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

Steve Noskowicz noskosteve at yahoo.com
Sat Sep 3 23:37:11 UTC 2011

Forgot the OT before.

--- Denis Barton in part wrote:
> 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.

   I believe it would since it is not a modification to the device.  If an IR or laser remore connected *to* the FRS unit, it would be unapproved.

> 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. 

Yes.  This is what allows the FCC to certify an FRS even though it's transmitter/antenna does exceel the Part 15 limits (as do pretty much all other licensed transmitting devices).

> 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. 

It is COMPLETELY explicit in this. "95.194 (c) You may not attach any antenna, power amplifier, or other apparatus to an FRS unit that has not been FCC certified as part of that FRS unit. There are no exceptions to this rule and attaching any such apparatus to a FRS unit cancels the FCC certification and voids everyone’s authority to operate the unit in the FRS."

 No unauthorized accessories, period (unless the unit is not operated).  Notice that it makes no mention of transmitting, only "attaching any such apparatus ...cancels the FCC certification and voids everyone’s authority to operate the unit in the FRS."

No exceptions means no exceptions.

> However, see the entry below about 95.603.

Here is where I would aply my experience and say the following.   95.603 does not *define* an FRS unit as *only* the transmitter.  This section is defining the limits of the transmitter portion given the above comments on 15.1b.
A definition would explicitly be called a definition.

> 95.601 explicitly references only the transmitter for any
> Personal Radio Service device....

> 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.

Bad assumption.  You can not assume this.  .194 says "unit" and does not say transmitter.

> 95.635 specifies the unwanted radiation from any device
> with and without external connections but again only
> references the transmitter portion of each device.

Not any device, but the transmitter.  Because 95.635 only specifies transmitter performance explicitly, you can not include receiver performance in this section.   Since receivers do not have emissions as specified, you can not extend the requirement to receivers or any other parts of the unit.
Receiver or other sub-system rules, if there are any, would typicaly be found in another section or part (such as Part 95)

> Given all the above I would argue to the FCC that Bob's
> modification ...is permissible...

I believe the FCC would simply point to 95.194: "You may not attach any ...other apparatus to an FRS unit.... There are no exceptions to this rule ..."

Pretty clear, having read and siscussed similar topics before with the FCC or via one of the TCBs.

73, Steve, K9DCI

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