HAM, Marine SSB, Other?

[barnakiel]

No long range except for an SSB receiver.

Not going the HF way even when lotto happens: too big, to heavy and to power-hungry in our tiny ship!

Sponsors to get me an IsatPhone PLS apply ;-)

b.

[btrayfors]

Eric,

I think you're misreading Part 80.

The key phrase is, "in the Maritime Service".

The fact that a radio has been type accepted by the FCC for maritime use does not place it automatically "in the Maritime Service".

As a licensed amateur radio operator I can take ANY radio....marine, ham, aircraft, military, land mobile, home brew, etc.....and use it in my home, in the field, on my boat, in an airplane, or anywhere at all. It will be in use in the Amateur Radio Service, not "in the Maritime Service" or "in the Aircraft Service" or whatever.

Any other interpretation would be really stretching the language and the intent of the international regulations.

Bill

[fairbank56]

If your ships radio station requires type approved marine Rf gear ( which I beleive all do! You are breaking such type approval by modifying your radio to transmit on ham bands, you are not breaking any ham rules but you are breaking marine radio rules.

Technically correct except for those radio's that are capable of transmission on the ham bands as is (out of the box)(no mod required).

This is why manufacturer's do not openly advertise that their radio's are capable of operating on the ham bands. Vendors selling them do advertise it. While Icom does not advertise the M802 as ham capable, they do provide the front panel keystrokes required to "open" the transmitter in their knowledge database

Eric

[hellosailor]

Logically...what is the purpose of a Maritime Service radio license? One might say, first and foremost, to provide for the safety of ships at sea. To ensure that the maritime radio station can always be used, by any souls on board, in the event of any emergency, one might reluctantly concede that there is a point in requiring the radio in that station to be used solely for that service, i.e. never disconnected, never modified and tuned to some other use. But in order to give the greatest chance that the ship will be able to call out in distress, there is some logic to requiring the radio be "unmolested" at all times.

Now, does that make sense in the context of small boat, singlehander, daily need for dual purpose....perhaps not. Regulations usually aren't well-drafted and it would seem that these regulations could be improved. But that takes money, and the FCC doesn't spend a dime unless they can make a dollar. Or, someone really gets on their case.

If the FCC ran the FDA, they'd just ban peanuts, shellfish, and strawberries from public sale. That's much safer and simpler than trying to deal with allergens on an individual basis.

[fairbank56]

Originally Posted by btrayfors

As a licensed amateur radio operator I can take ANY radio....marine, ham, aircraft, military, land mobile, home brew, etc.....and use it in my home, in the field, on my boat, in an airplane, or anywhere at all. It will be in use in the Amateur Radio Service, not "in the Maritime Service" or "in the Aircraft Service" or whatever.

I disagree. A part 80 certified marine transceiver is intended for use in the maritime service, not the amateur radio service. It must be operated under a marine station license whether you intend to transmit on marine frequencies or not. Otherwise, we could all just forgo the station license and $220 fee and just claim "oh we only use it for the ham bands, we don't use it on marine channels"

Eric

[btrayfors]

Eric,

Respectfully, that's BS.

Again, just because a radio has been type-accepted for a particular service -- maritime, aeronautical, or whatever --

--- DOES NOT AUTOMATICALLY PLACE IT IN THAT SERVICE --

--- nor does it mean that the radio must be used ONLY in that service.

A marine radio in use in my home under my amateur radio license is absolutely NOT in the maritime service and is perfectly legal by any reasonable interpretation of the ITU Rules and Covenants and the FCC Regulations.

Bill

[Viking Sailor]

Originally Posted by fairbank56

Wrong, wrong wrong! Part 80 rules apply to ALL part 80 certified radio's regardless if you are required to have them or not.



I use one myself from my shop but technically, it is against the rules. Any part 80 certified marine HF-SSB transceiver installed and operating is a marine station and is required to operate under a marine station license and under part 80 rules regardless if it is on a vessel or land.

If you were to get caught and asked for your coast station license, telling them you only use it on the ham bands isn't going to cut it.

I'm not trying to be the FCC police, I don't care, I do it too. It's no big deal and nothing to worry about. I'm just saying that it is in fact, against the rules.

Eric

No Eric you are wrong!

A voluntarily equipped ship can be operated under either a valid ship station license or a valid ham station license as long as the rules for the station license covering the frequencies being used are complied with.

Part 80

Subpart A—General Information
80.5 Definitions.

(6) Compulsory ship. Any ship which is required to be equipped with radiotelecommunication equipment in order to comply with the radio or radio-navigation provisions of a treaty or statute to which the vessel is subject.


(7) Voluntary ship. Any ship which is not required by treaty or statute to be equipped with radiotelecommunication equipment.


Subpart F—Equipment Authorization for Compulsory Ships

80.251 Scope.

(b) The equipment described in this subpart must be certificated.

I find it very interesting that their is an explicit subpart and statement stating that the equipment on compulsory equipped ships must be certificated, but no equivalent text in part 80 for voluntarily equipped ships.

[fairbank56]

Originally Posted by btrayfors

Again, just because a radio has been type-accepted for a particular service -- maritime, aeronautical, or whatever --

--- DOES NOT AUTOMATICALLY PLACE IT IN THAT SERVICE --

--- nor does it mean that the radio must be used ONLY in that service.

That's exactly what it means. For example, there are some handheld marine VHF's that are certified for both part 80 and part 90 (land mobile). You cannot legally use a part 80 only certified radio in the land mobile radio service. It must be certified for that service. The land mobile frequencies can only be legally programmed by vendors or FCC licensed tech's. BTW, the term type-acceptance was phased out 26 years ago. The radio's since then are known as "certificated". While not all amateur radio's require certification, most commercial units are and carry an FCC identifier label. They must meet certain FCC requirements regarding spurious emissions and radiation interference. These conditions are met by modern marine SSB radio's. They are easily capable of operating on the ham bands, but technically, it is against the rules. They are certified for part 80 only, not part 80 and part 97. The main difference being that marine frequencies are channelized while ham are continuously variable, not to mention that they are used for entirely different purposes.

Again, I use marine SSB on the ham bands all the time as you do but technically, it's against the rules.

Eric

[fairbank56]

Originally Posted by Viking Sailor

No Eric you are wrong!

You forgot rule 80.203 Authorization of transmitters for licensing

under Subpart E--General Technical Standards


(a) Each transmitter authorized in a station in the maritime services
after September 30, 1986, except as indicated in paragraphs (g), (h)
and (i) of this section, must be certificated by the Commission for
part 80 operations. Transmitters of a model authorized before
October 1, 1986 will be considered type accepted for use in ship or
coast stations as appropriate.

[btrayfors]

Eric,

What is it, exactly, that you don't understand by the phrase, "in the Maritime Service"?

A type-accepted (old term) or "certificated" transmitter for the Maritime Service is NOT IN THAT SERVICE just because it's put aboard a boat. It is, legally, only "in the Maritime Service" if it is installed on a boat which has a valid Ship Station License and is operated by a duly-permitted radiotelephone operator.

If that same radio is sitting at your home or office, it is NOT "in the Maritime Service". If you use it on the amateur radio bands, it is "in the Amateur Radio Service".

Nothing else makes any sense.

BTW, there are radios, like the Yaesu System 600 AKA FT-600, which are "certificated" for maritime, land-mobile, and amateur radio service. Same radio. Just a little plug in the front changes their "certification".

Bill

[hellosailor]

Eric, read what bt said. Again and again until the light bulb turns on.

Radios may be certified for particular service. That JUST means they have been approved for commercial sale to users in that service. That is not a restriction of any kind, except to prevent their sale to other services which require other certifications.

Certified for the Marine Service means "Yes, you may sell this and buyers may buy it, both with the intent of using it without penalty in that service." That's all.

It doesn't forbid all other use, including that of a paperweight, movie set prop, or kiddie toy. It simply authorizes one type of use--for use in commerce, buying and selling for an intended use, mainly.

And the Amateur Radio Service is fairly unique in that it has very different rules designed to encourage amateurs to experiment with electronics. An amatuer radio operator is allowed to take ANYTHING, from a RollsRoyce engine on a 747, to a GE nuclear turbine, to the distress beacon off a UFO buried under Area52 (not 51), and TRY THEIR BEST to make it into a ham radio.

As long as that pile of junk doesn't violate the emissions standards for the Amateur Radio Service, if a ham operator says "this is a ham radio and I'm certifying that it complies" then that operator has the sole responsibility for making it so.

I can take a hearing aid battery and a paper clip and say "this is a spark gap radio, class A0" and (did I get that right bill?) voila, it is a legal ham radio.

You are confusing "limited permissions" as being "implied exclusions" but that's not the rules. You're totally misreading them, and while you are free to continue misunderstanding them, if you still don't get it, I'd suggest calling the FCC. They've got a whole bunch of nice folks who answer toll-free phone lines to explain this stuff.

[Viking Sailor]

Originally Posted by fairbank56

You forgot rule 80.203 Authorization of transmitters for licensing

under Subpart E--General Technical Standards


(a) Each transmitter authorized in a station in the maritime services
after September 30, 1986, except as indicated in paragraphs (g), (h)
and (i) of this section, must be certificated by the Commission for
part 80 operations. Transmitters of a model authorized before
October 1, 1986 will be considered type accepted for use in ship or
coast stations as appropriate.

The general paragraph 80.203 (a) is explained by the more specific paragraph 80.251 (b) to apply to vessels defined by paragraph 80.5 (6). Therefore, lacking an equivalent paragraph, vessels defined by paragraph 80.5 (7) are excluded from the scope of paragraph 80.203 (a).

Furthermore, the comments you made about transmitter frequency adjustments only appear in paragraph 80.203 (b). This paragraph and its subparagraphs only applies to VHF transmitters. There is no equivalent paragraph for MF or HF transmitters. So, yes it is legal for an operator to tune a part 80 certified transmitter to the ham bands.

[fairbank56]

Originally Posted by Viking Sailor

The general paragraph 80.203 (a) is explained by the more specific paragraph 80.251 (b) to apply to vessels defined by paragraph 80.5 (6). Therefore, lacking an equivalent paragraph, vessels defined by paragraph 80.5 (7) are excluded from the scope of paragraph 80.203 (a).

You've got to be kidding me The rules under Subpart E--General Technical Standards including 80.203 apply to ALL part 80 certified transmitters. Subpart F--Equipment Authorization for Compulsory Ships goes on to explain rules specific to equipment on compulsory ships. Just because 80.203 does not specifically mention voluntary installations, does not mean they are excluded It doesn't mention compulsory ships either.

Furthermore, the comments you made about transmitter frequency adjustments only appear in paragraph 80.203 (b). This paragraph and its subparagraphs only applies to VHF transmitters.

Yes, that's why I said "VHF" I was making a point that you totally missed.

There is no equivalent paragraph for MF or HF transmitters. So, yes it is legal for an operator to tune a part 80 certified transmitter to the ham bands.

How about 80.1165 Assignment and use of frequencies, under Subpart X--Voluntary Radio Installations, which again, references subpart H--Frequencies. Amateur radio frequencies are not listed there.

You cannot legally transmit on a part 80 radio outside of it's intended marine channels unless the radio is already capable of doing so as is from the manufacturer (other rules apply in that situation). There are other rules with restrictions under CFR Title 47 that apply to modification of certificated equipment.

80.13 Station license required.

(a) Except as noted in paragraph (c) of this section, stations in the
maritime service must be licensed by the FCC either individually or by
fleet.

97.11 Stations aboard ships. (amateur radio rules)

Stations aboard ships or aircraft.

(b) The station must be separate from and independent of all other
radio apparatus installed on the ship

Nobody really cares if an operator of a voluntary station uses his part 80 certified marine radio on the ham bands, but technically, it is against the rules.

Installing a marine HF-SSB transceiver on a vessel or land does in fact make it a marine station and a station license is required. Get caught without one (extremely unlikely) and you will be heavily fined (extremely likely). Good luck claiming that you don't use it on marine channels. Yes, just having a part 80 radio such as using it for a paperweight does not place it in the marine service. Installing it so that it is fully operational does.

Eric

[Wotname]

[fairbank56]

Originally Posted by btrayfors

BTW, there are radios, like the Yaesu System 600 AKA FT-600, which are "certificated" for maritime, land-mobile, and amateur radio service. Same radio. Just a little plug in the front changes their "certification".

Bill

Well, it doesn't change the certification, it changes the configuration. I'm curious about that rig. Iv'e seen the FT-600 version (amateur radio configuration) which only transmits on ham freq's. Do you have one in the marine configuration? Does it have the FCC part 80 identifier label on it? Can it readily operate on ham as well or do you have to change the configuration plug? If you have a system 600, does it come with the configuration plugs and is it actually certified for all 3 configurations...i.e. FCC label?

Eric