FCC Notice of Violation for NGGMRS’s linked repeater system

[RFI-EMI-GUY]

From Part 97:

(39) Remote control. The use of a control operator who indirectly manipulates the operating adjustments in the station through a control link to achieve compliance with the FCC Rules.

Nowhere in that definition does it talk about content.

OK well, that is part 97. Some similarity, but the history is the context of this entire argument.

There was at one time a requirement for a control operator for Part 97 as well as for GMRS in the early days, when repeaters were first becoming a thing. The Part 97 control operator used (an out of band) wireline or a frequency above 2 meters (The repeater band of the time). GMRS was saddled with a similar requirement, but because all they had were the 8 UHF pairs, they were permitted to use wireline (dial up) to turn off and on a repeater. Later for both services automated control of repeaters was permitted and the control operator requirement was eliminated.

95.1733 (8) was a rule born of the GMRS control operator requirement and became a scriveners error in the rules because the rule sections it was previously linked to were eliminated and finally the rule stood on its own with no purpose. I notified FCC in the NPRM of this conflict and although I got named in a footnote, they kicked the can down the road because of "insufficient time to research." I have done a bit of that research in reading older rules.

What we are seeing is the result/demise of, an important agency where the institutional knowledge has died, retired, or been fired by Elon. What has happened is that rather have the important research and discussion 9 years ago, the FCC has written bad rules that can be interpreted however one wishes.

My interpretation? Great, in 2017 FCC opened up the GMRS for linking by internet and some goofball forgot to remove 95.1733 (8) a deprecated rule that conflicts with the new direction.

9 years have gone by and it has festered without reasonable discussion on what guardrails could be put in place.

Guardrails I suggest:

Linked Repeaters always secondary to local repeaters, linked repeaters must provide local repeat option as primary operation. Example Tone A is local repeat mode only, Tone B is linked. Users call each other locally and use linked only as needed. No need to light up the planet.

Linked repeaters must monitor for other co-channel activity on their INPUT frequency. A carrier squelch used to sense a co-channel mobile and inhibit linked traffic for 30 seconds. Simple to implement timer logic. Sometimes integral to commercial repeaters.

Maximum of four Linked Repeater pairs in a linked sub-system and of those any two that may overlap, can only overlap 20% of the adjacent area between repeaters.

Larger systems of two or more sub-systems may only link sub-systems in times of emergency.

No system or sub-system shall be linked across state lines without a showing of need demonstrated to FCC.

 

[RFI-EMI-GUY]

associations installing high profile repeaters on every pair in an area then requiring membership dues to use their repeaters has been a pet peeve of mine

I'm too lazy to look this up but I remember something about prohibiting leasing GRMS repeater air time. If that is true and the linked system in question is charging for use then that would be another problem.

There are GMRS users that complain there is no local infrastructure and that the simplex range is ****ty. Putting up high profile repeaters is expensive and in some cases impossible because towers are now owned by huge wall street backed firms.

This leaves only a few options, dozens of ****ty back yard repeaters or pay dues for a high profile repeater on a co-op arrangement (perfectly legal, read the GMRS rules). A third option is linking those ****ty backyard repeaters to overcome terrain. NGGMRS charging dues for their high profile repeaters is perfectly legal. Linking, I will leave that to the lawyers.

By the way, back in 1970's in Chicago, a high profile GMRS group ringed the suburbs with Spectra Tac receivers connected via leased wireline and shoe strings. Nobody ever complained and it certainly could have been a violation of 95.1733 (8) at the time. If one were so very anal.

 

[mmckenna]

My interpretation? Great, in 2017 FCC opened up the GMRS for linking by internet and some goofball forgot to remove 95.1733 (8) a deprecated rule that conflicts with the new direction.

If it comes down to the FCC screwed up and NGGMRS is in the right, the FCC will just follow up with a NPRM to fix it. Those that care will submit comments for or against. I suspect that most that understand will be against it. If I was the betting kind, the NPRM would result in fixed FCC rules that align with this notice of violation. But, I'm not the betting kind, and ultimately I probably don't care enough to lose any sleep over this.

FCC knows what the rules say and I'm sure they've got a plan here.

But like I said, fun to sit on the sidelines and watch….

Maximum of four Linked Repeater pairs in a linked sub-system and of those any two that may overlap, can only overlap 20% of the adjacent area between repeaters.

I think it needs to go farther.
If someone wants to run a linked system, they -must- use simulcast. No exceptions. If they can charge users, afford IP linking, and afford site leases, they can afford some simulcast hardware. It's not rocket surgery, and it's done all over the place. GMRS can join the 21st century if they want to operate systems like this.

But, probably too difficult to enforce.

8 pairs, repeater output shared with simplex/FRS, GMRS isn't the place for this kind of stuff. I agree with the FCC's take on this, keep GMRS a radio service for local communications. Lots of other spectrum to set up linked repeaters. I'm having a hard time understanding the need for wide area linked personal radio services. I doubt these repeaters are built/linked/powered in such a way to make them reliable in a true disaster, and they'd likely be overwhelmed with traffic anyway.

PTToC is going to be cheaper for most people and fit all of their actual/realistic needs. For those that want to play ham radio or fulfill their whacker dreams by carrying around a CCR look alike of a APX8000, they can do that without the linked system.

 

[MTS2000des]

This NAL merely reinforced what the FCC publicly clarified on their website regarding GMRS operations: linked repeaters are not compatible with the basis and purpose of GMRS for short range (1-25 miles) LISTEN before TALK and SHARED basis. Hard to do that when a bunch of linked high power chatterboxes spread out over hundreds of square miles simulcasting two or three sad hams who are two miles apart being heard in four states. Illustrates perfectly why this is piggish and inconsiderate of others who have repeaters and follow the rules. It was about damn time, now the enforcement bureau has spoken. Officially at that. What shall the Hobbit respond with?

 

[Hans13]

Of course they are going to lawyer up. This puts their SMR business at risk. No one is going to pay their insane prices for local repeater area coverage.

Greed AND ego, IMHO.

 

[Hans13]

​

§ 95.327 Restricted operation.​

The FCC may deny or restrict the use by any operator(s) of any specified channel(s) in a specified geographic area if, in the judgment of the FCC, such use is not in the public interest. Furthermore, the FCC may restrict the use by any particular operator(s) of any channel as to geographical area of operation, transmitting power, or other operating conditions.

 

[Hans13]

I'm too lazy to look this up but I remember something about prohibiting leasing GRMS repeater air time. If that is true and the linked system in question is charging for use then that would be another problem.

Non-profit situation and sharing arrangements must be kept as part of the station records.

§ 95.1705 Individual licenses required; eligibility; who may operate; cooperative use.
...
f
...

(3) A station may be shared only:

(i) Without charge;

(ii) On a non-profit basis, with contributions to capital and operating expenses including the cost of mobile stations and paging receivers prorated equitably among all participants; or

(iii) On a reciprocal basis, i.e., use of one licensee's stations for the use of another licensee's stations without charge for either capital or operating expenses.

(4) All sharing arrangements must be conducted in accordance with a written agreement to be kept as part of the station records.

 

[Hans13]

Pay me $100 a year and I'll give you unlimited "Tactical Unit Numbers" and access to EVERY open GMRS repeater in the country.

"Shut up and take my money!"

 

[RFI-EMI-GUY]

Just for reference:

This is the anti-linking mentality. I would be happy to pay $90 a year for such service. Has this guy ever paid a cable bill?

I doubt this guy is gonna put up his own repeater on his $0.24 a day budget.

He needs to get a job and stop complaining about "boomers" or whatever..

 

[Hans13]

This NAL merely reinforced what the FCC publicly clarified on their website regarding GMRS operations: linked repeaters are not compatible with the basis and purpose of GMRS for short range (1-25 miles) LISTEN before TALK and SHARED basis. Hard to do that when a bunch of linked high power chatterboxes spread out over hundreds of square miles simulcasting two or three sad hams who are two miles apart being heard in four states. Illustrates perfectly why this is piggish and inconsiderate of others who have repeaters and follow the rules. It was about damn time, now the enforcement bureau has spoken. Officially at that. What shall the Hobbit respond with?

I agree with you in spirit but I have never been quite so sure that the letter of the regulations clearly prohibit it. I do NOT like it or agree with the practice.

What I posted before as to the FCC's ability in Part 95 to restrict any particular station, geographic location, etc that are deemed by the FCC to be not in the public interest seems to me to be a hammer of last resort that would squash this in favor of the FCC. Prior to a few minutes ago, I don't recall ever noticing that little gem in Part 95.

 

[RFI-EMI-GUY]

Hey what about that Melon Husk guy that has taken over the entire LEO orbital plane with , what 40,000 satellites? He wants $130 a month for internet and I have to buy one of his crummy terminals. I want to put up my own satellite but he has all the spectrum and orbital slots and I am too poor, living in my mommys basement Bwah Bwahh Bwahh!

 

[Hans13]

View attachment 205079

Just for reference:

This is the anti-linking mentality. I would be happy to pay $90 a year for such service. Has this guy ever paid a cable bill?

I doubt this guy is gonna put up his own repeater on his $0.24 a day budget.

He needs to get a job and stop complaining about "boomers" or whatever..

Well, those of us who already had repeaters on the air had interference and complaints from a local pay group that came along years after we were on the air and gobbled up most, if not all, of the pairs on high profile repeaters. When one person paid a lot of money to move his open repeater to the highest profile site in the area (lots of $$$ spent by him), they sqealed like crazy over the use of that one measly pair!

 

[RFI-EMI-GUY]

This NAL merely reinforced what the FCC publicly clarified on their website regarding GMRS operations: linked repeaters are not compatible with the basis and purpose of GMRS for short range (1-25 miles)

There has never been a mileage limit or "short range" definition for GMRS. Anyone with some knowledge of LMR knows that 50 watts and no limitations on antenna height or ERP equates to pretty high performance. Add mountaintops in Georgia and the signals will travel, which is pretty much the entire point of spending money on radios.

 

[Hans13]

Hey what about that Melon Husk guy that has taken over the entire LEO orbital plane with , what 40,000 satellites? He wants $130 a month for internet and I have to buy one of his crummy terminals. I want to put up my own satellite but he has all the spectrum and orbital slots and I am too poor, living in my mommys basement Bwah Bwahh Bwahh!

I think what you are missing from the equation is that the personal radio service regulations and purpose. Cable providers, Musk, and other strawmen aren't actually equivilent. I am still not convinced that the regulations directly allow the FCC to shut down linking and, if it wasn't against the regulations, I was willing to complain when all of the pairs were used up by high profile paid repeaters (linked or not), I respected that it was not against the rules and acknowleged such.

But, that part 95 regulation I posted tonight might be the death of linking because, AFAIK, it basically says that if the FCC can articulate why, in their opinion, something is not in the best interest of the public, they can restrict it. I don't like that broad language but it does seem to be saying that, IMHO.

 

[RFI-EMI-GUY]

Well, those of us who already had repeaters on the air had interference and complaints from a local pay group that came along years after we were on the air and gobbled up most, if not all, of the pairs on high profile repeaters. When one person paid a lot of money to move his open repeater to the highest profile site in the area (lots of $$$ spent by him), they sqealed like crazy over the use of that one measly pair!

The FCC changed the rules years ago to eliminate repeater station licenses. So there is no way to prove incumbency of a particular, center coordinate, area or frequency. I hear a lot of anecdotal stories (of crybabies), but did anyone actually, formally, reach out and try to work or cooperate with NGGMRS or any other "pay group".

 

[Hans13]

There are GMRS users that complain there is no local infrastructure and that the simplex range is ****ty. Putting up high profile repeaters is expensive and in some cases impossible because towers are now owned by huge wall street backed firms.

This leaves only a few options, dozens of ****ty back yard repeaters or pay dues for a high profile repeater on a co-op arrangement (perfectly legal, read the GMRS rules). A third option is linking those ****ty backyard repeaters to overcome terrain. NGGMRS charging dues for their high profile repeaters is perfectly legal. Linking, I will leave that to the lawyers.

By the way, back in 1970's in Chicago, a high profile GMRS group ringed the suburbs with Spectra Tac receivers connected via leased wireline and shoe strings. Nobody ever complained and it certainly could have been a violation of 95.1733 (8) at the time. If one were so very anal.

We still managed to have people put up high profile, open repeaters in our area. It's not cheap but people are still willing to do it there. It sucks when they have to get so much grief from membership clubs that have grabbed every pair with the intention of not leaving room for anyone else. These pair all over-lap there. It's ridiculous and greedy there.

 

[RFI-EMI-GUY]

But, that part 95 regulation I posted tonight might be the death of linking because, AFAIK, it basically says that if the FCC can articulate why, in their opinion, something is not in the best interest of the public, they can restrict it. I don't like that broad language but it does seem to be saying that, IMHO.

The FCC, in the 2017 NPRM if I recall, stated that they were not going to require frequency coordination and expected the GMRS community to work it out. I will bet that there will be hundreds of letters in support of NGGMRS from their members (and others), and a fraction of that amount will be against. I am in favor of linking, but not to the extent that NGGMRS "allegedly" operates.

 

[Hans13]

The FCC changed the rules years ago to eliminate repeater station licenses. So there is no way to prove incumbency of a particular, center coordinate, area or frequency. I hear a lot of anecdotal stories (of crybabies), but did anyone actually, formally, reach out and try to work or cooperate with NGGMRS or any other "pay group".

YES! It was our group that started the membership club. I handed over the email list and roster to them myself because the group seemed to want more organized activities. I tried to warn them gently beforhand. Once positioned with all of the pairs tied up, the group enacted draconian rules and most of the GMRS airwaves fell silent. Anytime any of us open repeaters had traffic, we would get juvenile interference and threats of "their buddy" at the FCC. I even got a contact from their "FCC agent buddy." Lies and garbage.

I have experience with exactly one GMRS membership group. I knew them all personally. It was a total nightmare. They did not want to cooperate... they wanted to DOMINATE the area so everybody had to pay their dues and follow their endless extra rules.

(ETA: I know some of you guys who founded that group are reading this. Shame on you all!)

 

[RFI-EMI-GUY]

We still managed to have people put up high profile, open repeaters in our area. It's not cheap but people are still willing to do it there. It sucks when they have to get so much grief from membership clubs that have grabbed every pair with the intention of not leaving room for anyone else. These pair all over-lap there. It's ridiculous and greedy there.

There are 32 tone codes and a lot more DCS codes. There is really no reason that repeaters cannot co-exist on same channels. If a "club" is linking the entire state and not monitoring the repeater input, then they are doing things wrong. All that can be fixed.

 

[RFI-EMI-GUY]

I have experience with exactly one GMRS membership group. I knew them all personally. It was a total nightmare. They did not want to cooperate... they wanted to DOMINATE the area so everybody had to pay their dues and follow their endless extra rules.

Amateur radio repeater coordination collapsed here in Florida because it was a good old boy network. Nobody could get "permission" to put up a repeater and as a result the leadership got called out and disbanded as a non compliant non profit org by the one guy crazy enough to do so.