As we all have pretty much long established, Part 95 is not very well written and has a bunch of holes in it.
I think the biggest issues (which I'm sure NCGMRS is going to use for their defense) is:
- 95.1733 which specifically prohibits messages conveyed via a wireline to be transmitted but fails to define what a wireline actually is.
- 95.1745 which allows for remote control of a control station or repeater.
- 95.1749 which says network connection for remote control is okay for GMRS.
The reasons I specifically see these as issues...well there is no definition of "wireline" in Part 95 or all of Chapter 1 of Title 47. If you take the Chapter 5 definition of wire communications, it's a point to point copper wire interface and defined similarly to how remote control is defined in Part 95 (that point to point path has to leave the premises to be considered remote operation). Well if the FCC chooses to call a wireline any E&M type interface...that could spell the end of two mobiles strapped together to build a repeater or even integration with external controllers.
However, under the current assumed definition wireline via wire communications, a private microwave network (IP based even) is not a wireline therefore messages conveyed over that interface simply fall under remote control. Hell, Starlink to Starlink....is not wireline network connection or even LTE to LTE because it's crossing that wireless demarcation when it leaves the premises. To even further muddy that, the "Interconnection Prohibited" clause was removed in 2017.
We also now have a unique situation where taking two control stations, one for say a the 700 pair and one for the 625 pair, tying them together via E&M with something like an ACU-1000...we are not conveying messages over wireline and RF, operation is local and/or automatic and we've also interconnected independent repeaters (under automatic operation) without crossing any of the technical restrictions. Of course, the FCC can restrict or limit a geographic area but they haven't specifically defined that area (which is a requirement of 95.327), yet.
Is linking outside of the spirit of the service? I don't believe it is. In fact there is the argument that it may be required to facilitate emergency communications or even to support disaster operations. If I need to interconnect two repeaters to support incident operations (or even training) to allow information to flow between teams and/or IC, that's one thing that should specifically be allowed. As some in this thread may have heard from my SWIC yesterday at APCO, we integrate AUXCOM into ESF-2 and believe that the AUXC is not just limited to amateur radio operators. However, common courtesy is:
- Be as spectrally efficient as nessecary. So if you can accomplish your immedate wide-area needs with voting/simulcast, in order to use a few channels as possible, that's the way to go.
- If you patch something together, break the patch when it is no longer needed.
I honestly think we are coming to the point where the lack of coordination is affecting GMRS and there may need to be some additional language that states something a long the lines of simulcast/voting to fill in a repeater is fine, on demand interconnection is fine, but full time linked systems are not. Even going as far as repeaters need to be listed under locations on our licenses (itinerant operations exempt) with the frequency in use. Then at least it becomes easier to tell, oh that operator is filling in a site for simulcast or attempting to build a wide area network (outside of the "spirit") and we should have a chat with them (as the commission).
