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With a trucked system the system, not the operator sets the transmit frequency thus the operator with the mic is no longer is in complete and direct control of the emission emanating from their radio. This brings to the forefront of any legal argument who exactly is then responsible for the emissions of all the mobiles using the trucked system. Let’s say I go key down on the trucked system to talk to my buddy on talk group 3. My radio then goes “yo repeater I’d like to communicate on talk group 3” and the repeater then responds, “ok tune to frequency 3 and transmit”. Radio tunes to frequency 3 and clobbers the communications of a life safety operation in progress either because you screwed up the code plug or the repeater sent you somewhere it should not have or whatever.
What if someone screwed up the programming of a conventional ham repeater with the incorrect input frequency and clobbers a life safety operation? What if the repeater is part of a linked network and someone goofs up one of the linked repeaters to transmit over a life safety operation? (Heck, in the case of a relative of mine, what if your cable TV box malfunctions and starts to clobber air band frequencies and you live near a military airport?)
Part of what you’re referring to is the distinction between centralized (station class FB8) trunking systems commonly used in public safety versus decentralized (FB6) stations like LTR. Centralized systems have the controller in charge and the FCC requires that the frequencies be exclusively licensed for quite some distance. With decentralized systems, the controller indicates the next free repeater, but the radio is still supposed to make sure the frequency is free.
(Not sure if it’s entirely part of the centralized/decentralized distinction, but systems also differ in whether the controller directly gives out frequency assignments, or just points to channel numbers.)
Stick with a decentralized system and the repeater control op can’t reasonably be held at fault if a user causes interference.
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FB6 is a business radio class:
FB6 - Private Carrier (profit)
A repeater operated by a radio communications provider for multiple subscribers who are covered under the carrier's license.
Not applicable to amateur radio as we are individually licensed as is the repeater,? whose trustee is the responsible party for it.
Ken
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You guys are missing the most important point about trunking and modes like DMR roaming.
Does the control operator know when the radio is transmitting or what frequency is used every time it transmits?
Does your radio ID by itself in a way that complies with 97.119(b) every time it sends a control channel message?
Do you ID by voice at the end of every single PTT transmission?
The control operator (end user) of a trunked radio cannot comply with the station identification requirements in 97.119(a) because there is no way to ensure that you ID every 10 minutes or at the end of every transmission on each frequency that is used.
Tom ND5Y
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Isn't the same true of EVERY repeater?
That said, the control op is not responsible for "ensuring"
the ID of the user radios - only the repeater(s).
If you are using a repeater, YOU are responsible for your IDing.
You made a lot of good points, but ended it with a bad argument.
Case in point: If you drive through a valley out of the repeater range, and you ID your transmitter at 9 minutes, that satisfies the legal requirements EVEN THOUGH that ID never came through the repeater.
Case #2: IF you are using a repeater that has CTCSS access, and you ID yourself without CTCSS, you satisfied your legal obligations to ID even though the control op of the repeater never heard it.
Joe M.
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On 1/1/2021 9:38 AM, nd5y via groups.io wrote:
The control operator (end user) of a trunked radio cannot comply with
the station identification requirements in 97.119(a) because there is no
way to ensure that you ID every 10 minutes or at the end of every
transmission on each frequency that is used.
Tom ND5Y
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Toms assertion that the user is the control operator of a repeater is incorrect. A lot of folks simply have never read the rules and fcc opinions concerned repeater operation.
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On Jan 1, 2021, at 9:55 AM, Joe M. <mch@...> wrote:
Isn't the same true of EVERY repeater?
That said, the control op is not responsible for "ensuring"
the ID of the user radios - only the repeater(s).
If you are using a repeater, YOU are responsible for your IDing.
You made a lot of good points, but ended it with a bad argument.
Case in point: If you drive through a valley out of the repeater range, and you ID your transmitter at 9 minutes, that satisfies the legal requirements EVEN THOUGH that ID never came through the repeater.
Case #2: IF you are using a repeater that has CTCSS access, and you ID yourself without CTCSS, you satisfied your legal obligations to ID even though the control op of the repeater never heard it.
Joe M.
On 1/1/2021 9:38 AM, nd5y via groups.io wrote:
The control operator (end user) of a trunked radio cannot comply with
the station identification requirements in 97.119(a) because there is no
way to ensure that you ID every 10 minutes or at the end of every
transmission on each frequency that is used.
Tom ND5Y
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I think we’re actually just disagreeing on what constitutes “the most important point.”
Indeed, most (if not all) currently used trunking modes with more than one frequency would not entirely conform to some aspects of Part 97 as written.
That feels like part of the challenge to figure out. Do you create a new ham-complaint protocol that tackles these things? Do you just set up a 2-frequency LTR system that also supports conventional operation and, every ten minutes, ID on both? Do you petition to tweak the rules slightly to accommodate trunked systems? Do you just trust that making a good-faith effort to ID regularly on a system that has a public website documenting how it works will satisfy the spirit of the law?
I don’t know the answers, but I don’t think it’s a reason the idea can’t get off the ground.
You guys are missing the most important point about trunking and modes
like DMR roaming.
Does the control operator know when the radio is transmitting or what
frequency is used every time it transmits?
Does your radio ID by itself in a way that complies with 97.119(b) every
time it sends a control channel message?
Do you ID by voice at the end of every single PTT transmission?
The control operator (end user) of a trunked radio cannot comply with
the station identification requirements in 97.119(a) because there is no
way to ensure that you ID every 10 minutes or at the end of every
transmission on each frequency that is used.
Tom ND5Y
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It's sad how often discussions on a technical list degenerate into bickering about FCC rules.
So many people concerned about following the rules - except when it comes to themselves respecting the group rules:
"This group is not for discussing FCC rules"
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Yep, that's why I backed out of it. Rules are guidelines and are frequently outdated by the time they are published. You also shouldn't have to take every sentence at face value. Rules are written to be interpreted and should never be taken to be obstructions
to try something new, old, or different. The folks that sit there and come up with citations why something is not allowed really need to find a different hobby.?
That's why 88kph doesn't really mean 88kph.
td
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From: repeater-builder@groups.io <repeater-builder@groups.io> on behalf of nj902 <wb0emu@...>
Sent: Friday, January 1, 2021 8:15 AM
To: repeater-builder@groups.io <repeater-builder@groups.io>
Subject: Re: [repeater-builder] Trunking
?
It's sad how often discussions on a technical list degenerate into bickering about FCC rules.
So many people concerned about following the rules - except when it comes to themselves respecting the group rules:
"This group is not for discussing FCC rules"
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What if someone screwed up the programming of a conventional ham repeater
with the incorrect input frequency and clobbers a life safety operation? Only the repeater trustee is responsible. The users would be responsible to know that they can't program an out-of-band frequency in their radios, just like they always would. What if the repeater is part of a linked network and someone goofs up one
of the linked repeaters to transmit over a life safety operation? (Heck, in
the case of a relative of mine, what if your cable TV box malfunctions and
starts to clobber air band frequencies and you live near a military
airport?) Can't happen. These things are NOT programmed on the fly. But again, only the licensee of the link is responsible for that.
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On 12/31/2020 8:34 PM, Eric Fort wrote: Not quite the same legal result between one 4 channel trundled system with multiple talk groups and 4 separate repeaters. The key difference is in the case of 4 separate repeaters the licensee holding the mike always transmits on the single input frequency of that one single channel repeater and has positive control over which frequency his transmitter is tuned to. With a trucked system the system, not the operator sets the transmit frequency thus the operator with the mic is no longer is in complete and direct control of the emission emanating from their radio. Sorry, but that is not a correct interpretation. These are frequencies setup and known in advance. Therefore, the user knows. And really, the only requirement a ham has for frequency is to know that he is operating withing his license privileges. If a repeater trustee sets up a repeater with input frequencies outside of a users privileges, then that user can't use his system. But I don't see how that could be anyway, because the only band that has repeater inputs authorized that could be outside a class of licensee is 10 M, since you have to have general or above to operate there. Otherwise, all repeater bands are within every license class privileges. There is no requirement for frequency tolerance for hams, if that's what you're thinking. Just what is needed to prevent interference and keep your emissions within your operating privileges.
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Sorry Jim, but part of what you mentioned is wrong.
When a ham transmits he only needs to be on the frequency and mode he is licensed for.? What happens to his signal through a repeater does not matter as long as the repeater is legal for the control operator (trustee/ call sign on repeater)? license class.
That was decided on many years ago when the first OSCAR satellite that had a repeater (translator)? on it that received on 2 meters and down linked on 10 meters.? The FCC said it was fine for a Technician class to use it even though the Tech did not have 10 meter privileges.
For a while the novice class had some privileges on the 220 MHz band.? My wife and some others had a novice class? .? As we had a 2 meter and 220 mhz repeater and a controller we linked the 2 together so they could also come out on the 2 meter machine.? All legal.
Ralph ku4pt
On Friday, January 1, 2021, 02:51:06 PM EST, Jim Barbour <wd8chl@...> wrote:
On 12/31/2020 8:34 PM, Eric Fort wrote:
> Not quite the same legal result between one 4 channel trundled system with multiple talk groups and 4 separate repeaters. The key difference is in the case of 4 separate repeaters the licensee holding the mike always transmits on the single input frequency of that one single channel repeater and has positive control over which frequency his transmitter is tuned to. With a trucked system the system, not the operator sets the transmit frequency thus the operator with the mic is no longer is in complete and direct control of the emission emanating from their radio.
Sorry, but that is not a correct interpretation. These are frequencies
setup and known in advance. Therefore, the user knows.
And really, the only requirement a ham has for frequency is to know that
he is operating withing his license privileges. If a repeater trustee
sets up a repeater with input frequencies outside of a users privileges,
then that user can't use his system. But I don't see how that could be
anyway, because the only band that has repeater inputs authorized that
could be outside a class of licensee is 10 M, since you have to have
general or above to operate there. Otherwise, all repeater bands are
within every license class privileges.
There is no requirement for frequency tolerance for hams, if that's what
you're thinking. Just what is needed to prevent interference and keep
your emissions within your operating privileges.
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On 1/1/2021 3:05 PM, Ralph Mowery via groups.io wrote: Sorry Jim, but part of what you mentioned is wrong.
When a ham transmits he only needs to be on the frequency and mode he is licensed for. That's basically what I said... What happens to his signal through a repeater does not matter as long as the repeater is legal for the control operator (trustee/ call sign on repeater)? license class. That was decided on many years ago when the first OSCAR satellite that had a repeater (translator)? on it that received on 2 meters and down linked on 10 meters.? The FCC said it was fine for a Technician class to use it even though the Tech did not have 10 meter privileges.
For a while the novice class had some privileges on the 220 MHz band.? My wife and some others had a novice class? .? As we had a 2 meter and 220 mhz repeater and a controller we linked the 2 together so they could also come out on the 2 meter machine.? All legal.
Ralph ku4pt Yup. I agree with that completely. On Friday, January 1, 2021, 02:51:06 PM EST, Jim Barbour <wd8chl@...> wrote:
On 12/31/2020 8:34 PM, Eric Fort wrote:
Not quite the same legal result between one 4 channel trundled system with multiple talk groups and 4 separate repeaters. The key difference is in the case of 4 separate repeaters the licensee holding the mike always transmits on the single input frequency of that one single channel repeater and has positive control over which frequency his transmitter is tuned to. With a trucked system the system, not the operator sets the transmit frequency thus the operator with the mic is no longer is in complete and direct control of the emission emanating from their radio. Sorry, but that is not a correct interpretation. These are frequencies
setup and known in advance. Therefore, the user knows.
And really, the only requirement a ham has for frequency is to know that
he is operating withing his license privileges. If a repeater trustee
sets up a repeater with input frequencies outside of a users privileges,
then that user can't use his system. But I don't see how that could be
anyway, because the only band that has repeater inputs authorized that
could be outside a class of licensee is 10 M, since you have to have
general or above to operate there. Otherwise, all repeater bands are
within every license class privileges.
There is no requirement for frequency tolerance for hams, if that's what
you're thinking. Just what is needed to prevent interference and keep
your emissions within your operating privileges.
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Thank you, exactly the point I was making earlier.
Eric
Af6ep
Sent using SMTP.
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On Jan 1, 2021, at 6:38 AM, nd5y via groups.io <nd5y@...> wrote:
?You guys are missing the most important point about trunking and modes like DMR roaming.
Does the control operator know when the radio is transmitting or what frequency is used every time it transmits?
Does your radio ID by itself in a way that complies with 97.119(b) every time it sends a control channel message?
Do you ID by voice at the end of every single PTT transmission?
The control operator (end user) of a trunked radio cannot comply with the station identification requirements in 97.119(a) because there is no way to ensure that you ID every 10 minutes or at the end of every transmission on each frequency that is used.
Tom ND5Y
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My apologies then for somewhat starting this sub thread. I had not seen this when I signed up for the list and while I’d prefer this remain a primarily technical list at times the rules under which we operate dictate the direction in which we take our technical endevor so?
Eric
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On Jan 1, 2021, at 8:15 AM, nj902 <wb0emu@...> wrote:
"This group is not for discussing FCC rules"
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Conventional DMR Phase 2 can indeed automatically roam. No trunking is required.
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The Real RFI-EMI-GUY
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On Fri, Jan 1, 2021 at 09:38 AM, nd5y wrote:
You guys are missing the most important point about trunking and modes
like DMR roaming.
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As can P25 Conventional if you have a radio with Vote-Scan enabled.
The argument about trunking is moot as there is not even enough traffic these days to even justify keeping many of the conventional repeaters that already exist on the air.??
Aside from DMR and LTR trunking you also have one transmit frequency that is always tied up with control channel traffic - even if nobody is using the system - so unless you have enough traffic to keep 3 or more talkgroups active at all times there is no benefit to trunking and it is just taking up more bandwidth needlessly.? This is one reason that the majority of Federal agencies are still running conventional repeaters rather than trunking.? The other reason is instant access versus waiting for a channel grant.? State/Local agencies generally have enough traffic on enough talkgroups to justify trunking and P25 Phase 2 TDMA trunking has made that even more efficient - but trunking also takes a lot more hardware which is not cheap by any means and would be outside the budget of most clubs, many of which are still running repeaters that were built in the 1970s (not that there is anything wrong with that but running a modern trunking system is not going to work well without newer equipment - with the possible exception of LTR which is an ancient trunking format that has mostly been abandoned by commercial users and was never intended for public safety.
The efforts put forward here would be better directed towards improving the existing systems (conventional) and encouraging use of them.? It is hard enough getting people to adopt things like D-Star, DMR, and P25 much less a trunking system that requires even more specific hardware and programming.? Instead of beating each other over the head about if trunking is legal for Ham Radio let's use that effort to encourage the use of the existing systems so we can maintain our privileges.? If you really have a question of if Trunking is legal under part 97 the answer is just a phone call or email away - the FCC will be glad to answer those questions directly.
Although experimentation with new modes and technologies is great for Ham radio it has also had the negative effect of diluting the user-base and driving many who are not as technically savvy away.? While we should continue to experiment and develop new technologies ultimately we need to make sure we are adopting technologies that are positive for the ham radio community at large - and avoiding technologies that are proprietary or harmful to the hobby.? Any digital mode that is not open-source has no place in ham radio in my opinion (use of proprietary vocoders that are reasonably available commercially not included as these are a foundation of nearly every digital voice mode).? MMDVM and Pi-Star are great as they have given access to many digital modes to many people - but hotspots should be used as a tool for when you are not able to utilize a local repeater - not as a replacement.? Unfortunately these technologies, which should have helped build up ham radio, have actually had quite a detrimental impact in the capabilities of the ham community at large should we actually need to communicate during an emergency.? I am not against these - but I am against them being the only way a ham operates as they might as well just be talking on a Skype or Zoom call.
I eagerly await all of your spirited dissenting views on my thoughts.?
Thanks,
Dan Woodie, CETsr KC8ZUM
On Fri, Jan 1, 2021 at 5:47 PM RFI-EMI-GUY < rhyolite@...> wrote: Conventional DMR Phase 2 can indeed automatically roam. No trunking is required.
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The Real RFI-EMI-GUY
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I never even mentioned repeaters.
All amateur stations require a control operator. Not just repeaters.
It doesn't make any difference if your transmissions are repeated or not or if you are using a trunked system or not. You still have to follow the station identification requirements.
Tom ND5Y
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Toms assertion that the user is the control operator of a repeater is incorrect. A lot of folks simply have never read the rules and fcc opinions concerned repeater operation.
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On Fri, Jan 1, 2021, 17:31 Dan Woodie < kc8zum@...> wrote: If you really have a question of if Trunking is legal under part 97 the answer is just a phone call or email away - the FCC will be glad to answer those questions directly.
Hold up.
Here is some reading everyone should review. Scroll down to the heading "A historical note, and a caution on communications with the FCC:" Sorry, I'm using a mobile so I cannot link directly to the correct spot. It gives a good perspective on things.
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That’s why you speak your call into your microphone
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On Jan 1, 2021, at 6:32 PM, nd5y via groups.io <nd5y@...> wrote:
I never even mentioned repeaters.
All amateur stations require a control operator. Not just repeaters.
It doesn't make any difference if your transmissions are repeated or not or if you are using a trunked system or not. You still have to follow the station identification requirements.
Tom ND5Y
Toms assertion that the user is the control operator of a repeater is incorrect. A lot of folks simply have never read the rules and fcc opinions concerned repeater operation.
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Brett,
I was looking for exactly that text but couldn't remember where I found it! I searched my mailing list archives thinking it was more recent.
I wonder if we can get that section promoted to its own page on the Repeater Builder site. I think it's good advice both for interacting with the FCC, and for summarizing the spirit of amateur radio.
On Fri, Jan 1, 2021, 17:31 Dan Woodie < kc8zum@...> wrote: If you really have a question of if Trunking is legal under part 97 the answer is just a phone call or email away - the FCC will be glad to answer those questions directly.
Hold up.
Here is some reading everyone should review. Scroll down to the heading "A historical note, and a caution on communications with the FCC:" Sorry, I'm using a mobile so I cannot link directly to the correct spot. It gives a good perspective on things.
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Matt Wagner
Ken W0KAH
RFI-EMI-GUY