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

[Denis Barton]

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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