SUBJECT: FCC Help Case HD0000819887 Resolution
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Case Id: HD0000819887
Summary: Rule Clarification
Description: Good afternoon,
A local group I’m a part of has been discussing the legality of APRS (AX.25 digital information) using modulated FM audio over the GMRS service; this is classified as an F2D emission type. APRS generally consists of very short bursts of data conveying messaging, status and location information utilizing the AX.25 data protocol popular with the Amateur Radio Service
We’ve come to believe these transmissions to be allowed on GMRS for the following reasons. We are using the online copy of the Title 47, Part 95 rules found at ecfr.gov.
In reviewing the rules:
95.331 states that only use within the purpose of the personal radio service in question is allowed.
95.1703 states the scope and purpose of GMRS, this definition includes limited data.
95.1731 allows handheld devices to share data consistent with APRS, but it also does not explicitly prohibit non-handheld (ie. mobile) devices from sending such data, or other types of data.
95.1771 lists F2D as an allowed emission type (modulated data using FM)
95.1773 allows data transmissions on all channels except the 467 main channels.
This all seems fairly straight forward thus far; however 95.1787 lists numerous additional restrictions on data transmission, but this section as written seems to apply only to radios seeking Part 95E certification or “…submitted for certification under this subpart…” (ie. a manufacturer submitting a radio for certification).
We’d appreciate some clarification on the following scenarios:
- Does 95.1787 apply to operation or does it only apply to handhelds under going the certification process as the wording states?
- Is externally modulated F2D-emission data such as APRS (using an external modem) allowable using a Part 95 approved handheld radio (assuming 5W with removable antenna)?
- Is externally modulated F2D-emission data such as APRS (using an external modem) acceptable using a Part 95 approved non-handheld radio (assuming a 50W mobile unit on the main channels with external antenna)?
Thanks in advance for your time and input, it’s appreciated.
Kind Regards,
[Redacted]
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Dear [Redacted],
Here is the response we received to your inquiry:
The Commission did not adopt a specific data transmission standard when authorizing digital data transmissions in the GMRS, but the ability to transmit data was intended to allow short duration transmissions of location information, acknowledgement and short text in order to protect the primary use of the band for voice communications on a commons shared channel basis where users listen before talking to avoid interference. Such transmissions must comply with the requirements of 95.1731(d), 95.1773(c), 95.1787, and 95.339.
With that said, any digital data transmissions in the GMRS must only be initiated by a manual action by the operator, except that GMRS units may automatically respond with location data when being interrogated by another GMRS or FRS unit. The rules also limit digital data transmissions to hand-held units with a non-removable integral antenna.
- Does 95.1787 apply to operation or does it only apply to handhelds under going the certification process as the wording states?- Yes. All transmitters used in the GMRS service must be certified for such use. See 95.335 and 95.1761.
- Is externally modulated F2D-emission data such as APRS (using an external modem) allowable using a Part 95 approved handheld radio (assuming 5W with removable antenna)? Digital data transmissions are only permitted on GMRS hand-held units with a non-removable integral antenna(see 95.1731(d) & 95.1787). Additionally, Rule 95.339 prohibits attaching any external device to any Personal Radio Service transmitter if the combination results in a violation of the rules. The inquirer may also refer to FCC 17-57 para. 38 and 39 for additional discussion on this matter.
- Is externally modulated F2D-emission data such as APRS (using an external modem) acceptable using a Part 95 approved non-handheld radio (assuming a 50W mobile unit on the main channels with external antenna)? See above.
If you have any further questions or need additional information, please submit a help request at https://www.fcc.gov/wireless/available-support-services or call the FCC Licensing Support Center at (877) 480-3201.
Sincerely,
FCC Licensing Support Center
8:00 AM – 6:00 PM EST, M – F
Ref:MSG6254623
Email from: FCC IT Service Desk, fccprod@servicenowservices.com, Received January 5, 2021