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GMRS / FRS - Discussions related to GMRS (General Mobile Radio Service) and FRS (Family Radio Service) communications

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Old 06-05-2017, 4:06 PM
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Default Response from the FCC on linking repeater audio over the internet and it's legality

Since this topic is always such a hotly debated one, I figured I would ask the FCC myself about the permissibility of linking audio between GMRS repeaters over the internet.

Below was the response they gave me.

Case Id: HD0000002998556

Summary: Licensing Requirements

Description: There seems to be a lot of confusion as to whether linking the audio of two or more GMRS repeaters via an internet connection is permitted or prohibited under the part 95 rules.

Could we please get some sort of clarification as to whether this is a strictly prohibited action per part 95 rules?

Thank you.

Solution Description: Dear Mr. *******,

GMRS stations may not be interconnected to the public switched telephone network as per 95.127. However, proposing to use a VoIP link between the two repeater sites is permissible if the link is considered non-interconnected VoIP. VoIP can either be an interconnected VoIP service or non-interconnected VoIP service, see the definitions below. It is my understanding that if your internet provider is the cable company, itís fine; but if you have DSL or dial-up internet from the phone company, it isnít.

The second method using RF to link the two repeater sites is allowed so long as the link meets the rules and limitations for fixed stations pursuant to the Part 95 rules.

ß64.601

(23) Non-interconnected VoIP service. The term ďnon-interconnected VoIP serviceĒó

(i) Means a service tható

(A) Enables real-time voice communications that originate from or terminate to the user's location using Internet protocol or any successor protocol; and

(B) Requires Internet protocol compatible customer premises equipment; and

(ii) Does not include any service that is an interconnected VoIP service.

ß9.3

Interconnected VoIP service. An interconnected Voice over Internet protocol (VoIP) service is a service that:

(1) Enables real-time, two-way voice communications;

(2) Requires a broadband connection from the user's location;

(3) Requires Internet protocol-compatible customer premises equipment (CPE); and

(4) Permits users generally to receive calls that originate on the public switched telephone network and to terminate calls to the public switched telephone network.

The rules may be found at the following website: https://www.fcc.gov/general/rules-regulations-title-47

Should you have any further questions, or need additional information, please submit a request through https://esupport.fcc.gov/onlinerequest.htm or call the FCC Licensing Support Center at 1-877-480-3201, selecting option 2 after the main menu.

Sincerely,

FCC Licensing Support Center
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Old 06-05-2017, 4:52 PM
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Hmmm.....
The definition between a "non-interconnected VoIP" and an "interconnected VoIP" seems a bit fuzzy to me. For example, I have a DSL connection using DSL Extreme as my ISP. The phone line used for the DSL service does not have line voltage or dial tone and cannot be used to make analog phone calls. It is strictly a broadband data connection.
Would this be considered a "non-interconnected VoIP" or an "interconnected VoIP" link?
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Old 06-05-2017, 5:22 PM
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Quote:
Originally Posted by SteveSimpkin View Post
Hmmm.....
The definition between a "non-interconnected VoIP" and an "interconnected VoIP" seems a bit fuzzy to me. For example, I have a DSL connection using DSL Extreme as my ISP. The phone line used for the DSL service does not have line voltage or dial tone and cannot be used to make analog phone calls. It is strictly a broadband data connection.
Would this be considered a "non-interconnected VoIP" or an "interconnected VoIP" link?
You can make a Cable or DSL or even a fixed wireless connection "interconnected VOIP" by buying SIP trunk access- landline phone or not.

Without telling your SIP server to connect to the PSTN via SIP trunk or other method like an autopatch you cannot dial a PSTN number and make a PSTN phone ring on the other end.

Quote:
ß9.3

Interconnected VoIP service. An interconnected Voice over Internet protocol (VoIP) service is a service that:

(4) Permits users generally to receive calls that originate on the public switched telephone network and to terminate calls to the public switched telephone network.
The intent says if you intend to allow calls to/from the PSTN from your repeater links aka tryting to provide a partyline phone service over GMRS. Having dry loop DSL and not configuring any SIP connection to the PSTN should be plenty of extra steps to ensure compliance if the FCC come knocking.

Removal of an autopatch would be the last step to ensure compliance, but that may not even be necessary.
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Old 06-05-2017, 5:45 PM
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Based purely on the response; it appears they are literally saying if your not transporting or otherwise using PSTN for autopatch or interconnection (i.e. ISP), then linking is okay. Additionally they are prohibiting "interconnection" to a VoIP service for the purpose of autopatch.
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Old 06-06-2017, 1:12 AM
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If you read carefully part 95, in its current and soon to be revised form, the actual interconnection prohibition specifically speaks of the Public Switched Telephone Network, or PSTN. The PSTN has largely ceased to exist , and the FCC knows this. The FCC support Center adding a discussion of of interconnected VoIP services only serves to confuse the issue,, and goes beyond the rules as written.

It is as simple as this, if you are interconnecting using VOIP, and your link does not require the dialing of any PSTN equipment or circuits using the North American Numbering Plan, you are fine.

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Old 06-06-2017, 6:20 AM
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Quote:
Originally Posted by RFI-EMI-GUY View Post
If you read carefully part 95, in its current and soon to be revised form, the actual interconnection prohibition specifically speaks of the Public Switched Telephone Network, or PSTN. The PSTN has largely ceased to exist , and the FCC knows this. The FCC support Center adding a discussion of of interconnected VoIP services only serves to confuse the issue,, and goes beyond the rules as written.

It is as simple as this, if you are interconnecting using VOIP, and your link does not require the dialing of any PSTN equipment or circuits using the North American Numbering Plan, you are fine.

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That's how I'm interpreting it as well.

As far as I'm concerned, this conclusively ends the linking debate altogether. Linking is straight up permissable under the rules if you don't touch the PSTN directly.
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Old 06-06-2017, 9:45 AM
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Per 9.3(4), as long as the link doesn't involve connecting telephone calls to the repeater, it is allowed.
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Old 06-06-2017, 10:15 AM
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The way I read the FCC response is if your internet is supplied by a public phone company like ATT or a Bell company DSL, then you cannot connect the repeater to that. If internet is supplied by a cable company then its fine.

Read this statement a couple more times from the FCC, and they referring to internet, not POTS.
"It is my understanding that if your internet provider is the cable company, itís fine; but if you have DSL or dial-up internet from the phone company, it isnít."

To me that means you can have two otherwise identical repeater voice to digital to internet boxes at each end of the GMRS circuit, one connected to a Joe Blow Cable Company modem and its fine, but one connected to an ATT DSL or U-Verse modem would not be legal, even if there is no POTS voice circuit on the same line.
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Quote:
Originally Posted by RFI-EMI-GUY View Post
If you read carefully part 95, in its current and soon to be revised form, the actual interconnection prohibition specifically speaks of the Public Switched Telephone Network, or PSTN. The PSTN has largely ceased to exist , and the FCC knows this. The FCC support Center adding a discussion of of interconnected VoIP services only serves to confuse the issue,, and goes beyond the rules as written.

It is as simple as this, if you are interconnecting using VOIP, and your link does not require the dialing of any PSTN equipment or circuits using the North American Numbering Plan, you are fine.

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Old 06-06-2017, 10:17 AM
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My understanding of PSTN is any network owned or operated by a Telephone Company using copper, not sure about fiber. As Verizon, ATT and etc are. So as described in the letter Cable companies like Spectrum, Optimum etc are permitted. You will have to look up your provider usually in your states Public Service Regulations to determine which is and or not. PSTN telephone companies are regulated by the FCC and the State.

This whole PTSN thing is really outdated and needs to be revamped since now with fiber and wireless the main means of telephone service. The rule was to protect the telephone monopoly so that you couldn't go around them to make a call.
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Old 06-06-2017, 10:27 AM
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The FCC response doesn't differentiate between copper or fiber, just a public phone company vs other types of internet providers. To me, internet delivered by ATT fiber all the way to the repeater location would not be legal for VoIP repeater linking. Neither would internet provided by a wireless 3G/4G router at the repeater site. And I agree its stupid and the rules should be changed or updated to cover current technology.
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Quote:
Originally Posted by radioman2001 View Post
My understanding of PSTN is any network owned or operated by a Telephone Company using copper, not sure about fiber. As Verizon, ATT and etc are. So as described in the letter Cable companies like Spectrum, Optimum etc are permitted. You will have to look up your provider usually in your states Public Service Regulations to determine which is and or not. PSTN telephone companies are regulated by the FCC and the State.

This whole PTSN thing is really outdated and needs to be revamped since now with fiber and wireless the main means of telephone service. The rule was to protect the telephone monopoly so that you couldn't go around them to make a call.
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Old 06-06-2017, 10:33 AM
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PSTN service is PSTN service no matter if the signal is carried over copper or fiber or even a microwave link.

In the simplest terms, if you hear a dial tone and have to dial a number, that's without a doubt a connection to the PSTN service.

I personally would prefer that the PSTN system should remain operational and separate, for the time being, as it is a (relatively) low tech but robust and highly reliable communications system. Since it is separately powered with its own backup power systems distributed throughout the network, when a major disaster hits, wireline telephone service, particularly if fed by underground cables, is often still operational even when every other service is down for the count.

I recall horror stories of idiots who, after a hurricane knocked utility poles down, went out to salvage copper from the "junk" lying in the yard and in doing so, took out the WORKING telephone service that was being carried on the aerial phone cables on that utility pole.

In my opinion the penalty for attempting to salvage copper from utility services should be death after a year of slow torture.
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Old 06-06-2017, 11:08 AM
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Than again you have the Telco carriers trying to rid themselves of copper, since they have to by FCC rules share it. On Long Island since Sandy some 4 years ago, Verizon has refused to reinstall copper service and is being sued by the customers. They were given some junk wireless equipment in it's place. You can't Fax on it, you can't get Internet on it, and the latency is terrible. Verizon scammed me into going that route and after only 1 day of trying it has refused to reinstate my copper service without a $1,000.00 deposit and a lot of personal information they are not entitled to. They are basically treating you as a new customer from scratch even though we have used New York Tel, Bell Atlantic and now Verizon for over 40 years.

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Old 06-06-2017, 11:15 AM
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Quote:
Originally Posted by RFI-EMI-GUY View Post
If you read carefully part 95, in its current and soon to be revised form, the actual interconnection prohibition specifically speaks of the Public Switched Telephone Network, or PSTN. The PSTN has largely ceased to exist , and the FCC knows this. The FCC support Center adding a discussion of of interconnected VoIP services only serves to confuse the issue,, and goes beyond the rules as written.

It is as simple as this, if you are interconnecting using VOIP, and your link does not require the dialing of any PSTN equipment or circuits using the North American Numbering Plan, you are fine.

Sent from my SM-T350 using Tapatalk
I am with you on this one. I think people just need a reason to debate. This has been said many times, you can not read into what is not written. You are free to interpret the law any way you choose until it goes to court and it will only be interpreted for whats written. Judges wont assume anything. PSTN is the circuited switching of audio circuits. If you are purchasing a DATA connection no judge will assume this may or may not be on the PSTN because as defined by the FCC; PSTN (public switched telephone network) is the world's collection of interconnected voice-oriented public telephone network. The key here is voice-oriented, any interface to the internet would be packet data and not as voice-oriented audio. So unless you dial a number use that connection and link away.

Last edited by coryb27; 06-06-2017 at 11:22 AM..
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Old 06-06-2017, 11:31 AM
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The FCC support Center response makes no sense at all, I could have either a DSL, a Cable or a 3G/G (wireless) modem and all three would have the same ports, an RJ11 for a local POTS line and an RJ45 Ether net LAN connection. These modems would have exactly same functionality, and the "bits" which comprise the Vo IP streams from the POTS line and any imposed from the LAN would be separately encapsulated and transported to the "internet" in the same way.

It all comes down to INTENT. If the GMRS station is utilizing the PSTN and NANP to route calls with the INTENT of providing an interconnected service, that is prohibited. But if you have a DSL modem and are using the LAN connection, and the VoIP hardware is nailed down with IP adresses, not NANP numbers, why should the FCC or even AT&T bother caring? Realistically, they don't or we would have seen station inspections and notices of violation.

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Old 06-06-2017, 12:20 PM
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I don't see how this interpretation would be enforceable. There's no way you could tell what ISP technology was used to transport the bits between repeaters by monitoring RF traffic, and the FCC can't search your premises to see what ISP technology you used to connect the repeaters without probable cause, which they could only get by monitoring your RF emissions or an insider complaint.

It's kind of like enforcing type-accepted radios only restrictions on a service. As long as you aren't exceeding maximum power or bandwidth/modulation/deviation limits, there's no way to tell you aren't using a type-accepted radio unless you get raided/searched for some other reason.
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Old 06-06-2017, 1:07 PM
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Quote:
Originally Posted by zikada View Post

Sincerely,

FCC Licensing Support Center[/b]
Without a name, although I like the answer, it is gobbledegook and BS. Someone at the FCC has to step up and own this, or it is not worth the pixels it's printed on.
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Old 06-06-2017, 1:35 PM
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The original intent of this rule was to prohibit the use of autopatch on GMRS. It seems that back in the 1980's or so, a large, statewide club in Florida was using GMRS repeaters equipped with autopatch to bypass TELCO tolls.

I would think that as long as you are not making dial-up voice calls on your repeaters, it doesn't really matter who your Internet provider is.
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Old 06-06-2017, 2:30 PM
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Quote:
Originally Posted by Citywide173 View Post
Without a name, although I like the answer, it is gobbledegook and BS. Someone at the FCC has to step up and own this, or it is not worth the pixels it's printed on.

The OP Zikada has included the Case ID number of the correspondence.

Case Id: HD0000002998556

I am saving this valuable thread to my FCC file for future reference.
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Old 06-06-2017, 3:07 PM
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I disagree with their interpretation of DSL as being interconnected. I'd say dial-up is a bit more nebulous, but also not quite "interconnected" in the way the rules are meant to prohibit.

The idea isn't to prevent linking between repeaters, it was to prevent a phone line from being hooked up to the repeater (i.e. an autopatch) where an unlicensed user could dial the phone number (intentionally or unintentionally) and begin making transmissions on the GMRS side. This is the reason for telephone interconnection being banned.

When you use DSL, you're using the phone line but your DSL modem is sending a digital signal on the phone line concurrent with any analog phone traffic. The phone company at the office end demodulates the signal and patches you into the Internet via their fiber trunks. At no point can someone dial your phone number and gain access to the repeater.

When you use dial-up it's a similar story except you're using the analog phone line to dial the remote office and send the data stream over the normal audio path. So yes, you're making a phone call over the phone line but someone can't just ring your phone number and gain access to the repeater. So even this, technically, should be allowed. I wouldn't test the FCC on it, but for technical reasons it should be permissible.

Their point about VoIP is spot-on though. A VoIP system like we use with Asterisk and app_rpt is basically a private PBX system. You're making phone calls between internal extensions, not connected to the Public Switched Telephone Network. There's no phone number for someone to dial, and no way for someone who isn't authenticated in the system from being able to activate a repeater. By restricting to GMRS licensees only (and keeping Ham operators off of the network), there is controlled access only to licensed individuals which meets the FCC's rules. Now if this VoIP system had a public phone number, it would be considered interconnected and would be in violation of the FCC rules. Again, someone could just ring that number and begin transmitting on a licensed service, which is what this aims to prevent in the first place.
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Old 06-07-2017, 7:20 AM
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And there are Regions that allow DSL on lines without Dial-tone [Rare, but are out there]

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Quote:
Originally Posted by N2DLX View Post
I disagree with their interpretation of DSL as being interconnected. I'd say dial-up is a bit more nebulous, but also not quite "interconnected" in the way the rules are meant to prohibit.

The idea isn't to prevent linking between repeaters, it was to prevent a phone line from being hooked up to the repeater (i.e. an autopatch) where an unlicensed user could dial the phone number (intentionally or unintentionally) and begin making transmissions on the GMRS side. This is the reason for telephone interconnection being banned.

When you use DSL, you're using the phone line but your DSL modem is sending a digital signal on the phone line concurrent with any analog phone traffic. The phone company at the office end demodulates the signal and patches you into the Internet via their fiber trunks. At no point can someone dial your phone number and gain access to the repeater.

When you use dial-up it's a similar story except you're using the analog phone line to dial the remote office and send the data stream over the normal audio path. So yes, you're making a phone call over the phone line but someone can't just ring your phone number and gain access to the repeater. So even this, technically, should be allowed. I wouldn't test the FCC on it, but for technical reasons it should be permissible.

Their point about VoIP is spot-on though. A VoIP system like we use with Asterisk and app_rpt is basically a private PBX system. You're making phone calls between internal extensions, not connected to the Public Switched Telephone Network. There's no phone number for someone to dial, and no way for someone who isn't authenticated in the system from being able to activate a repeater. By restricting to GMRS licensees only (and keeping Ham operators off of the network), there is controlled access only to licensed individuals which meets the FCC's rules. Now if this VoIP system had a public phone number, it would be considered interconnected and would be in violation of the FCC rules. Again, someone could just ring that number and begin transmitting on a licensed service, which is what this aims to prevent in the first place.
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