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[aprssig] FRS & Type Acceptance WAS: Clubs, FRS ...teams

Eric Hansen skyssx at gmail.com
Sat Sep 3 22:02:23 UTC 2011


I know. He could rig up a LASER tx/rx pair, wire the transmitter up
into the  speaker/mic plug stub, then shoot the LASER down the PVC
tube the radio is in. No chance of spurious optical emission since the
pipe is opaque.

Or just not spend days over analyzing activity in CB 2.0 that affects
not one other person.

On Sat, Sep 3, 2011 at 5:55 PM, Denis Barton <wb8skp at gmail.com> wrote:
> Alex,
>
> Would this be legal ? Put a mic next to the FRS and run it to an amp and
> speaker in Bob's office, and caring it further, have a mic in his office run
> up to a speaker next to the FRS and have the FRS set to VOX. No mods to the
> radio.
>
> Denis
>
> I do understand what you're saying including Part 15 which governs nearly
> every piece of electronics around.  I'm not taking offense but I think
> there's enough gray areas within the rules that it could very easily be
> argued in front of the FCC that his modification is acceptable.  For that
> argument I would present the following:
>
> 15.1b appears to state that an RF device may violate Part 15 if the FCC
> certified it and licensed it otherwise.  However 15.5a appears to contradict
> that statement though it references a section that doesn't exist (90.63).
>
> 15.23 exempts home-built devices.  This is probably a little gray because
> it's a combination of a commercial device with a home-built modification.
>
> 95.194 governs the FRS units and does mention that you may not attach an
> apparatus to an FRS unit that has not been certified as part of that unit.
> However, see the entry below about 95.603.
>
> 95.129 which governs the GMRS portion of Personal Radio and the FCC
> explicitly singles out transmitters and not the whole unit.  Certification
> of a GMRS capable radio applies only to its transmitter according to that
> section.  The grey area comes in the dual-use radios that can operate on
> GMRS and FRS simultaneously.  If it can do both and there's a license to
> operate GMRS then it is likely that 95.194 does not apply and Bob's speaker
> wire and power cord are not covered because such a modification is not
> considered by 95.129.
>
> 95.401 defines FRS to be a Citizens Band Service (95.401b) but it does not
> specify GMRS as a Citizens Band because of the GMRS licensing requirement.
>
> 95.601 explicitly references only the transmitter for any Personal Radio
> Service device.  It also explicitly includes FRS in the Personal Radio
> Service.
>
> 95.603 specifies that an FRS unit must be certified but then defines an FRS
> unit to be a transmitter.  Therefore the use of "FRS Unit" in 95.194 applies
> only to the transmitter portion.
>
>
> 95.605 defines the certification procedure and specifies only the
> transmitter.  Chapter 2 Subpart J that it references (2.907) only specifies
> that certification is based on test data and applies to other identically
> produced devices.
>
> 95.607 prohibits the addition of external connections to a CB transmitter
> but this is a gray area because 95.669 restores the provision.
>
> 95.635 specifies the unwanted radiation from any device with and without
> external connections but again only references the transmitter portion of
> each device.
>
> 95.669 specifies the external controls that may be available on a CB
> transmitter.  This is another grey area because CB Service was already
> defined to include FRS so a CB transmitter could be construed to include FRS
> as well though it now conflicts with 95.194 and 95.669 is conflicting with
> 95.607.
>
> Given all the above I would argue to the FCC that Bob's modification (not
> withstanding his Part 97 license) is a home-built device and therefore Part
> 15.23 applies assuming he has shown the use of good engineering practices
> (such as a choke on each wire as close as possible to the radio) and that
> the modification is permissible because it applies only to the receiver
> rendering most if not all of Part 95 null as he is not exercising the
> transmitter portion of the radio.  If Part 95 was included, there are enough
> exceptions in the rules to allow the basic modification that Bob performed
> consistent with the rules (even in the face of some contradictions).
>
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