear. The alternative I offered forces the reader to compile or consult a complete list of station types and then exclude them all until only “fixed station” remains.  That’s a terrible way to write rules.

13 hours ago, Sshannon said:

But the way they used the words in the definition doesn’t make it confusing. Saying that a Fixed Station may only communicate with another Fixed Station. They could have just as easily said “A Fixed Station may not communicate with mobile stations, base stations, control stations, or hand-held portables.”

 

[KAF6045]

2 hours ago, UncleYoda said:

I don't know what the PRSG website is, but looking at outdated information is not the best option for interpreting current rules.

Personal Radio Steering Group (Inc.)

I think it was run by one man in a spare room of his house... It claimed to be an organization for GMRS users back in the day when a GMRS license specified just two (main) frequency pairs (to go with the common cheap business band "A/B" (or 1/2) channel toggle). Used to publish a GMRS repeater directory.

Frequencies were not identified by Channel numbers, as I might, say, have requested .550 and .675 as my two frequencies, and put them into a radio as .675=A/1, .550=B/2 -- "you" may have requested .575 and .675 and put them in as .575=A/1, .675=B/2... My "channel 1" thereby is your "channel 2", and would be the only frequency we had in common. It took some time to get radios that still had the "shop/dealer" programmed two main channels, but allowed access to the interstitials when they became available (Maxon GMRS 210+3 is the unit I'm most familiar with -- 7 interstitials, FCC emergency channel, and two "dealer programmed" channels for the licensed frequencies. Note that repeaters did not get separate channels in these rigs -- they were either duplex, simplex, or had a toggle button to change behavior.

[OffRoaderX]

FFS, are you still arguing over this?  4 pages of trying to prove who's smarter over something that the FCC (based on their history of action) doesn't even care about? ..."some people" .... Need to go outside more often...

Just sayin...