GMRS: Use of Part 90 radios on Part 95

RFI-EMI-GUY · Nov 9, 2017

I am inviting discussion on interest in petitioning the FCC to permit cross certification of certain Part 90 radios for use in Part 95, provided they are factory or field programmed by a Certified (GROL etc) Technician to meet the restrictions of Part 95 operation.

My reasons are:

1) There is a dearth of new commercial and public safety grade radios for GMRS. Most are bubble pack consumer grade radios.

2) Most of the consumer grade radios being offered lack repeater offset capabilities and other features required for repeater operations.

3) None of the current consumer radios offered provide full channel deviation and receiver bandwidth permitted by GMRS rules. The radios do not provide 16K0F3E emission (+/- 5.0 KHz deviation) nor do the receiver specifications reflect 25 KHz wideband operation. This technical deficiency reduces the effective range and voice quality of GMRS operations. (1)

4) There are no repeaters being manufactured that are Part 95 certified. (Bridgecom claims to be but this author has been unable to independently verify this using FCC OET search)

5) There is a need for users of Part 90 radios to access GMRS channels. (Search and Rescue, CERT, etc)

6) There are Part 90 radios in service in GMRS and as many are in aged condition, operators are faced with buying equipment that is substandard in order to be compliant with FCC rules.

There is a surplus of Part 90 radios that are perfectly acceptable for use in GMRS Part 95 but no longer suitable for Part 90 under the narrowbanding mandate. Having access to these radios would improve the quality and utility of GMRS.

To be frank, I see many Part 90 radios being used in GMRS so there is that.

(1) LEIKHIM AND ASSOCIATES LLC - VHF-UHF Narrowbanding

jhooten · Nov 9, 2017

You do know that current Part 90 radios cannot do "16K0F3E emission (+/- 5.0 KHz deviation) nor do the receiver specifications reflect 25 KHz wideband operation", don't you?

From this document: https://transition.fcc.gov/pshs/docs/clearinghouse/guidelines/Narrowbanding_Booklet.pdf one can find the following,
"VHF and UHF transmitters that operate with a maximum channel bandwidth greater than
12.5 kHz may not be manufactured in or imported into the United States after January 1,
2011"

RFI-EMI-GUY · Nov 10, 2017

jhooten said:
You do know that current Part 90 radios cannot do "16K0F3E emission (+/- 5.0 KHz deviation) nor do the receiver specifications reflect 25 KHz wideband operation", don't you?

From this document: https://transition.fcc.gov/pshs/docs/clearinghouse/guidelines/Narrowbanding_Booklet.pdf one can find the following,
"VHF and UHF transmitters that operate with a maximum channel bandwidth greater than
12.5 kHz may not be manufactured in or imported into the United States after January 1,
2011"

You are correct about current models, and the amendment would have to address that.

There are radios designed prior to a certain date that do wideband and there are radios after a certain date that do both wideband and narrow band. But some current radios actually will do wideband if you have the proper software or entitlement key.

There are some exceptions to wideband within the 450-470 MHz band such as CFR 47 Part 22 where channels are still allocated on 25 KHz centers. Operators in a geographic area could choose to deploy two way repeater services.

jhooten · Nov 10, 2017

I do agree that it is a good use for some of the piles of no longer compliant part 90 radios sitting on shelves after being replaced with narrow band units.

As you said wide band keys are available for some radios. Getting one can be a bureaucratic nightmare.

Thunderknight · Nov 10, 2017

Well the manufacturers could just allow wideband on the gmrs channels as part of the firmware. I really don't get the Motorola entitlement key thing for certain models and not others. My CDM needs an entitlement key, my APX has the permitted WB channels as part of the firmware/CPS.

Of course it's also perfectly permissible to run NB on GMRS if you want to.

But I do agree with the concept...to just make part 90 gear legal on GMRS (licensed users GMRS) would be a good reuse of equipment. But then again, I'm not sure it will go over well at the FCC since they don't seem to like mixing services.

Project25_MASTR · Nov 10, 2017

jhooten said:
You do know that current Part 90 radios cannot do "16K0F3E emission (+/- 5.0 KHz deviation) nor do the receiver specifications reflect 25 KHz wideband operation", don't you?

From this document: https://transition.fcc.gov/pshs/docs/clearinghouse/guidelines/Narrowbanding_Booklet.pdf one can find the following,
"VHF and UHF transmitters that operate with a maximum channel bandwidth greater than
12.5 kHz may not be manufactured in or imported into the United States after January 1,
2011"

Not exactly. Motorola still certifies radios for it actually. However, you have to have either a Wideband EID or have the radio (such as an APX SU) have firmware which acknowledges wideband services and still allows the programming of wideband in those ranges. On UHF AXP radios for example, the 70 cm band, GMRS and T band portions of the tuning range are actually capable of wideband.

RFI-EMI-GUY, I actually believe there is a posted letter floating around on a forum somewhere (MyGMRS maybe) that has the opinion of someone in the FCC stating Part 90 radios are GTG but I've not seen it in a year or two but it does certainly pre-date the recent rule change.

DaveNF2G · Nov 10, 2017

The FCC will need a financial incentive, especially to revisit previously certified and possibly obsolete transmitters. No fees, no action.

KD8DVR · Nov 10, 2017

RFI-EMI-GUY said:
I am inviting discussion on interest in petitioning the FCC to permit cross certification of certain Part 90 radios for use in Part 95, provided they are factory or field programmed by a Certified (GROL etc) Technician to meet the restrictions of Part 95 operation.

My reasons are:

1) There is a dearth of new commercial and public safety grade radios for GMRS. Most are bubble pack consumer grade radios.

2) Most of the consumer grade radios being offered lack repeater offset capabilities and other features required for repeater operations.

3) None of the current consumer radios offered provide full channel deviation and receiver bandwidth permitted by GMRS rules. The radios do not provide 16K0F3E emission (+/- 5.0 KHz deviation) nor do the receiver specifications reflect 25 KHz wideband operation. This technical deficiency reduces the effective range and voice quality of GMRS operations. (1)

4) There are no repeaters being manufactured that are Part 95 certified. (Bridgecom claims to be but this author has been unable to independently verify this using FCC OET search)

5) There is a need for users of Part 90 radios to access GMRS channels. (Search and Rescue, CERT, etc)

6) There are Part 90 radios in service in GMRS and as many are in aged condition, operators are faced with buying equipment that is substandard in order to be compliant with FCC rules.

There is a surplus of Part 90 radios that are perfectly acceptable for use in GMRS Part 95 but no longer suitable for Part 90 under the narrowbanding mandate. Having access to these radios would improve the quality and utility of GMRS.

To be frank, I see many Part 90 radios being used in GMRS so there is that.

(1) LEIKHIM AND ASSOCIATES LLC - VHF-UHF Narrowbanding

Submit a proposal for rulemaking.

Sent from my SAMSUNG-SM-G920A using Tapatalk

RFI-EMI-GUY · Nov 10, 2017

KD8DVR said:
Submit a proposal for rulemaking.

Sent from my SAMSUNG-SM-G920A using Tapatalk

That's what I would like to do. In past, I have successfully applied for waivers for other clients in Part 90. This shouldn't be difficult to draft. I want to have the discussion and get valuable input.

I touched on this subject during reply comments for the recent Part 95 rewrite and the FCC did not see it as timely. But they didn't shoot it down entirely.

The NPRM will have a comments cycle and there could be push-back from the bubble pack vendors and if the response from GMRS rank and File is "Meh" it wont go far.

RFI-EMI-GUY · Nov 10, 2017

DaveNF2G said:
The FCC will need a financial incentive, especially to revisit previously certified and possibly obsolete transmitters. No fees, no action.

The FCC will just have a couple meetings , put it out on notice for reply comments, review the responses and make a decision. I don't see why they would have to get the OET involved in reviewing previous certifications.

As far as incentive, more licenses = more filing fees to FCC, In the short term 1,000 new licenses at $70 a pop would cover the cost of those meetings.

What might help would be some graphic comparison of Part 90 25 KHz emission mask and the current w5 KHz mask described in Part 95. I think there are some differences in the manner the same mask is presented in the rules or Part 90 is tighter.

Any thoughts...Class? . Buehler?

RFI-EMI-GUY · Nov 10, 2017

MCore25 said:
Not exactly. Motorola still certifies radios for it actually. However, you have to have either a Wideband EID or have the radio (such as an APX SU) have firmware which acknowledges wideband services and still allows the programming of wideband in those ranges. On UHF AXP radios for example, the 70 cm band, GMRS and T band portions of the tuning range are actually capable of wideband.

RFI-EMI-GUY, I actually believe there is a posted letter floating around on a forum somewhere (MyGMRS maybe) that has the opinion of someone in the FCC stating Part 90 radios are GTG but I've not seen it in a year or two but it does certainly pre-date the recent rule change.

Interesting that the APX has specifically mapped GMRS as wide-band capable. Do they have Part 95 certification on the FCC grant?

I would love to see that letter!

The old rules contained a paragraph instructing licensees to contact the local FCC office to determine if a particular radio was OK. These were pre internet days so it could be the local office had a list of the couple dozen LMR radios that were certified OR the FCC Field Engineer made a decision to whether the radio was OK. The way the rule was written were vague.

radioman2001 · Nov 10, 2017

Pick a radio you want to use, run the FCC id and see if that model was dual certified. A lot of them were, and some were even certified for part 80 for Marine.

Project25_MASTR · Nov 10, 2017

RFI-EMI-GUY said:
Interesting that the APX has specifically mapped GMRS as wide-band capable. Do they have Part 95 certification on the FCC grant?

I would love to see that letter!

The old rules contained a paragraph instructing licensees to contact the local FCC office to determine if a particular radio was OK. These were pre internet days so it could be the local office had a list of the couple dozen LMR radios that were certified OR the FCC Field Engineer made a decision to whether the radio was OK. The way the rule was written were vague.

Next to no one buying APX's local to me buys UHF (VHF and 7/800 are kings here). I'd imagine that they are not in there but considering the last few NIFOGs have listed MURS and GMRS frequencies I can understand why Motorola put the info in there.

RadioGuy7268 · Nov 10, 2017

I like your basic idea, and fully agree with your goal of putting good analog equipment to work. I've seen plenty of decent pieces of equipment laying around un-used that would work well on GMRS.

That said, I think the FCC's baseline stance would be one of: "Why should we go back and do this now? The manufacturers could have, and should have, applied for Part 95 certification at the time their radios were type accepted."

Plenty of Kenwood radios had both Part 90 & 95 type acceptance. Motorola made the M1225/GR1225/P1225 with both part 90 & 95 certs - but then stopped doing that when they went to the CM200/CP200 line. If the difference of emissions was not significant - why NOT get the added cert? Probably due to sales vs. the added cost of type acceptance testing & filing, right?

If the FCC would allow an "after the fact" type acceptance change to happen now, what would stop that from being used again in the future? Why bother with type acceptance costs now, if you can just apply a retro-active standard later?

Finally - why limit the programming to FCC Licensed tech's? There's no such limitation on that for Part 90 or 95 even now, so why add a new twist to the mix? My guess is that nearly half of people out there programming radios have no GROL or equivalent license - and the FCC hasn't mandated technician licensing since the days of de-regulation in the early 1980's.

Again, I would hope that the FCC would look favorably on giving equivalent status to type 90 equipment. I just think that something less formal than an FCC rule making would be the way to get it done.

N4GIX · Nov 10, 2017

RFI-EMI-GUY said:
4) There are no repeaters being manufactured that are Part 95 certified. (Bridgecom claims to be but this author has been unable to independently verify this using FCC OET search)

Please refer to my latest reply in the "Is it just me" thread. I popped the cover on my BCR-40U to obtain the certifications for the actual radio(s) being used in this repeater.

SK4MPTM40U
https://fccid.io/SK4MPTM40U

Note that they have no "front panels" at all, and take note of their certifications: 22, 74, 90, 95A

bill4long · Nov 10, 2017

I have been thinking of filing a petition myself for some time. But it's probably a waste of time.

RFI-EMI-GUY said:
To be frank, I see many Part 90 radios being used in GMRS so there is that.

Yep. Have you ever heard of the FCC busting anyone for using Part 90 gear on GMRS? Me neither. And you never will. Why? The FCC knows that Part 90 radios are technically worthy, right there in the middle of the 420-450 UHF band. Also, the FCC is complaint driven and they frankly have better things to do with their limited resources that police GMRS, unless some GMRS transmitter is actually interfering with another service. They know people are using Part 90 on GMRS and they frankly don't care in practice. For heaven sakes, there's an unlicensed rogue GMRS repeater in NYC that's been operating for years, and they have done nothing. What does that tell you?

But file the petition anyway. It can't hurt. It won't cost you anything. And who knows, they might get off their dead butts and do the right thing.

One comment on your proposal: why should I have to use a "certified" tech to program my GM-300 or other Part 90 radio? I'm quite capable of doing it myself. For gawd sakes, it's being done out there. Like the plague. Scrap the "certified technician" requirement.

bill4long · Nov 10, 2017

jhooten said:
You do know that current Part 90 radios cannot do "16K0F3E emission (+/- 5.0 KHz deviation) nor do the receiver specifications reflect 25 KHz wideband operation", don't you?"

GMRS radios may use narrow band (11K0F3E). They just cannot use digital. (Which is stupid.) Only analog allowed. At any rate, there is a stockpile of decommissioned 16K0F3E commercial radios due to narrowbanding for those who wish to use 16K0F3E. Like the plague.

95.633(2) Lesser emission bandwidths may be employed, provided that the unwanted emissions are attenuated as provided in § 95.635. See §§ 95.628(g) and 95.639(f) regarding maximum transmitter power and measurement procedures.

RFI-EMI-GUY · Nov 10, 2017

RadioGuy7268 said:
I like your basic idea, and fully agree with your goal of putting good analog equipment to work. I've seen plenty of decent pieces of equipment laying around un-used that would work well on GMRS.

That said, I think the FCC's baseline stance would be one of: "Why should we go back and do this now? The manufacturers could have, and should have, applied for Part 95 certification at the time their radios were type accepted."

Plenty of Kenwood radios had both Part 90 & 95 type acceptance. Motorola made the M1225/GR1225/P1225 with both part 90 & 95 certs - but then stopped doing that when they went to the CM200/CP200 line. If the difference of emissions was not significant - why NOT get the added cert? Probably due to sales vs. the added cost of type acceptance testing & filing, right?

If the FCC would allow an "after the fact" type acceptance change to happen now, what would stop that from being used again in the future? Why bother with type acceptance costs now, if you can just apply a retro-active standard later?

Finally - why limit the programming to FCC Licensed tech's? There's no such limitation on that for Part 90 or 95 even now, so why add a new twist to the mix? My guess is that nearly half of people out there programming radios have no GROL or equivalent license - and the FCC hasn't mandated technician licensing since the days of de-regulation in the early 1980's.

Again, I would hope that the FCC would look favorably on giving equivalent status to type 90 equipment. I just think that something less formal than an FCC rule making would be the way to get it done.

Yeas, equivalent status describes what I am proposing. Going back and retroactively certifying radios would be a waste of time and resources. I am proposing that if the Part 90 radio has the correct, emission mask, deviation, frequency error and maximum power level, and has no disqualifying features (like encryption) it should be considered an equivalent.

I proposed the GROL because at one time the GROL implied a great degree of responsibility. It is true that GROL is no longer required. And maybe offering that is not needed. That is why we are having the discussion,

As far a NPRM versus a less formal action on the part of the FCC, how would one go about that and have it be available to licensees in general?

Thank you for your inputs, you were first to notice the GROL comment!

RFI-EMI-GUY · Nov 10, 2017

Bridgecom "MANLY" 16K0F3E Wideband GMRS FCC Accepted

N4GIX said:
Please refer to my latest reply in the "Is it just me" thread. I popped the cover on my BCR-40U to obtain the certifications for the actual radio(s) being used in this repeater.

SK4MPTM40U
https://fccid.io/SK4MPTM40U

Note that they have no "front panels" at all, and take note of their certifications: 22, 74, 90, 95A

Thanks!

.It appears we can add Bridgecom to the GMRS friendly repeater and mobile manufacturer. In fact they have my beloved wide band 16K0F3E modulation available, so they make MANLY radios not bubble wrap clap trap.

I am pleased and will sleep better tonight!

RFI-EMI-GUY · Nov 10, 2017

bill4long said:
I have been thinking of filing a petition myself for some time. But it's probably a waste of time.

Yep. Have you ever heard of the FCC busting anyone for using Part 90 gear on GMRS? Me neither. And you never will. Why? The FCC knows that Part 90 radios are technically worthy, right there in the middle of the 420-450 UHF band. Also, the FCC is complaint driven and they frankly have better things to do with their limited resources that police GMRS, unless some GMRS transmitter is actually interfering with another service. They know people are using Part 90 on GMRS and they frankly don't care in practice. For heaven sakes, there's an unlicensed rogue GMRS repeater in NYC that's been operating for years, and they have done nothing. What does that tell you?

But file the petition anyway. It can't hurt. It won't cost you anything. And who knows, they might get off their dead butts and do the right thing.

One comment on your proposal: why should I have to use a "certified" tech to program my GM-300 or other Part 90 radio? I'm quite capable of doing it myself. For gawd sakes, it's being done out there. Like the plague. Scrap the "certified technician" requirement.

I agree there probably are no NAL's for any technical violations like using Part 90 gear against GMRS licensees. But, anyone wishing to construct a fully compliant, high performance system using wide band 16K0F3E and repeaters will find their choices of equipment are increasingly limited. I see an NPRM as a way to pave a path for those folks who are hesitant to deploy "better" gear.

Your comment about the GROL is well taken I through it up as a trial, but can see that may complicate matters for most users who are either well competent to program the radios or will find someone who can.

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