Seeking User Comments on 25W to 50W GMRS Mobile Radios

[K4EET]

Hi Bob @AK9R and thanks for the questions. It appears, but like I said “contacting the FCC is probably needed here,” GMRS type accepted radios from the old Part 95 (not Part 95E) do not show up when I search globally for radios under Rule Parts 95 or 95E with “Exact Match” unchecked in the OET EAS. Out of 489 authorizations found, Bendix King, Kenwood, Motorola, etc. do not appear anywhere in the listing.

Now I may be doing something wrong in this “global search” but I would think @prcguy’s BK radio from Post #39 would appear in the listing like Midland’s MXT-500 does. I do not have any FCC ID’s to specifically search for or cite. Perhaps @mmckenna and/or @prcguy will chime in with a search for their specific radio with results from the OET EAS. What a rabbit hole this has become. 😂

 

[prcguy]

Hi Bob @AK9R and thanks for the questions. It appears, but like I said “contacting the FCC is probably needed here,” GMRS type accepted radios from the old Part 95 (not Part 95E) do not show up when I search globally for radios under Rule Parts 95 or 95E with “Exact Match” unchecked in the OET EAS. Out of 489 authorizations found, Bendix King, Kenwood, Motorola, etc. do not appear anywhere in the listing.

Now I may be doing something wrong in this “global search” but I would think @prcguy’s BK radio from Post #39 would appear in the listing like Midland’s MXT-500 does. I do not have any FCC ID’s to specifically search for or cite. Perhaps @mmckenna and/or @prcguy will chime in with a search for their specific radio with results from the OET EAS. What a rabbit hole this has become. 😂View attachment 185467View attachment 185468

Bendix King EMV4990A FCC ID K95 LT30003

Appears to be FCC part 22, 74 and 90, I don't find part 95.

 

[K4EET]

Bendix King EMV4990A FCC ID K95L T30003

Appears to be FCC part 22, 74 and 90, I don't find part 95.

Thanks for the comment. And to be honest, although the Midland MXT500 appears to be the logical choice, my gut feeling is that I should not buy it. This is sooooooo frustrating that I’m actually upset 😠 over the rules versus product availability. No wonder some people “just do it.” Trying to be legal is truly a pain in the backside!

 

[mmckenna]

I do not have any FCC ID’s to specifically search for or cite. Perhaps @mmckenna and/or @prcguy will chime in with a search for their specific radio with results from the OET EAS. What a rabbit hole this has become. 😂

Here's the Kenwood TK-8180 in the 30 watt/450-520MHz model:

FCC - OET TCB Form 731 Grant of Equipment Authorization

It shows approval under FCC Rules Part 95A (as well as others).

Subpart A is "General Rules for the Personal Radio Services".

If you look at 95.355 under Part A, it says:

Revoked or withdrawn certification. In the event that the FCC revokes or withdraws a grant of equipment certification for a type of Personal Radio Service transmitter, existing transmitters already in service may continue to be operated unless and until the FCC determines otherwise and gives Public Notice of that decision.​

To me, that means that once the FCC puts their approval on the radio, it's good to go -unless- the specifically revoke said approval. The link to the Type Approval document for the radio is still showing on the FCC page and I would expect the FCC to indicate it had been revoked. I think the only time I've ever seen them revoke type acceptance was with some of the CCR's that had falsified test documents.
Since 95A cover ALL the personal radios services, I'd take it to mean that The Kenwood TK-8180 having approval for Part 95A and it covering GMRS, and all it's specs for that model falling inside the rules for GMRS (power, frequency, antenna, band width,etc), it would be good to go.
To make things more complicated, If you dive into the Part 95, Subpart E section, you'll see this:

§ 95.1761 GMRS transmitter certification.​

(a) Each GMRS transmitter (a transmitter that operates or is intended to operate in the GMRS) must be certified in accordance with this subpart and part 2 of this chapter.​

​

This says "Must be certified in accordance with this SUBPART". This subpart is E, not A.

So, it would seem like the rules have changed. We know that happened in the past and things have been juggled. I think that would mean that under -current- rules, the TK-8180 might not receive GMRS approval. But it DOES currently have Part 95A approval from under the old rules.

Expecting the FCC to go back through every radio ever certified to update it after a rule change would be expecting a lot.

This really seems like something where the rules have changed (we know that happened) -after- the radio received it's approval. Kenwood is not going to go through the expense to recertify the radio under the updated rule structure for an EOL'd radio to satisfy a fringe group of people buying used radios off e-bay. FCC doesn't seem concerned enough to void the approval for Part 95A on this radio.


I think this squarely falls into the "bureaucracy black hole" of things that will never be addressed. And I doubt the people that answer the 800 number at the FCC are going to be able to resolve it. This is probably a question that would need to go directly to the OET and hope that got to a knowledgeable engineer/legal expert that was willing to take the time to research the question and provide a binding answer.
I am not going to hold my breath on that.

 

[mmckenna]

Want to go down another rabbit hole?

§ 95.335 Operation of non-certified transmitters prohibited.​

Except as provided in paragraph (a) of this section, no person shall operate a transmitter in any Personal Radio Service unless it is a certified transmitter; that is, a transmitter of a type which has obtained a grant of equipment certification for that service, pursuant to part 2, subpart J of this chapter. Use of a transmitter that is not FCC-certified voids the user's authority to operate that station. See sections 302(a), (b), and (e) of the Communications Act (47 U.S.C. 302(a), (b), and (e)).​

​

(a) Exceptions. Under certain exceptions, non-certified Personal Radio Service transmitters, or transmitters certified for use in the land mobile radio services may be operated. Any such exceptions applicable to stations in a Personal Radio Service are set forth in the subpart governing that specific service. See e.g., §§ 95.735 and 95.1735.​

​

Trouble is, 95.735 -only- applies to the Radio Control Radio Service, and 95.1735 just doesn't exist at all.

So, claims of Part 90 radios being OK, does not jive with the -current- rules.

To expand on my previous post:
If you follow the part 2, subpart J of this chapter, you'll get to this regarding revocation of approval:

The Commission may withdraw any equipment authorization in the event of changes in its technical standards. The procedure to be followed will be set forth in the order promulgating such new technical standards (after appropriate rulemaking proceedings) and will provide a suitable amortization period for equipment in hands of users and in the manufacturing process.​

 

[mmckenna]

So, I have a Kenwood TK-3180 portable, 450-520MHz. It has Part 95A approval. It's programmed with GMRS channels correctly per the specifications laid out in the rules. The radio has not been modified in any way.

I do my absolute best to follow the FCC rules. I have 3 separate FCC licenses, one that applies to my job, and I'd like to keep them.
I have no qualms about using the TK-3180 on GMRS.

I would not use a hacked amateur radio.

 

[prcguy]

Want to go down another rabbit hole?

§ 95.335 Operation of non-certified transmitters prohibited.​

Except as provided in paragraph (a) of this section, no person shall operate a transmitter in any Personal Radio Service unless it is a certified transmitter; that is, a transmitter of a type which has obtained a grant of equipment certification for that service, pursuant to part 2, subpart J of this chapter. Use of a transmitter that is not FCC-certified voids the user's authority to operate that station. See sections 302(a), (b), and (e) of the Communications Act (47 U.S.C. 302(a), (b), and (e)).​

​

(a) Exceptions. Under certain exceptions, non-certified Personal Radio Service transmitters, or transmitters certified for use in the land mobile radio services may be operated. Any such exceptions applicable to stations in a Personal Radio Service are set forth in the subpart governing that specific service. See e.g., §§ 95.735 and 95.1735.​

​

Trouble is, 95.735 -only- applies to the Radio Control Radio Service, and 95.1735 just doesn't exist at all.

So, claims of Part 90 radios being OK, does not jive with the -current- rules.

To expand on my previous post:
If you follow the part 2, subpart J of this chapter, you'll get to this regarding revocation of approval:

The Commission may withdraw any equipment authorization in the event of changes in its technical standards. The procedure to be followed will be set forth in the order promulgating such new technical standards (after appropriate rulemaking proceedings) and will provide a suitable amortization period for equipment in hands of users and in the manufacturing process.​

At one time the rules specifically mentioned the use of Part 90 radios were ok on GMRS. I would bet those radios would be grandfathered under the current rules, otherwise the FCC would need to make public notice and give a grace period for users before making them illegal.

 

[mmckenna]

At one time the rules specifically mentioned the use of Part 90 radios were ok on GMRS. I would bet those radios would be grandfathered under the current rules, otherwise the FCC would need to make public notice and give a grace period for users before making them illegal.

Yep, the waters be muddy.

 

[K4EET]

Hi @mmckenna and I really appreciate your time and efforts put into coming up with the three above posts. That was the best analysis of the printed rules and regulations that I could have ever asked for. Definitely more than I would have ever expected.

Whenever you retire, you should get on the FCC’s payroll. You would be a great asset to them. If you were to pass the Bar Exam, you would also make a great lawyer. Maybe go for both!

I like your rationale and it does make a lot of sense.

I do my absolute best to follow the FCC rules. I have 3 separate FCC licenses, one that applies to my job, and I'd like to keep them.

I agree with you on that quote as well. And after reading your posts, I do see where the Kenwood TK-3180 is a good choice as a GMRS transceiver. I am definitely not a Kenwood engineering tech but I will look into what it would take to be able to correctly program the Kenwood TK-3180, both equipment-wise and knowledge-wise. I have to admit, I would much prefer a Kenwood or Motorola radio over the Midland radio.

Not sure if I’ll ask the FCC for clarification on this subject. It is obviously 🙄 a complex question surrounded by a lot of quagmire. I agree with you where you say:

This is probably a question that would need to go directly to the OET and hope that got to a knowledgeable engineer/legal expert that was willing to take the time to research the question and provide a binding answer.

I don’t think I have the clout nor the reason for the FCC to justify the time to make a ruling on this topic. It is not a simple answer based on the current CFR. Simplification of the regulations would go a long way in helping the GMRS user make sound decisions on their equipment choices.

It took me 90 minutes to draft this reply. I obviously no longer have what it takes to be an efficient engineer. This darn illness of mine is really messing up my grey matter. Not to mention what trying to understand the FCC’s Rules and Regulations is doing to me. Have I mentioned a rabbit hole? 😂

 

[mmckenna]

Maybe go for both!

Thanks, but after 32 years (so far) of working in the public sector, I'm looking forward to not working in the public sector.

but I will look into what it would take to be able to correctly program the Kenwood TK-3180, both equipment-wise and knowledge-wise. I have to admit, I would much prefer a Kenwood or Motorola radio over the Midland radio.

KPG-89 is probably one of the easier softwares to learn. It is intuitively laid out and has good help files.
If I had to train a new person how to program radios, I'd probably start with KPG-89 as the first step.

I don’t think I have the clout nor the reason for the FCC to justify the time to make a ruling on this topic. It is not a simple answer based on the current CFR. Simplification of the regulations would go a long way in helping the GMRS user make sound decisions on their equipment choices.

I agree. But I suspect it would be hard to cover the "previously type accepted" equipment question. The goal would be to make it easier to understand, and that subject is getting off into the deep weeds, as we've seen in this thread. Not sure there is a good/easy answer.

I think that while the rules are not very clear, we should try to see the overall intent of the type certification process.
The goal is to approve radios that meet the technical requirements of the radio service so someone who is not in possession of their own EMI/RFI testing lab can determine if a radio meets the necessary requirements and will not (hopefully) cause harmful interference to other users.

The type acceptance thing works well on the consumer side because anyone can walk into a Target store and buy an FRS radio and walk out without risking causing interference to the local police department. As we've seen with the CCR's coming pre-programmed with frequencies out of the box, radios sold to consumers sometimes end up causing problems. Fixing those problems can take a lot of time, money and effort (been there, done that).


This has been a good thread with some mostly common sense discussion. I'm not an expert at this stuff, just (usually) pretty good at reading and learning. Trying to look at all this from the many angles is a challenge. Everyone is going to have their own take on it, and that's fine with me. But remembering that the rules are there so we can all share a limited resource is important. Sharing means that we all have to get along, even if that's inconvenient sometimes.

 

[Coffeemug]

Hi @Coffeemug and thanks for your comment. Not entirely off-topic since the theme of my thread is to be compliant with the FCC rules and regulations. As I am finding out, in the GMRS area, compliance is easier said than done. There are so few Part 95E radios out there that I can understand how easy it would be to just program any “unlocked” radio for GMRS and have at it.

One thing that I’ve not gotten an answer to, and contacting the FCC is probably needed here, “are previously type accepted Part 95 radios that are no longer in the FCC’s database still legal to use for GMRS?” I probably know what the FCC’s answer will be, further decreasing the number of type accepted radios in the GMRS world. It is getting darker the further I go down this rabbit hole…

Thanks for your service to your community. Also, if you are a Military Veteran Thank you! I'm sure that was no easy task, especially for those individuals who served in Vietnam, because they suffer worse when or if they came home.

Thank You!

 

[K4EET]

@mmckenna, @prcguy, @Coffeemug, and everybody else who has been a part of this thread so far (including those that will chime in later on, if any), I want to say that your contributions to the discussions have been greatly appreciated! I have learned a lot reading all of your comments. Hopefully this thread will be helpful to future readers that are interested in the GMRS section of radio communications. 😃

 

[mmckenna]

@mmckenna, @prcguy, @Coffeemug, and everybody else who has been a part of this thread so far (including those that will chime in later on, if any), I want to say that your contributions to the discussions have been greatly appreciated!

Well, just keep in mind that you are getting exactly what you paid for.

But seriously, I there has been some good info shared by all.

 

[Firebell2110]

I remember one fella from years ago, Russ Stafford W3CH (SK). Russ also had a GMRS call, which I don't remember Here was an individual who preached on the importance of working in the confines of the FCC Rules and Regulations. However, I knew that Russ didn't always practice what he preached. Russ used to be the communications coordinator for the Delaware Valley Multiple Sclerosis Society. Each year the MS 150 City to Shore, Russ would insist that no Radio Volunteer would use Q-codes or ten codes, because according to him, violates FCC Rs & Rs. Besides, Russ strictly forbids the use opened / modified radios. Of course, Russ was using a Radio. I can see the reasons to use plain langue, and I can also see the reasons for using typed accepted equipment. But I can't understand why he didn't comply to his own rules.
Don't get me wrong, Russ Stafford was stand up person, even though he was do as I say and not as I do.
Just want to add a story from my years of being licensed in both Amateur Radio and GMRS. Sorry if I seemed to stray off the topic, because I wasn't really trying to. I just didn't really feel like I could make sense just my experience on casual rag chewing, whether Amateur Radio or GMRS..

like I said better off with MURS!!!!!!

 

[hill]

People can keep get TK-3180 programmed. I am not too far away.

With it be able to be programmed with all repeater pairs/simplex channel and than can use OST to select PL tone you require. The OST list can have all the standard tones in it.

 

[K4EET]

like I said better off with MURS!!!!!!

Why do you say “better off with MURS”?

 

[K9KLC]

like I said better off with MURS!!!!!!

I'm curious to the reasoning behind this statement also. Frankly the same rabbit hole exists with Murs as far as type acceptance and other than no "actual" license, I've done way better on GMRS (when I do that stuff) than anything Murs.

 

[K9KLC]

Why do you say “better off with MURS”?

Why indeed???

 

[hill]

like I said better off with MURS!!!!!!

For HT radio to radio simplex maybe.

GMRS is way more powerful of radio service with the ability to use repeaters. Plus being able to do 50 watt simplex between mobile/base radios on some of channels.

Around this way are GMRS repeaters cover over 30 miles in each direction with a mobiles and no real way for MURS to compete with this.

 

[Coffeemug]

like I said better off with MURS!!!!!!

Whatever your needs are, that's what you use. I can't really say which two-way radio service is best, because each service has its pros and cons. I'm sure there are individuals who will agree me, and others that disagree with me, and maybe say that I don't know anything when comes to radio communication.
Hey, let them say what they want, because I know more than some individuals think.

Have Good Day!