Transmitting on non-compliant radios

[Monsterduc]

Disclaimer: I do not condone transmitting illegally. This is a technical discussion question intended to bring better understanding to if/why radio compliance and FCC certification matters.

 

While looking for a new GMRS HT, I noticed a pattern of manufacturers creating what appears to be two models of the same radio but with different capabilities. For example, the Wouxun KG-Q10G and KG-Q10H appear to be the same exact radio, with the exception that the G model is locked down to only transmitting on the GMRS frequencies (and cut a few HAM features), whereas the H model is (presumably) not locked down in such a way. The same thing could be said about the infamous Baofeng UV-5R versus the UV-5G.

 

I recently also got a little interest in MURS and thought it would be neat to have a radio that could transmit on both GMRS and MURS frequencies. Bundle that with a few business radio frequencies that I’m licensed to use, and now I’m searching for a radio that can transmit on all of the above (although I don’t believe one exists legally as explained below). It would be nice to have one radio that could do it all instead of having to carry 3 separate radios, one for each application.

 

Now let’s talk about the FCC rules. After reviewing many convoluted forum posts about part-95 acceptance and reading the rules themselves, I came to the conclusion that such multi-band radios exist but could not transmit legally – mostly HAM radios. This is because part 95 specifies that any compliant radio can only transmit on part 95 frequencies. (Yes, I know there are legacy part 90/95 compliant radios plus multiple revisions of the part 95 rules, but let’s just ignore those for now.)

 

My real question boils down to this: blatantly ignoring the fact that there is some (il)legality involved in transmitting on a radio that is noncompliant with part 95…

• Are there any reasons someone wouldn’t just go out and buy the non-GMRS version of a radio and program it to “masquerade” as a GMRS radio?
• What’s wrong with programming a HAM radio for 462.6125 MHz, setting the bandwidth to 20kHz, limiting the power to 5W, and pulling the PTT trigger? I’m sure we all know someone who’s used a UV-5R or other non-compliant HT to talk GMRS/FRS/MURS/etc.
• Why shouldn’t (or should) someone go out and buy a Wouxun KG-Q10H or Baofeng UV-5R instead of their GMRS counterparts and use it in a non-compliant fashion as their all-in-one HT?

 

I’m looking for more of a nuts-and-bolts explanation of frequencies, bandwidths, transmit power, etc. and less of an explanation of the part 95 rules – it has already been well established that transmitting on GMRS frequencies with an unapproved radio is illegal.

 

Again: I do not condone transmitting illegally. This is a technical discussion question intended to bring better understanding to if/why radio compliance and FCC certification matters.

[Lscott]

8 hours ago, Monsterduc said:

I’m looking for more of a nuts-and-bolts explanation of frequencies, bandwidths, transmit power, etc. and less of an explanation of the part 95 rules

It really boils down to the user/operator/programmer of the radio. If a non certified radio is carefully programmed to meet the exact frequency, bandwidth and power limits of the service it would be very unlikely to be distinguishable from an officially certified radio. However the services are primarily aimed for the general public that has little to no technical knowledge of radio theory. Thus the certification rules are designed to physically limit the radio's operation to avoid interference to other services due to accidental miss adjustment of the radio if access was allowed to arbitrary, freely, adjustable frequency, power and bandwidth settings. So, in general the rules are such that a lay person could simply buy a certified radio, turn it on, and immediately use it without the possibility of disrupting other services.

Do people use opened up Ham gear, non certified commercial gear etc. on the various Part 95 services, yes, but the smart ones won't admit to it in a public forum, and they are very careful how they program their radios to avoid interference and disruptive operations. They usually have the necessary technical expertise to do so.

[marcspaz]

 

The answer to all 3 questions are "just the FCC rules."

 

The long and short of it... the FCC is less worried about the hardware compliance for performance sake and more worried about the end user.  Restricting the hardware to help prevent users who are not knowledgeable from getting on emergency frequencies and causing harmful interference is the end goal.  There are some other license holders that they are trying to prevent interference with, too... but emergency services is the top priority.

 

There are a bunch of radios that are capable of covering all of the desired frequencies and typically outperform the technical requirements for GMRS and other services, but due to the risk of harmful interference, they can't get certified for legal use.

 

[OffRoaderX]

4 hours ago, kidphc said:

they can identify many radios by spectral fingerprints as well as electronic finger print of the circuitry with power applied to the circuit and not just when transmitting.

Based on my understanding, they can only do this after they have observed, identified, and fingerprinted the radio.. They cannot tell anything about a fresh, out-of-the-box, never before surveilled radio.

[Socalgmrs]

So MANY MANY people do exactly what you’re talking about and MANY MANY get away with it.  NO ONE will ever know what radio you’re transmitting on unless you tell them. People can’t even tell a $20 uv5r to a $5000 Motorola.  No way they can tell if you’re in a ham or gmrs eadio.   If you’re not over wattage, great even better.   The very very few times this has been enforced it has been an add on charge.  The transmitter in a uv5r and uv5g is exactly the same. Just one is locked out of everything but gmrs and one can be unlocked to all available frequencies it can transmit on, both uhf and vhf.  So if you care about being “legal” get a gmrs cert radio and if you do t care then get the radio you want and don’t tell. If that’s what you want to do knowing the “rules/laws”.  

[OffRoaderX]

1 minute ago, Socalgmrs said:

So MANY MANY people do exactly what you’re talking about and MANY MANY get away with it.  ....  If you’re not over wattage, great even better

Just for clarification - According to the FCC's own records & data, 99.99999% of people doing it in the last 15 years "get away with it", and 99.9999% of people also over wattage, have also gotten away with it. 

[kidphc]

So MANY MANY people do exactly what you’re talking about and MANY MANY get away with it.  NO ONE will ever know what radio you’re transmitting on unless you tell them. People can’t even tell a $20 uv5r to a $5000 Motorola.  No way they can tell if you’re in a ham or gmrs eadio.   If you’re not over wattage, great even better.   The very very few times this has been enforced it has been an add on charge.  The transmitter in a uv5r and uv5g is exactly the same. Just one is locked out of everything but gmrs and one can be unlocked to all available frequencies it can transmit on, both uhf and vhf.  So if you care about being “legal” get a gmrs cert radio and if you do t care then get the radio you want and don’t tell. If that’s what you want to do knowing the “rules/laws”.  

I saw old ass video of an FCC enforcement truck. The guy was impromptu interviewing a field officer.

According to them they can identify many radios by spectral fingerprints as well as electronic finger print of the circuitry with power applied to the circuit and not just when transmitting.

He did mention they are undermanned.

Enforcement cost a lot of money and time. They are better off selling spectrum for the big bucks.

So you really have to screw up before they actually start door knock. Usually, entails interferring with someone paying for spectral space to make money off of.

Me personally, I would pay a bit more for a Motorola Jedi than a UV5r (yes I have several of the variants). For the durability and spectral cleanliness.


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[nokones]

9 hours ago, OffRoaderX said:

Just for clarification - According to the FCC's own records & data, 99.99999% of people doing it in the last 15 years "get away with it", and 99.9999% of people also over wattage, have also gotten away with it. 

Probably because the close friends of those 99.9999% people don't know of their shenanigans and haven't dropped a dime on them yet to the FCC, or as you have stated a gazillion times, most people probably don't care..

[marcspaz]

13 minutes ago, nokones said:

Probably because the close friends of those 99.9999% people don't know of their shenanigans and haven't dropped a dime on them yet to the FCC, or as you have stated a gazillion times, most people probably don't care..

 

Man... in my neighborhood, snitches get got!  Quick. 

[amaff]

Help me out here. On 1 hand, "one must only transmit on type accepted radios OR ELSE!"

24 minutes ago, nokones said:

Probably because the close friends of those 99.9999% people don't know of their shenanigans and haven't dropped a dime on them yet to the FCC, or as you have stated a gazillion times, most people probably don't care..

But on the other hand, chinese radios suck and are bad and no one should use them

1 hour ago, nokones said:

It is really amazing that people spend and waste their money and put up with all the problems and limitations of these POS CCRs.

So...what GMRS radios are out there that are type accepted, and not Chinese? Because by your logic (CCRs bad, non-type-accepted bad), it sounds like no one should be using GMRS period.

[SteveShannon]

17 minutes ago, amaff said:

what GMRS radios are out there that are type accepted, and not Chinese?

Garmin radios are still made in Taiwan I believe.  Mine was anyway.

[kidphc]

Help me out here. On 1 hand, "one must only transmit on type accepted radios OR ELSE!"
So...what GMRS radios are out there that are type accepted, and not Chinese? Because by your logic (CCRs bad, non-type-accepted bad), it sounds like no one should be using GMRS period.

Sadly I think part of the reason that ccr are terrible (not all but the one that are especially looked at by novices) is if you look at the FCC certification for the radio it's done in a lab in China. Often with the same person, so it feels like no real certification is going on except for a rubber stamp.

It would be like asking your wife to certify you were working to your employeer while you were in the pool all day.






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[tweiss3]

Again, it it comes back to trying to regulate so that one cannot make a mistake, but it still happens to everyone. Even running a dedicated Part 95 approved radio for GMRS, grabbing the wrong mic and using the wrong call sign. The reason many of the newer Chinese radios over lock the firmware (only 1 repeater channel possible for each repeater frequency) is to keep you from using the radio outside of GMRS. 

Once you get away from CCRs and into real LMR equipment, you begin to see the benefit of zones and other features. MURS has no use to me, so I don't ever even listen, but I do listen to railroad while traveling. Zones can let you split up frequencies by location/service/etc. Build separate zones for GMRS and ham, then when you are scanning the zone, you only respond to ham or GMRS. My Harris radio will go even further, by holding multiple mission plans (on the fly changing of code plugs). I have 1 for amateur radio (with zones for each group of counties in the entire state), and 1 for work frequencies. Can't ever mix them up then, even with a bump of a button.

I have issues with many of the cheap chinese radios and their performance overall. While technically just as wrong, using proper LMR radios with Part 90 certifications is less of a concern when used on GMRS. They technically meet all the performance criteria of Part 95, where as the CCR radios are a huge crap shoot if it meets, they just toss a different firmware and sticker on the radio. I know some meet specs, and they may have gotten better over the last few years, but after my experiences with front end overload of expensive CCRs, I've determined it's not worth the cost savings to deal with a marginal receiver (and possible out of spec radio), not to mention the other plusses of true LMR equipment. 

[amaff]

12 minutes ago, SteveShannon said:

Garmin radios are still made in Taiwan I believe.  Mine was anyway.

Ah. I'd forgotten about those. The only GMRS HTs with more disrespectful pricing than Midland

So, 1 (very expensive) example.

[kidphc]

Again, it it comes back to trying to regulate so that one cannot make a mistake, but it still happens to everyone. Even running a dedicated Part 95 approved radio for GMRS, grabbing the wrong mic and using the wrong call sign. The reason many of the newer Chinese radios over lock the firmware (only 1 repeater channel possible for each repeater frequency) is to keep you from using the radio outside of GMRS. 
Once you get away from CCRs and into real LMR equipment, you begin to see the benefit of zones and other features. MURS has no use to me, so I don't ever even listen, but I do listen to railroad while traveling. Zones can let you split up frequencies by location/service/etc. Build separate zones for GMRS and ham, then when you are scanning the zone, you only respond to ham or GMRS. My Harris radio will go even further, by holding multiple mission plans (on the fly changing of code plugs). I have 1 for amateur radio (with zones for each group of counties in the entire state), and 1 for work frequencies. Can't ever mix them up then, even with a bump of a button.
I have issues with many of the cheap chinese radios and their performance overall. While technically just as wrong, using proper LMR radios with Part 90 certifications is less of a concern when used on GMRS. They technically meet all the performance criteria of Part 95, where as the CCR radios are a huge crap shoot if it meets, they just toss a different firmware and sticker on the radio. I know some meet specs, and they may have gotten better over the last few years, but after my experiences with front end overload of expensive CCRs, I've determined it's not worth the cost savings to deal with a marginal receiver (and possible out of spec radio), not to mention the other plusses of true LMR equipment. 

Side note how you like the Xg100m?

The mission plans have me spoiled personally.

Got to play with a kenwood armada. They sound so clean. But it's like one of those things that is so expensive for common folk it didn't even register as a real thing.

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[SteveShannon]

20 minutes ago, amaff said:

Ah. I'd forgotten about those. The only GMRS HTs with more disrespectful pricing than Midland

So, 1 (very expensive) example.

Really they’re a GPS with a sunlight visible screen, a full set of topo maps and a GMRS radio .

Several members of my rocketry club got them because Garmin pioneered sending locations between GMRS radios. In our hilly terrain it means we can find someone who might have gotten hurt.

Also, I think my Midland and Motorola GMRS radios were from Malaysia rather than China.  They were not $20 radios, but they weren’t $400 either, maybe $100 for 2?

I guess the moral is this: if you want a $20 radio, it will almost certainly come from China.  If you want a quality radio from somewhere other than China, be prepared to pay more money. They are available though.

[kidphc]

Based on my understanding, they can only do this after they have observed, identified, and fingerprinted the radio.. They cannot tell anything about a fresh, out-of-the-box, never before surveilled radio.

Would make sense more for judiciary trial evidence.

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[marcspaz]

1 hour ago, OffRoaderX said:

Based on my understanding, they can only do this after they have observed, identified, and fingerprinted the radio.. They cannot tell anything about a fresh, out-of-the-box, never before surveilled radio.

 

I used to do this for federal law enforcement. Feel free to reach out if you want to know what was being done when I left about 2 years ago.

[Monsterduc]

Not that I had intended on bringing up the legal side of things, but I think this video from @OffRoaderX sums up the FCC's stance on non-compliant radio enforcement pretty well.
https://www.youtube.com/watch?v=gh9rV49_i70

Thanks to everyone who's shared their thoughts so far.

[WRUI365]

Man you people don't want to know what I have at hand. ,Some mad in Malaysia, Some in Japan, and yes one made in the U.S.

[WRXB215]

I have "compliant" radios. They do exactly what I tell them.