I am not sure that the PSTN or (North America numbering plan) NANP even exist in the regulatory world of the FCC today. A reread of the current rules finds those definitions no longer exist.


On 2/18/2019 1:05 PM, Pierre Martel wrote:
So from what I can understand. you can link them if the method to link is not connected to a pstn line. Now If I am not too crazy, that would mean that a user that have only a dsl line on site could link by RF (using an wifi access point and a wifi client network card ) to by pass the interconnection to the pstn.. So it is very easy to not be connected to a pstn network. The othe part aboit interconnected voip system. It is easy to build a voip system that have no link to any pstn network (allstarlink being one) But it is as easy to connect that voip system to a pstn system. Grey is predominant in that situation.

Pierre
VE2PF

Le lun. 18 févr. 2019 à 12:20, Brad Trogdon <Brad@trogdon.org> a écrit :
Thank you for the reply but you provide no answers to my very specific questions.

Please see my reply to your questions and comments noted by ">>>"


Has anything been settled with HamVoIP as an attempt to run off with Jim’s work? As of this date I do not believe it has been.
>>> What does HamVoIP have to do with the linking of GMRS Repeaters? 

In a shared repeater/simplex channel environment, it is always good to be able to monitor the input before keying up a repeater. In a linked system that’s not possible unless you do the BCLO in each repeater. Never saw that work out too well mixed mode.
>>> Not sure you understand how radios work.  If a station is strong / close enough to the repeater to be heard then they are otherwise the users of the repeater users will talk over the "Unheard users". 

>>> Cornell is not the authority. Federal Register in its entirety is https://www.federalregister.gov/documents/2017/08/29/2017-17395/personal-radio-service-reform#sectno-citation-%E2%80%8995.1701 .  The URL which you provided references " telephone connection is prohibited".  What leads you to believe that telephone is connected?  In my specific situation Telco is not even connected to the building.  So no chance of violation.

So if you have an organized group or club engaged in linking GMRS repeaters together and one of them is in violation related to telco, does that mean the collective network is 9/10 legal?
>>> 1. GMRS Repeater linking as an ability or practice is not an "Organized Group".  2. No, the one person is the offender not the others whom are in compliance.  Its against the rules to use foul language on radio frequencies.  If another station is and you hear it but don't reciprocate does that make you and offender of the rules?  No and that logic is silly if you believe true.

>>> Are you questioning your local GMRS folks whom are charging for access (Membership) to their closed system that is using apt_rpt (AllStar)?   www.NorthGeorgiaGMRS.com is a single organized group of 30 GMRS Linked repeaters.  I'm not a betting person but I would venture to guess that DSL is in the mix.


<<< FCC Correspondence via email on the topic. >>>
Case Id: HD0000002998556

Summary: Licensing Requirements

Description: There seems to be a lot of confusion as to whether linking the audio of two or more GMRS repeaters via an internet connection is permitted or prohibited under the part 95 rules.

Could we please get some sort of clarification as to whether this is a strictly prohibited action per part 95 rules?

Thank you.

Solution Description: Dear Mr. *******,

GMRS stations may not be interconnected to the public switched telephone network as per 95.127. However, proposing to use a VoIP link between the two repeater sites is permissible if the link is considered non-interconnected VoIP. VoIP can either be an interconnected VoIP service or non-interconnected VoIP service, see the definitions below. It is my understanding that if your internet provider is the cable company, it’s fine; but if you have DSL or dial-up internet from the phone company, it isn’t.

The second method using RF to link the two repeater sites is allowed so long as the link meets the rules and limitations for fixed stations pursuant to the Part 95 rules.

§64.601

(23) Non-interconnected VoIP service. The term “non-interconnected VoIP service”—

(i) Means a service that—

(A) Enables real-time voice communications that originate from or terminate to the user's location using Internet protocol or any successor protocol; and

(B) Requires Internet protocol compatible customer premises equipment; and

(ii) Does not include any service that is an interconnected VoIP service.

§9.3 

Interconnected VoIP service. An interconnected Voice over Internet protocol (VoIP) service is a service that:

(1) Enables real-time, two-way voice communications;

(2) Requires a broadband connection from the user's location;

(3) Requires Internet protocol-compatible customer premises equipment (CPE); and

(4) Permits users generally to receive calls that originate on the public switched telephone network and to terminate calls to the public switched telephone network.

The rules may be found at the following website: https://www.fcc.gov/general/rules-regulations-title-47 

Should you have any further questions, or need additional information, please submit a request through https://esupport.fcc.gov/onlinerequest.htm or call the FCC Licensing Support Center at 1-877-480-3201, selecting option 2 after the main menu.

Sincerely,

FCC Licensing Support Center
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