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Part 95 rule changes. Finally.

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RFI-EMI-GUY

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Its quite possible I'm reading into it /far/ more then necessary, I do admit. However, the new wording of 95.1749 is perhaps still confusing. Now correct me if I'm wrong, but, the rule literally states "for the sole purpose of operation by remote control", AFAIK the FCC defines "remote control" as: "Under remote control, the licensee has implemented a means by which the repeater’s control operator(s) can monitor and control its operation by some form of control link from one or more distant locations."

This says nothing about rebroadcast of voice or other transmissions, which would /seem/ to say that 95.1749 stipulates that using POTS or any network connection for linking where the sole purpose is /control/ is okay, but because of the lack of wording, may or may not mean that use of that link for rebroadcast of voice is legal. Which still leaves linking for the purpose of transmission rebroadcast in this legal-gray-limbo area.

For it (linking) to NOT be legal, there would need to be specific language prohibiting it.

Historically, remote control of a base station or repeater station has been between a control point like dispatch office and the station. In the early days this was done with DC control current over a leased voice line. This later evolved to tone remote control over leased circuits and private microwave circuits. Then later concepts like satellite receiver voting and multicast and simulcast techniques developed. Now we have IP based circuits. None of these iterations of the concept of remote control received any special attention in Part 90. Why expect to see it here? It is all remote control.
 

AA4TX

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Concerning the 462.xxxx interstitial channels. Isn’t the following proposed paragraph in effect narrow banding previously wide band interstitial channels for GMRS?

Proposed Rules:
§ 95.1775(b) 462 MHz interstitial channels. The peak frequency deviation for emissions to be transmitted on the 462 MHz interstitial channels must not exceed ± 2.5 kHz.

Current Rules:
§95.637 (a) A GMRS transmitter that transmits emission types F1D, G1D, or G3E must not exceed a peak frequency deviation of plus or minus 5 kHz. A GMRS transmitter that transmits emission type F3E must not exceed a peak frequency deviation of plus or minus 5 kHz.

This seems to be in direct conflict with this statement:
"With the use of interstitial channels already in place and an established base of 25 kHz equipment held by individuals, any orderly switch to 12.5 kHz channels would be difficult, costly in lost equipment investments, and would not result in a material increase in spectrum efficiency. Consequently, we find that the record does not support a transition to a narrowbanding requirement for GMRS, and so we decline to establish such a requirement at this time. "
 
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jonwienke

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The interstitial channels have always been narrowband, even when used by GMRS. They are simply applying the same rules to the 467MHz interstitials as the 462MHz interstitials.
 

amphibian

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Linking is remote control, you are reading more into it then is needed. I didn't see any language that says linking repeaters is not allowed. Pressing a button to talk is not automatic.

As far as the comment above "Possible DMR and other newer technology may be in the works also" no that was denied as I was one of the people that petitioned it. It was clearly written as shown below.

We also note that seven parties filed petitions for rule making requesting that we allow a time division multiple access (TDMA) modulation technique (i.e 7K60FXE 2 slot DMR TDMA) on GMRS frequencies to facilitate digital emissions and narrow banding to increase capacity on GMRS channels.

We deny these petitions. As explained above, the ability of GMRS licensees to communicate with each other is essential for the “listen before talk” etiquette, self-policing, and emergency calls that occur on these shared channels, and introducing a new modulation technique that is inconsistent with existing equipment would complicate the shared environment of GMRS channels.

Read it again....they only denied "TDMA & Narrowbanding" together.... Request for narrowbanding was turned down...and thank God for that, the other request was for TDMA AND narrowbanding and since they turned down narrowbanding they couldn't approve both TDMA and narrowbanding....

Doesn't mean that a waiver couldn't be requested and approved on doing other forms of digital technologies...

It does leave room for approval in the very near future if enough request are submitted and justification is there to support it....

William R Howell,
GMRS License Call Sign: WQYX489
CEO, USGMRS Repeater & Users Group Association
USGMRS Repeater & Users Group Association (usgmrsgroup.club)
FB Group Page: USGMRS Repeater & Users Group
 

AA4TX

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The interstitial channels have always been narrowband, even when used by GMRS. They are simply applying the same rules to the 467MHz interstitials as the 462MHz interstitials.

Thanks.
Can you point me to the current rule in Part 95 that says the 462.xxxx interstitial channels are narrow band for GMRS? I must be missing it.
 

Dantian

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Linking for purposes of control is permitted, but that would be linking the repeater to its control point and not linking audio between repeaters. 95.1733(a)(8). Receiver voting is not linking repeaters, it's linking remote receivers to a repeater. Networks of linked repeaters in GMRS? Can't see how that's allowed.
 

amphibian

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Linking for purposes of control is permitted, but that would be linking the repeater to its control point and not linking audio between repeaters. 95.1733(a)(8). Receiver voting is not linking repeaters, it's linking remote receivers to a repeater. Networks of linked repeaters in GMRS? Can't see how that's allowed.

I guess we are going to start hashing this out again and again and again....

FCC stated on it before in a letter that is was legal to do....

I have not seen anything in this NPRM that stated that it was not allowed or prohibited...

If so, then show me where it states that it is prohibited and I will stand to be corrected.....



William R Howell,
GMRS License Call Sign: WQYX489
CEO, USGMRS Repeater & Users Group Association
USGMRS Repeater & Users Group Association (usgmrsgroup.club)
FB Group Page: USGMRS Repeater & Users Group
 

Dantian

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Well I think 95.1733 is pretty clear on that subject, as is 95.1749. From looking at this user group website, it would appear that the group is aiming to connect repeaters.

If you post that FCC letter it would be constructive. But it's well established that licensees can't rely on informal FCC staff interpretations.
 

RFI-EMI-GUY

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Concerning the 462.xxxx interstitial channels. Isn’t the following proposed paragraph in effect narrow banding previously wide band interstitial channels for GMRS?

Proposed Rules:
§ 95.1775(b) 462 MHz interstitial channels. The peak frequency deviation for emissions to be transmitted on the 462 MHz interstitial channels must not exceed ± 2.5 kHz.

Current Rules:
§95.637 (a) A GMRS transmitter that transmits emission types F1D, G1D, or G3E must not exceed a peak frequency deviation of plus or minus 5 kHz. A GMRS transmitter that transmits emission type F3E must not exceed a peak frequency deviation of plus or minus 5 kHz.

This seems to be in direct conflict with this statement:
"With the use of interstitial channels already in place and an established base of 25 kHz equipment held by individuals, any orderly switch to 12.5 kHz channels would be difficult, costly in lost equipment investments, and would not result in a material increase in spectrum efficiency. Consequently, we find that the record does not support a transition to a narrowbanding requirement for GMRS, and so we decline to establish such a requirement at this time. "


I agree; I think that rule conflict should be formally addressed since many existing GMRS radios are incapable of switching to NB. I think the FCC made an inadvertent error.
 

zikada

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Well I think 95.1733 is pretty clear on that subject, as is 95.1749. From looking at this user group website, it would appear that the group is aiming to connect repeaters.

If you post that FCC letter it would be constructive. But it's well established that licensees can't rely on informal FCC staff interpretations.

Where is a wireline control link defined in the Part 95 rules?
 

Dantian

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Where is a wireline control link defined in the Part 95 rules?

They probably should have defined it, but the definitions for operate and control point, as well as the prohibition on connecting to "other networks" should cover it.
 

N2DLX

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They probably should have defined it, but the definitions for operate and control point, as well as the prohibition on connecting to "other networks" should cover it.

There is no prohibition on connecting to other networks for GMRS. It specifically states that connection to the Public Switched Network and other networks is allowed. It prohibits telephone connections (i.e. autopatch) as it always has. The language is much clearer now.
 

coryb27

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Read it again....they only denied "TDMA & Narrowbanding" together.... Request for narrowbanding was turned down...and thank God for that, the other request was for TDMA AND narrowbanding and since they turned down narrowbanding they couldn't approve both TDMA and narrowbanding....

Doesn't mean that a waiver couldn't be requested and approved on doing other forms of digital technologies...

It does leave room for approval in the very near future if enough request are submitted and justification is there to support it....

William R Howell,
GMRS License Call Sign:
CEO, USGMRS Repeater & Users Group Association
USGMRS Repeater & Users Group Association (usgmrsgroup.club)
FB Group Page: USGMRS Repeater & Users Group

We deny these petitions. As explained above, the ability of GMRS licensees to communicate with each other is essential for the “listen before talk” etiquette, self-policing, and emergency calls that occur on these shared channels, and introducing a new modulation technique that is inconsistent with existing equipment would complicate the shared environment of GMRS channels.

TDMA is DMR and that is narrow band. This 12.5 kHz of bandwidth is then fractured using TDMA to create two time slots. I know what I petitioned for and unlike you hold several licensed part 90 frequency's that I run an IP site connect DMR system on. I did not start doing this stuff 2 months ago like yourself.
 
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Dantian

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There is no prohibition on connecting to other networks for GMRS. It specifically states that connection to the Public Switched Network and other networks is allowed

It is allowed for the sole purpose of operation by remote control. Remote control is for operation, that is, causing the transmitter to transmit or not transmit. That does not include audio, as is also clear from 95.1733 and 95.303. The concept of control of a station is remarkably consistent throughout the FCC rules.
 
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gatekeep

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There is no prohibition on connecting to other networks for GMRS. It specifically states that connection to the Public Switched Network and other networks is allowed. It prohibits telephone connections (i.e. autopatch) as it always has. The language is much clearer now.

The original rule no longer appears in the rules. What has appeared in its place is whats referred to as 95.1749. Which reads:

$ 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.

As written this is taken to include the content of the original rule and adds extra language.

I can't speak for others, but perhaps my definition of 'remote control' is incorrect. I've always assumed that 'remote control' talks about the remote ability to control and monitor the repeater, base or fixed station's ability to transmit.
 

RFI-EMI-GUY

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The original rule no longer appears in the rules. What has appeared in its place is whats referred to as 95.1749. Which reads:



As written this is taken to include the content of the original rule and adds extra language.

I can't speak for others, but perhaps my definition of 'remote control' is incorrect. I've always assumed that 'remote control' talks about the remote ability to control and monitor the repeater, base or fixed station's ability to transmit.

§ 95.1745 GMRS remote control.
Notwithstanding the prohibition in § 95.345,
GMRS repeater, base and fixed stations may be
operated by remote control.

REMOTE CONTROL AS DESCRIBED IN PART 90:


§ 90.461 Direct and remote control of transmitters.

(a)In general. Radio transmitters may be operated and controlled directly (as when the operating position for the transmitter and the transmitter being operated are at the same location), or remotely (as when the transmitter being operated and the position from which it is being operated are at different locations).

(b)Control of transmitters at remote locations. Radio transmitters at remote locations may be operated and controlled through the use of wire line or radio links; or through dial-up circuits, as provided in paragraph (c) of this section. Such control links or circuits may be either those of the licensee or they may be provided by common carriers authorized by law to furnish such service.

(c)Dial-up circuits. Dial-up circuits may be provided by wire line telephone companies under appropriate tariffs, and they may be used by licensees for purposes of transmitter control, provided:

(1) The dial-up circuits serve only to link licensed transmitter control points and the transmitters being controlled.

(2) The dial-up circuits are so designed that the transmitters being controlled cannot be operated from any fixed position other than the licensed control points for those transmitters.

(3) Equipment used to provide the transmitter/dial-up-circuit interface is designed to preclude associated mobile units of the licensee from reaching any point(s) served by the wire line telephone facilities other than the control point(s) of the station(s) controlled.

(4) Any direct electrical connection to the telephone network shall comply with applicable tariffs and with part 68 of the Commission's Rules (See § 90.5(j)).

(5) Interconnection, within the meaning of §§ 90.7 and 90.477 through 90.483, may not take place at a control point which connects to its associated transmitter(s) through dial-up circuits; nor may such dial-up transmitter control circuits be used in conjunction with (or shared by) interconnection equipment.
[ 43 FR 54791, Nov. 22, 1978, as amended at 44 FR 67124, Nov. 23, 1979; 60 FR 50123, Sept. 28, 1995]
 
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gatekeep

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@RFI-EMI-GUI I understand that, I perhaps think that the hangup on this particular topic/argument is the definition of what exactly is meant behind 'remote control'.
 

RFI-EMI-GUY

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It is allowed for the sole purpose of operation by remote control. Remote control is for operation, that is, causing the transmitter to transmit or not transmit. That does not include audio, as is also clear from 95.1733 and 95.303. The concept of control of a station is remarkably consistent throughout the FCC rules.

You could perhaps link repeaters by non-wireline means -- such as by satellite or direct RF links -- as long as no control signals were passed over that link, and conversely no audio passed over the control links.

The proposed rules are much clearer and favorable in that there is no such distinction between audio and control signals. It is simply "operation by remote control ".
 

RFI-EMI-GUY

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@RFI-EMI-GUI I understand that, I perhaps think that the hangup on this particular topic/argument is the definition of what exactly is meant behind 'remote control'.

Read what I posted from part 90. there should be absolutely no confusion about operation by remote control. If the FCC wished to prohibit such operation as linking they would have done so in the rewrite.
 

gatekeep

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The proposed rules are much clearer and favorable in that there is no such distinction between audio and control signals. It is simply "operation by remote control ".

Read what I posted from part 90. there should be absolutely no confusion about operation by remote control. If the FCC wished to prohibit such operation as linking they would have done so in the rewrite.

Based on your descriptions here then, I would agree with the rest in saying that, in this instance they aren't prohibiting linking in any way shape or form, and it is actually a fully legal operation under 95.1749.
 
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