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The PRA GMRS
Repeater Beacon Updated May 6, 2007 |
| The position of the Federal Communications Commission Enforcement Bureau and the Personal Radio Association, Inc., is that automatic Morse-code beacon identifiers used to identify repeater stations in the General Mobile Radio Service are not permitted under Part 95 of the FCC Rules. Automatic beacon identification devices, whether voice recording or Morse code are a proximate cause of unwanted co-channel interference. Letters to GMRS licensees from FCC Enforcement Bureau Special Counsel Riley Hollingsworth have included direct orders to turn off beacon-style Morse-code (CW) station identification devices. The PRA requests that all licensees disable automatic ID devices of any type or change the device behavior so that the ID only occurs during periods of active use and are therefore considered activated by a control operator. In an effort to alert licensees to the FCC Rules regarding automatic operation and to create an awareness of the interference automatic identification devices cause, the PRA is initiating a program in 2007 to identify and notify licensees operating automatic beacons. These licensees will receive a post card from the PRA referring them to this FAQ. (Most repeater controllers like the Zetron 38A in use at PRA HQ can be set to provide a more-code identification only while the repeater is in actual use. It is a simple adjustment or programming modification.)
Why are beacon style ID's such an issue? Beacon style ID's do not listen first before transmitting. A beacon style ID device can and does interfere with GMRS transmissions in progress on other repeater systems. In areas where tropospheric ducting is common these ID'ers literally become on-the-air pollution. An automatic ID is in conflict with FCC R&R 95.171 that refers to channel sharing, also 95.7(a) as well as references referring to mutual interference in 95.7(b) and not causing intentional interference as in 95.183(5). Well beacon-style ID devices are allowed under Part 90 of the Rules so why not under Part 95? Part 90 is much different than Part 95. Under Part 90 a system ID can and does identify for all users of the repeater. Part 90 systems are also COORDINATED! This is not the case for a GMRS system with multiple licensees sharing the same repeater. GMRS systems are not coordinated. Part 90 also requires that when interference MIGHT result, the repeater owner MUST install devices to PREVENT automatic ID activation while the repeater output frequency is in use. Well I have to ID my repeater don't I? Not if it is not being used you don't. There is no reason to broadcast an automatic voice or CW ID if the repeater is not actively being used. The FCC rules also provide under 95.119(e) that a station need not identify its transmissions if it automatically retransmits communications from another station which [is] properly identified. Meaning that if a user of your repeater is identifying properly you don't need to identify the repeater itself. Each control operator needs to identify his/her own station while using a repeater. The individual's ID is heard on the input and the output frequency of the repeater. The rules do provide that a voice or CW ID can be used to identify a repeater see 95.119(d)(2) however, under the the current rules identification of the repeater in GMRS is really redundant. Can you cite some cases where automatic ID devices have become a concern for others and the Commission? FCC EB-2005-6020: "The complaint further alleges that a CW beacon identification system is used and transmits continuously, even when the system is not in use." FCC EB-2005-6021: The complaint alleges that your system is continually identifying in Morse code, without monitoring for radio traffic and when the system is not being used......Channels in GMRS are shared equally among all licensed users. Every GMRS system operator must cooperate in sharing the assigned channels with other GMRS systems by monitoring the channel before initiating transmissions, waiting until communications in progress are completed before initiating transmissions, engaging in only permissible communications and limiting transmissions to the minimum practical transmission time. Unless your system is being used, there is no reason whatsoever for you to continually transmit an automatic identification. If you seek an exclusive channel, you may wish to consider licensing in other services. Where in the rules does it say anything about automatic control? Automatic control in GMRS is not allowed. See FCC R&R 95.171. The requirements that the station operator must be at the control point, communicates messages and controls the station, and also "must cooperate in sharing each channel" eliminates automatic control as a possibility. Basically, if an operator is at a control point and controls the station, control is either local or remote. When an operator keys a repeater, identifies his transmission, and the ID device is activated the device is not under automatic control. (Automatic control of Amateur Radio repeaters is allowed and this may be cause for the confusion of some Hams that are also GMRS licensees 95.205(d)) Simply put, an “automatic” ID’er is automatic as no control operator is present. Therefore one could argue that an automatic ID’er (voice or CW) is not permitted under the rules because a control operator does not activate it. This is the position being taken by the FCC Enforcement Bureau and the PRA. Beacon ID devices are OK in the Amateur Service why not here? The Amateur Radio Service is very different than GMRS. First and foremost all Amateur repeaters are COORDINATED through regional committees. Any uncoordinated amateur radio repeaters have the burden of preventing interference to coordinated systems up and including ending operations altogether. Amateur repeaters are not likely to interfere with one another when beacon-style ID devices activate. The Amateur rules also look differently at automatic operation as noted above. Beacon-style ID devices are popular in the Amateur Service so traveling Amateurs know they are in range of a repeater. This is not an issue with GMRS since PRIOR PERMISSION is still required to use a GMRS repeater as GMRS repeaters are considered private property. Amateurs expect to use most any repeater they would like. GMRS licensees do not and may not have that expectation. GMRS is not a QSO chat-based hobby service. GMRS is a directed communication service for personal licensees and their families to conduct their personal business. There is NO NEED therefore to broadcast a beacon that attracts attention to your GMRS system. Amateurs that own and operate GMRS stations must read the GMRS rules and clearly understand the differences between the two. Amateurs do not bring their rules of operation with them to GMRS. Do beacons have other purposes? Some buff groups activate the beacon-style ID devices simply to discourage others from using the same frequency. A beacon ID from a high profile/large footprint repeater in an urban area going off every fifteen minutes (or perhaps more frequently) only shouts "THIS IS MY CHANNEL GO AWAY!!!!!!" A very unfriendly practice. Beacon identifiers are NOT necessary. We call it frequency camping. What can I do about beacons in my area? Ask the licensees of systems using beacon-style ID devices to deactivate the beacon OR adjust parameters so that it only activates during periods of actual repeater use. Be sure to let the licensee know if the beacon has been interfering with others. You can also refer them to this FAQ. Doesn't the repeater CW ID relieve the users under my license from having to identify their stations? No. Every user of a repeater has an obligation to identify their station while using the repeater. Their transmissions are on two frequencies. The repeater input and output. A CW identification transmits only on the repeater output. The FCC Rules do not specifically provide for a CW ID to identify for everyone in a family group either. All too frequently we hear GMRS users identifying on repeaters with made up unit identifiers and no FCC call signs. That FCC call sign is a requirement. It is not optional. I hear grandfathered licensees using their CW ID to identify their users all the time! Many do and they are in violation of the Rules. Grandfathered licensees have the same obligation to obey Part 95 of the Rules as do personal licensees. These users are NOT governed by Part 90. My beacon ID has been in use for years and no one has complained. We think if you asked around you might be surprised, particularly if you operate a high-level repeater operated by just a few individuals. Just because you have gotten away with it for years does not mean you should continue doing it. GMRS licensees should avoid causing interference in the first place and not have to be told that their behaviors have been causing interference. The logic behind this question is backwards. |
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