Imagine Nationwide or International Coverage of your GMRS Repeater, Legally!

[TDM827]

If you are going to talk the talk, walk the walk.

I propose you very publicly invest your time, money and reputation and create several of these "networks" and openly and proudly operate them. Frequently post to this group and keep us updated. This includes running it by the GMRS community. And most importantly, invite the FCC in to render an opinion on what you are doing. After all, if you are doing nothing wrong why worry, lol. 

If the FCC gives you their blessing you should be congratulated, I am sure you will be hero to many here seeking to evolve GMRS. 

I think what most people here are saying is you just don't have enough skin in the game for them to invest in your proposal.

I really look forward to you updating us on your communication and  coordination with the FCC.  

[WSGL219]

2 hours ago, CaptainSarcastic said:

A community is best served by a reliable repeater that covers the community - hearing conversations from across the country on a linked system does not benefit the local community who are wanting/needing to communicate with folks in their local area.

 

Let Ham Radio be Ham Radio, and let GMRS be GMRS.

This is exactly why i got into GMRS and not ham. We offroad, hike and camp. I dont want to be in the California desert and hear someone in Nevada calling out trails, talking to their point man or tail. Its a local system for local use. 

[SteveShannon]

38 minutes ago, 73blazer said:

Correct wording, "their interpretation" ! . Someone got it right for once! They're likely response is not to give a direct yes or no answer, they're likely to respond, after many months, with quotes of the part 95 section rules, leaving him right back in the same boat he's in now, interpreting it himself.

I said it like that because I am not convinced that the regulations support this interpretation. But I suspect it would be very expensive to fight them. 

[WSFL951]

1. What was the purpose of establishing a worldwide repeater system when other countries do not have GMRS?  

2. GMRS has only a few repeater frequencies. If all the repeaters in the United States operate on the same frequency, it will lead to interference, including with some rescue repeaters.

[73blazer]

2 minutes ago, WSFL951 said:

1. What was the purpose of establishing a nationwide repeater system when other countries do not have GMRS?  

2. GMRS has only a few repeater frequencies. If all the repeaters in the United States operate on the same frequency, it will lead to interference, including with some rescue repeaters.

I don't think it's a nationwide network of repeaters he's proposing, my read on his proposal is only to access one repeater from anywhere in the country...or world. perhaps.

[BoxCar]

1 minute ago, 73blazer said:

I don't think it's a nationwide network of repeaters he's proposing, my read on his proposal is only to access one repeater from anywhere in the country...or world. perhaps.

That can only happen by connecting the local repeater to another network. If the control passes only control codes affecting the ability of the target to carry information, then the connection is valid, however, should any other type of information be transmitted through the connection the connection becomes invalid as different networks carrying information ae interconnected. With a stricter interpretation of the relevant section, it would be an invalid connection even if the purpose were to listen (monitor) traffic on the target radio.

[CogentRadios]

55 minutes ago, 73blazer said:

I don't think it's a nationwide network of repeaters he's proposing, my read on his proposal is only to access one repeater from anywhere in the country...or world. perhaps.

I see there is a bit of confusion, this repeater would only be accessed by the people in that community via poc. Lets say you travel outside of the area on vacation you can still access the community. The question is the legal definitions. This is not a linked system for everyone, like linked repeaters were. Although its a novel idea, I do not want my system accessed by every joe blow in the US with a DTMF pad. I am working on the proposal and will share when completed.

[CogentRadios]

This was sent to the FCC for clarification to start the conversation.

POC GMRS rule clarification,

The rules and definitions pertaining to utilizing digital to analog FM technologies are not real clear and I am seeking clarification regarding the following scenario.

 

Utilizing POC (Push to talk over cellular) data radios bridged to an analog GMRS repeater. The POC’s do not fall into the definition of network, linking, Clear Communications or real time communications as defined by the FCC. There are multiple questions regarding this, and I hope to lay them all out to the best of my ability get the best clarification I can.

The scenario would be users utilizing a POC radio with a license validated group meaning that users in that group hold a valid GMRS license, the users would access a dedicated server through digital means, not a phone system as currently specified and defined by the FCC.

Once the signal reaches the bridge a conversion takes place from digital communications to analog FM just as a standard radio accessing the repeater would. The bridge, a radio would be under physical control and not operated remotely.

One of the questions that needs clarification is, what is the point of “Clear Communications”, is it the point that the data stream is initiated or the point that the conversion from digital to analog FM takes place. This I feel is crucial point of the transmit chain since “Clear Communication” does not take place until conversion to FM happens and vice versa. The way I understand “Clear Communications” is for example FM to FM not digital to FM it would be unintelligible.

I would also like to note in part 47 points out that GMRS or FRS devices ARE authorized to transmit data to include location and “Text Messages” essentially creating a digital network if there is more than one device. This creates confusion when part 47 states no network connections are allowed on GMRS systems or repeaters. Outside mesh networks could decipher and decode the digital location or text message essentially expanding the network between the two devices.

A ruling clarification has already been rendered on linking multiple GMRS repeaters, this is not applicable since there is no repeater linking or additional spectrum use either from the end user or repeater associated with this approach.

I would also like to point out that only licensed users in the designated community would have access to the system, meaning that NOT anyone with a POC radio would be able to access the Repeater as in a linked repeater scenario.

According to the following rules:

§ 95.1749 GMRS network connection.

Operation of a GMRS station with a telephone connection is prohibited, as in § 95.349. GMRS repeater, base and fixed stations, however, may be connected to the public switched network or other networks for the sole purpose of operation by remote control pursuant to § 95.1745.

§ 95.1731 Permissible GMRS uses.

The operator of a GMRS station may use that station for two-way plain language voice communications with other GMRS stations and with FRS units concerning personal or business activities.

(d) Digital data.  GMRS hand-held portable units may transmit digital data containing location information, or request location information from one or more other GMRS or FRS units, or containing a brief text message to another specific GMRS or FRS unit

95.1733 Prohibited GMRS uses.

(8) Messages which are both conveyed by a wireline control link and transmitted by a GMRS station;

 This brings into definition what is the legal definition of a network and at what point does clear communications take place.

The FCC does not explicitly define "network" in a single, clear statement, but based on its regulations and interpretations, a network is generally understood as a system of interconnected communication points, like radio stations, television channels, or internet service providers, that can transmit signals or data across a large area, falling under the FCC's jurisdiction for regulating interstate and international communications via radio, television, wire, satellite, and cable.

The follow up definition would be the definition of interconnectivity by the FCC.

The Federal Communications Commission (FCC) defines "interconnected VoIP service" as a service that allows users to make and receive calls to the public switched telephone network (PSTN). Interconnected VoIP services use Voice over Internet Protocol (VoIP) technology.

According to this definition a direct example of VOIP was given which clearly states  switched telephone network and I present no contest on this, but by mere definition this does not apply to a POC bridge to a GMRS repeater. The POC is digital stream, controlled by a closed server which directs a digital stream to a bridge device facilitating the conversion to FM. Just to point out another perspective on network, would the GMRS repeater with the users not also be considered a network or defined as such?

 

Although the broad definition of network could be applied to a POC radio system, I believe that at the point of conversion utilizing the “Clear Communications”  principal when the conversion and transmission to the repeater takes place it would be no different than a local user accessing the system as intended and does not apply. The possibilities this system brings to communities utilizing a GMRS repeater are multifold coupling utility with safety and maintaining the integrity of the allocated frequency spectrum. The antiquated approach to GMRS management is falling short of market technologies and advancements in communication.

I am grateful for your time and counsel on this I look forward to hearing from you.

 

Frank Sellers

CEO/President

 Cogent Radios Group

+1.931.208.0484

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[WSFF627]

I understand what your trying to do, its a cool idea and I sincerely hope it works out for you. 

However, I believe the FCC is going to tell you you cant do it because it is a clear violation of the rules as written.  POC uses the Cell telephone / data network. It is a network in every sense of the word. As I and others have stated before, yes you can connect a repeater for remote control of the repeater, you cant do it to carry messages / voice comms.

In any case, please keep us posted with the FCCs answer. This is and has been a good conversation.

[gortex2]

So in a nutshell you want to charge users for a service that some use already with zello. I guess I dont see the need to add LTE to a repeater that is for local use. If I wanted extended coverage I'd either install a second repeater or go to a service I can do other stuff. I have SAR stuff linked to Zello and it works for what it is. I clearly do not understand the facination of making GMRS into ham radio or commercial LMR all the time. 

[nokones]

19 hours ago, CogentRadios said:

Right, so the initial transmission is active on a digital fabric through an isolated server frame then relayed to a bridge where it is transmitted to the repeater in analog FM. Yes the transmitter is type accepted, a Hytera MN360. That's the point of establishing what the FCC defines as "Real Time Communications". So the bridge is under my direct control and not remote and does not go through a phone system. I will be writing up a request for clarification this week and forwarding it to the FCC . Its going to take me a week to just cover the definitions and applicability. Once I hear back I will share the request and findings with everyone. If I am wrong then I am wrong and will comply but under part 47 rules I really do not think I am. Even the definition of remote would not apply if I have physical control over the bridge.

 

It's not Part 47, it is Title 47.

[WSFL951]

21 hours ago, amaff said:

[nokones]

19 hours ago, WSGL219 said:

This is exactly why i got into GMRS and not ham. We offroad, hike and camp. I dont want to be in the California desert and hear someone in Nevada calling out trails, talking to their point man or tail. Its a local system for local use. 

And more than likely you won't be hearing someone in Nevada while you're in California calling out Trail Comms to other Jeepers. The trail comms are communicated on simplex channels and a majority of the Jeep Creeps use FRS radios and do not have access to Repeater channels. 

Anyways, most trails do not have repeater coverage and if they do than the coverage would be very sparse, thus the importance of using direct communications within the group.

[CogentRadios]

3 hours ago, WSFF627 said:

I understand what your trying to do, its a cool idea and I sincerely hope it works out for you. 

However, I believe the FCC is going to tell you you cant do it because it is a clear violation of the rules as written.  POC uses the Cell telephone / data network. It is a network in every sense of the word. As I and others have stated before, yes you can connect a repeater for remote control of the repeater, you cant do it to carry messages / voice comms.

In any case, please keep us posted with the FCCs answer. This is and has been a good conversation.

That may be the case, I think that Chevron vs. EPA will play a role in this ruling, the gist of the matter is that all rulings that carry a penalty of law or in effect act as a law generated by a federal agency and not congress are un-constitutional, that's why you hear guys acting the fool on the ham bands, cursing is considered a form of expression and subject to 1A protections. So if a Gov agency makes rules that present themselves as a law that's a constitutional violation because agencies do not have the authority to do that. A recent ruling that came into play is the bumpstock ruling, it was found to be unconstitutional because the ATF does not have that authority, congress does. This applies to all federal agencies, so if I get the boiler plate response I will escalate to the next level authority, next step is getting my congressman involved.

Well what about the communications act of 1934 you ask, once again the portion authorizing the FCC to enforce rules they wrote and arbitrate is and has been ruled a constitutional violation and subject to higher examination than administrative operational actions. A lot of people just dont understand how important the Chevron vs. EPA actually was and the broad impact that it has to benefit Americans.

 

[CogentRadios]

1 hour ago, gortex2 said:

So in a nutshell you want to charge users for a service that some use already with zello. I guess I dont see the need to add LTE to a repeater that is for local use. If I wanted extended coverage I'd either install a second repeater or go to a service I can do other stuff. I have SAR stuff linked to Zello and it works for what it is. I clearly do not understand the facination of making GMRS into ham radio or commercial LMR all the time. 

No, not only is the nutshell soft, its not even in the same conversation.

[TDM827]

This is gonna be fun to sit back and watch!

[MarkInTampa]

I picked up a VGC VR-N7500 50 watt mobile a few years ago just for grins for use as a base station. No display, no mic and everything runs via a app on a Android device and Bluetooth. What is kinda cool (and why I bought the radio) was that you could allow others on the internet with permission and app installed access to the radio, kinda like Zellow. So I setup a spare tablet connected on internet and the radio, installed the app on my phone and was able to access my favorite GMRS repeater from anywhere and it was cheap - like $150 or so, it's hard to find ANY 50 watt mobile for that price.

I could have setup multiple users, but I don't own the repeater I had the radio programmed to. IT WASN'T MY REPEATER to do so. I don't think a repeater owner would be very happy to find out his repeater is now a "networked repeater" without his knowledge. I just thought it was cool to be able to use for myself. Used it for a week or so and it worked great. The radio now sits on the shelf unused, I just hated the interface and never really used the radio remotely.

[CogentRadios]

11 minutes ago, MarkInTampa said:

I picked up a VGC VR-N7500 50 watt mobile a few years ago just for grins for use as a base station. No display, no mic and everything runs via a app on a Android device and Bluetooth. What is kinda cool (and why I bought the radio) was that you could allow others on the internet with permission and app installed access to the radio, kinda like Zellow. So I setup a spare tablet connected on internet and the radio, installed the app on my phone and was able to access my favorite GMRS repeater from anywhere and it was cheap - like $150 or so, it's hard to find ANY 50 watt mobile for that price.

I could have setup multiple users, but I don't own the repeater I had the radio programmed to. IT WASN'T MY REPEATER to do so. I don't think a repeater owner would be very happy to find out his repeater is now a "networked repeater" without his knowledge. I just thought it was cool to be able to use for myself. Used it for a week or so and it worked great. The radio now sits on the shelf unused, I just hated the interface and never really used the radio remotely.

Thats cool, and as a repeater owner I thank you for not doing it, LOLOL