What follows is my (WQWH848) query to the Commission and their reply:
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Case Id: HD0001312512
Summary: Licensing Requirements
Description: Greetings.
As a long-time user of various radio services and as an Administrator of several GMRS repeaters in western Washington State, I am hoping to quell rumors and misinformation regarding numerous topics, including repeater linking in the General Mobile Radio Service (GMRS).
Specifically, I have recently discovered a seven year old document purported to be a Commission response to a linking query. the reputed ID is HD0002998556. Text follows:
Summary: Licensing Requirements
Description: There seems to be a lot of confusion as to whether linking the audio of two or more GMRS repeaters via an internet connection is permitted or prohibited under the part 95 rules.
Could we please get some sort of clarification as to whether this is a strictly prohibited action per part 95 rules?
Thank you.
**Solution Description: Dear Mr. *****,
GMRS stations may not be interconnected to the public switched telephone network as per 95.127. However, proposing to use a VoIP link between the two repeater sites is permissible if the link is considered non-interconnected VoIP. VoIP can either be an interconnected VoIP service or non-interconnected VoIP service, see the definitions below. It is my understanding that if your internet provider is the cable company, it's fine; but if you have DSL or dial-up internet from the phone company, it isn't.
The second method using RF to link the two repeater sites is allowed so long as the link meets the rules and limitations for fixed stations pursuant to the Part 95 rules.
§64.601
(23) Non-interconnected VoIP service. The term "non-interconnected VoIP service"—
(i) Means a service that—
(A) Enables real-time voice communications that originate from or terminate to the user's location using Internet protocol or any successor protocol; and
(B) Requires Internet protocol compatible customer premises equipment; and
(ii) Does not include any service that is an interconnected VoIP service.
§9.3
Interconnected VoIP service. An interconnected Voice over Internet protocol (VoIP) service is a service that:
(1) Enables real-time, two-way voice communications;
(2) Requires a broadband connection from the user's location;
(3) Requires Internet protocol-compatible customer premises equipment (CPE); and
(4) Permits users generally to receive calls that originate on the public switched telephone network and to terminate calls to the public switched telephone network.
**The rules may be found at the following website: https://www.fcc.gov/general/rules-regulations-title-47 **
Should you have any further questions, or need additional information, please submit a request through https://esupport.fcc.gov/onlinerequest.htm or call the FCC Licensing Support Center at 1-877-480-3201, selecting option 2 after the main menu.
Sincerely,
FCC Licensing Support Center
Can your office please advise if the reply dealing with GMRS repeater linking is real or a manufactured story? Additionally, your more recent in-depth reply, regarding a correct interpretation of the current rules, could be a valuable additional assistance.
Sincerely,
Joseph Mann
WQWH848 / W7ROH / KROH 91.1 FM
www.radioofhope.org/Oly-Comm
Good morning,
Please be advised that this staff advice is not binding to the Commission. [Isn't that interesting?]
While neither this inquiry or the earlier inquiry that you reference provide sufficient details regarding the intent or purpose of the repeater "linking", staff opinion is that linking GMRS repeaters via the internet or PSTN in a way that sends GMRS messages and control signals to rebroadcast those messages via this link at a distant repeater site is not permitted. Please refer to 95.1733(a)(8) which specifically prohibits messages which are both conveyed by a wireline control link and transmitted by a GMRS station. Additionally, please refer to 95.1749 which states, "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."
There are only 8 channel pairs nationwide for GMRS repeater operations that are shared on commons basis, so linking many repeaters to transmit simulcast communications is not spectrum efficient and could interfere with other users a great distance away. Accordingly, pursuant to 95.1733(a)(8) GMRS messages which are both conveyed by a wireline control link and are transmitted by a GMRS station should not be carried on any network for the purpose of linking repeaters for simulcast."
We can't speak to the earlier staff advice that was provided through our licensing support center. Perhaps, that advice was intended to indicate that the connection would only be valid for remote control of the repeater site, or for the sole purpose of monitoring repeater communications by a control operator at a control point to ensure compliance with the Commission's rules. However, using such network connections to carry VOIP GMRS traffic for rebroadcast on one or more GMRS repeaters at distant locations renders the listen before talk etiquette ineffective and undermines the basic structure of this service. We also note that the prior response appears to reference the part 95 rules prior to the 2017 update. The 2017 update included the following restriction in 95.1749: "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."
If you have any further questions or need additional information, please submit a help request at https://www.fcc.gov/wtbhelp or call the FCC Licensing Support Center at (877) 480-3201.
Sincerely,
FCC Licensing Support Center
8:00 AM – 6:00 PM ET, M – F
Ref:MSG14608552