SSB vs HAM

[Dsanduril]

Originally Posted by jeremiason

I m not trying to be argumentative, so please don't assume that.

Wasn't/not, and likewise. I find it an interesting conversation.

Does the Icom M802 come from the factory with that setting, or does it come from your dealer? I know with my dealer he was willing to make the programming changes (and I think some dealers that deal with the sailing crowd almost do this without asking).

The M802 can be opened up to operate on non-marine bands but as far as I know that is not how Icom delivers it. If you search "SSB" on the Icom Americas website it is the first thing that comes up in the knowledgebase:

Icom America - Knowledge Base Article 57DG1541A3

But, the official specs from Icom are:

Frequency coverage (unit: MHz)
Rx: 0.5– 29.9999 (continuous)
Tx: 1.6– 2.9999, 4.0– 4.9999, 6.0– 6.9999
8.0– 8.9999, 12.0– 13.9999, 16.0– 17.9999
18.0– 19.9999, 22.0– 22.9999, 25.0– 27.5000

With a note on the general specs "Wide band receive coverage (0.5 – 29.9999MHz) [bold added].

I think Icom is dancing the two-step gracefully. They don't list the amateur bands in the transmission specifications, and yet their own website contains information on how to get around that limitation.

[btrayfors]

For heavens sake, many posts in this thread suggest that the 802 is the only radio which can be "opened" for both ham and marine use. THAT SIMPLY IS NOT THE CASE.

Virtually all marine SSB units can be "opened" to ham use, and most ham SSB radios can be "opened" in order to transmit on the marine SSB bands. Or the aviation bands. Or the military bands. Or the land mobile bands. Or the firefighter, railroad, and other HF bands.

Problem is, both of the "opening" actions can lead to ILLEGAL operation if you choose to TRANSMIT (not receive) on a band for which the radio was not type-certificated (that's the FCC term these days).

jeremiason: you've said several times in this thread that the 802 has been approved by the FCC for operation on both the marine and the ham bands.

I believe that is NOT true. And, I'd like to see any proof you might have -- aside from early advertisements -- that the FCC has actually approved the 802 for such use.

NOTE that is IS possible for the FCC to approve individual radio designs for use in more than one service. They have done so with certain VHF radios. And, I believe, they have effectively done so with one chameleon HF radio which with the proper "dongle" can be converted for marine, ham, or land mobile services.

But, to my knowledge, NO OTHER HF MARINE RADIO HAS RECEIVED "TYPE ACCEPTANCE" OR "CERTIFICATION" FOR USE IN SERVICES OTHER THAN THE MARINE HF SERVICE FOR WHICH IT WAS DESIGNED.

Furthermore, even if a radio such as the 802 were to have received FCC "certification", it would be illegal under the FCC's own Part 97.11 rules to use it for both ham and marine services, since it would violate the "separate and apart" stipulation of the rules for Amateur Radio,.

Bill
WA6CCA

[Dsanduril]

Originally Posted by btrayfors

For heavens sake, many posts in this thread suggest that the 802 is the only radio which can be "opened" for both ham and marine use.

I don't think anyone has been suggesting that the 802 is the "only" radio that can be operated in this way. It just serves as an example of a radio that is physically/electrically capable, that is programmed in software with restrictions, that has easy ways to remove these restrictions, and that is readily available and used frequently in cruiser's installations (at least new ones).

There is no "type-certification" in amateur service, that is whole point of the amateur service. So, barring regulations previously posted, you could have a type-certified marine radio and also run the same radio on amateur frequencies because type certification is not required there. And type certification does not preclude a radio from being capable of operating on other frequencies (see 47 CFR part 80.203 posted earlier). As an amateur you can build your own radio out of duct tape and biling wire, as long as it meets the emissions requirements it is legal and no type certification is required. Dual-purpose or dual-use has nothing to do with the capabilities of the physical equipment and everything to do with regulation.

[btrayfors]

Well, not quite.

ALL radios sold commercially in the U.S. require FCC approval. You cannot just market any radio.

It's true that you can build your own -- and as a ham of more than 40 years I've built my fair share -- and these don't require any FCC approval. But, you must not "cause harmful interference".

Yes the 802 is just an example. But, you could as well have used just about ANY marine radio...the 802, the 710, the 710RT, the 700Pro, the 700, the TKM-707, the System 600, the later SEA series....any of them. The point is, just about any marine radio can be "opened up" and programmed for both marine and ham use. I do it all the time, and at any given time I have more than 20 HF radios in stock: ham, marine, land-mobile, military.

I believe that "opening" and "programming" a radio -- ham or marine -- for potential use on both marine and ham bands is a good idea to be ready for possible emergency situations, wherein "any means" may be used to attract attention and get help. It's very good for listening and learning, too. That's why I do it for myself and my clients.

However, I certainly don't advocate using a single radio in both services, though many sailors do so, seemingly without a thought or a clue.

Bill
WA6CCA

Originally Posted by Dsanduril

I don't think anyone has been suggesting that the 802 is the "only" radio that can be operated in this way. It just serves as an example of a radio that is physically/electrically capable, that is programmed in software with restrictions, that has easy ways to remove these restrictions, and that is readily available and used frequently in cruiser's installations (at least new ones).

There is no "type-certification" in amateur service, that is whole point of the amateur service. So, barring regulations previously posted, you could have a type-certified marine radio and also run the same radio on amateur frequencies because type certification is not required there. And type certification does not preclude a radio from being capable of operating on other frequencies (see 47 CFR part 80.203 posted earlier). As an amateur you can build your own radio out of duct tape and biling wire, as long as it meets the emissions requirements it is legal and no type certification is required. Dual-purpose or dual-use has nothing to do with the capabilities of the physical equipment and everything to do with regulation.

[Dsanduril]

Sorry, my fingers went faster than my brain. Meant to say "there is no type certification requirement" in amateur service.

Radios for sale commercially have to meet certain requirements whether marine or HAM.

However, any marine SSB radio that can be opened to operate on the amateur bands can be used by a licensed amateur to transmit on the amateur bands. If it is not certified for that use then it is up to that amateur to ensure that it meets the FCC and ITU requirements. Doesn't matter what the manufacturer said or what service they applied for, in the amateur service it is up to each operator to determine that their radio meets requirements. Even so, still can't use the radio for dual service.

[hellosailor]

Generally speaking?
Few if any ham radios, made and accepted expressly for sale in the amateur service, are technically capable of being certified for use in the marine service. Without going geek...there are technical requirements like distortion limits and distortion caused by the radio, which ham units simply CANNOT meet, that marine units require tighter control over.
A friend of mine had a classic Drake radio, back when Drake supplied the State Department and other government customers with communications for the embassies overseas. They were also popular on commercial fishing boats, where the joke was that everyone knew who was using a Drake, because the audio sounded too damned good for a marine radio. Yes, there are exceptions to every rule.

An amateur is legally allowed to transmit on the ham bands with a sardine can and home-made crystals, if he can do it and do it within the technical requirements. But any other licensee on any other service? If you have to ask, the odds are you're cruising for one of the FCC's exclusive $10,000 congratulatory notes. And unlike Publisher's Clearing House, they're only set up to receive.

[Dockhead]

Originally Posted by Dsanduril

So what about this (from part 97 US HAM regulations), that you seem to ignore in recommending an M802 combined HAM/SSB?

That's the rule. It has nothing to do with the type of radio. It prohibits playing around as a radio amateur with a ship's regular radio on the amateur bands. I think the idea is you are not allowed to compromise availability of a crucial marine radio by doing ham stuff on it. It should really not apply to vessels not falling under GMDSS obligations to carry marine HF, but it does. Maybe it'Snot enforced. But it is definitely illegal, at least according to the letter of the law, to use your primary marine SSB for ham stuff.

[Dockhead]

Originally Posted by Dsanduril

Wasn't/not, and likewise. I find it an interesting conversation.

Does the Icom M802 come from the factory with that setting, or does it come from your dealer? I know with my dealer he was willing to make the programming changes (and I think some dealers that deal with the sailing crowd almost do this without asking).

The M802 can be opened up to operate on non-marine bands but as far as I know that is not how Icom delivers it. If you search "SSB" on the Icom Americas website it is the first thing that comes up in the knowledgebase:

Icom America - Knowledge Base Article 57DG1541A3

But, the official specs from Icom are:

Frequency coverage (unit: MHz)
Rx: 0.5– 29.9999 (continuous)
Tx: 1.6– 2.9999, 4.0– 4.9999, 6.0– 6.9999
8.0– 8.9999, 12.0– 13.9999, 16.0– 17.9999
18.0– 19.9999, 22.0– 22.9999, 25.0– 27.5000

With a note on the general specs "Wide band receive coverage (0.5 – 29.9999MHz) [bold added].

I think Icom is dancing the two-step gracefully. They don't list the amateur bands in the transmission specifications, and yet their own website contains information on how to get around that limitation.

I'm guessing -- purely guessing, but I've never read anything to contradict it -- that it might be illegal for Icom to sell a radio for amateur use which is not certified for that, but that it is not at all illegal for a licensed ham to snip a diode or enter some key sequences, and make it work on amateur bands. A licensed amateur can, with perfect legality, build his own radio, and use it all he likes, as long as he respects the bandwidth limits and doesn't cause harmful interference, can't he? Then why would he be doing anything wrong to modify some apparatus to make it work on the ham bands?

Anybody have any further insight into that?

A similar query:

It is illegal to sell a radio in the EU without a CE mark, which is why my M802 is supposedly illegal on my British flagged vessel. But is it, really? Illegal for me to use it? Or just illegal for someone to sell or install it? Those are two different things! I would also be really interested if someone has any concrete information about that.

And one last query to the radio sages of this forum:

The FCC rules clearly forbid the commingling of ham and marine HF operation on the ship's primary radio. But the FCC rules don't apply to me on a British flagged vessel in European waters! Are there similar rules in European countries? I am guessing that, unfortunately, this is a basic GMDSS concept and that the same rule exists everywhere, but I would be very curious to know the facts.

[Dsanduril]

Dockhead,

see my post #50. In the US absolutely nothing stopping a licensed amateur from buying a commercial marine SSB and modifying it to operate on the amateur frequencies. That's what amateur radio is all about. The operator then needs to "certify" that the radio is operating within regulatory limits. Continuing to use it as a marine SSB on the same boat...

I've done a bunch of CE export from the US. My understanding, it is illegal to sell anything "manufactured" without the mark. Use and operate, a different story. I could be way off base there, a very esoteric and bureaucratic area of study I wonder where that leaves the second-hand market? Is there a date for grandfathered second-hand items? Lots of stuff in Europe that was around before CE.

I've been searching for the answer to the question of whether the commingling is a US peculiarity or an ITU/GMDSS thing. So far nothing, would also love to hear if someone else has an answer.

[Cheechako]

I think the F C C checking if your radio is being used as intended is about as likely as a traffic cop checking to see if your smog valve is working properly on your car......

[hellosailor]

dockhead, the answer to most of your questions becomes obvious when you put the questions in context:

" A licensed amateur can, with perfect legality, build his own radio, and use it all he likes, as long as he respects the bandwidth limits and doesn't cause harmful interference, can't he? Then why would he be doing anything wrong to modify some apparatus to make it work on the ham bands? "
You really meant to say "A licensed amateur can, with perfect legality, build his own radio for use in the amateur radio service". Right?
So when that amateur opens up a maritime service radio, that would be illegal since he's not authorized to tamper with maritime radios. He needs a commercial license for that. As soon as that ham opens up the maritime service radio, it becomes a ham radio and further use in the maritime service would be illegal. Technically.

Same case for your Icom without the CE mark. The CE mark is not required for US flagged vessels even if they are operating in the EU. It is not required for US licensees. It is required for...what, perhaps installation of an EU licensed maritime radio station on an EU flagged vcessel? And that's the answer then.

Sometimes the difference between a US and an EU versioned radio is that the preset band limits are different. Or the programmed channels are different. And the mark signifies mainly that particular radio will be "safe" for appliance operators, who don't know what the limits are standards are, because they expect they have been programmed into the radio. Again, as a practical matter? If you don't commit any sins, you're not likely to be bothered about it.
You might want to confirm the model differences with Icom, and make sure that won't be a problem. Or, if the programming is just a matter of clipping a program wire, have that done, so your radio matches the operating parameters for your station license.

dsanduril-
"I wonder where that leaves the second-hand market?" Usually the regulations are very clear about that. If the EU does the same as the US on this, the regulations are specific to commercial manufacturers marketing their own goods, i.e. the radio must be accepted/certified/whatever before it can be marketed or sold for a particular service. With no provision applying to individuals or second-hand merchants who have not manufactured their own goods, and are not necessarily selling them for a particular service.
Some of the Chinese sell lots of UHF/VHF radios into the US without FCC approval this way. While they're bought and used by hams, the makers don't advertise the radios for any service, don't market them to any service. They just say "We have radio, it work this frequency" and they get away with it. (Which must really piss off the legitimate companies that have paid dearly for FCC conformation.)

[Cheechako]

My TS450S was very simple to open iup for the marine bands. As I remember it was just a matter of opening up the back panel and removing a little "bridge" held with two screws. What you have to watch out for using a Ham radio for Marine SSB is that many of the Marine SSB channels are Duplex... meaning they send and receive on different frequencies.

[goboatingnow]

Dockhead. A condition of your ships station license is the radio is ETSI type approved radios , as marked by the CE symbol or alternatively the European MED ( ships wheel mark )

Furthermore its illegal in Europe to put into service any radio not so marked. Bizarrely it is not illegal to sell it

Many many things can be legally sold that are illegal to use. Radios being a classic case.

Note that US flagged vessel located in European waters is subject to local radio regulations including radio fitment. As I stated many times before Flagging does not convey any sort of diplomatic immunity. However the rules of comity apply and are so applied by all progressive nations.

The icom 801E was brought out to implement a full class D MF/HF set, which the 802 cannot do.

Dave

[s/v Jedi]

Originally Posted by Dockhead

Hear, yes, but you will not be able to transmit on ham bands on an unmodified marine SSB set, and vice versa..

I believe an unmodified Icom 802 SSB can transmit on HAM bands.

[Dockhead]

Originally Posted by goboatingnow

Dockhead. A condition of your ships station license is the radio is ETSI type approved radios , as marked by the CE symbol or alternatively the European MED ( ships wheel mark )

Furthermore its illegal in Europe to put into service any radio not so marked. Bizarrely it is not illegal to sell it

Many many things can be legally sold that are illegal to use. Radios being a classic case.

Note that US flagged vessel located in European waters is subject to local radio regulations including radio fitment. As I stated many times before Flagging does not convey any sort of diplomatic immunity. However the rules of comity apply and are so applied by all progressive nations.

The icom 801E was brought out to implement a full class D MF/HF set, which the 802 cannot do.

Dave

It looks like there is no rule in the UK (at least) that you must not use a maritime radio set for ham operation. This is what the relevant document says:

Ship Radio Guidance Notes for Licensing
19

. Use of amateur radio stations on
board UK licensed ships
.
The establishment and use of amateur radio stations on board United
Kingdom licensed ships is permitted under the Amateur Radio Licence, grant
ed by Ofcom. On board a vessel, the licensee shall: a) install, use or make changes to the station only with the written permission of the vessel’s master;
b) observe radio silence when required by the vessel’s master.
.
The full terms, provisions and limitations with which the licensee shall comply with are available from Ofcom. See Section .
.
It is important to ensure that radio is used correctly. At sea, lives may depend upon this. Consequently, there are severe penalties for not keeping within the law and these include fines, imprisonment and the forfeiture of anything used in connection with the offence. Those convicted of such offences may, in addition, face the revocation of their licence and the suspension of their Authority to operate.

http://licensing.ofcom.org.uk/binari...dio/of168a.pdf

The same thing appears in the Licence Conditions for UK amateurs: http://www.rsgb.org/books/extra/Adva...Conditions.pdf

Don't see any prohibition on using the same equipment for marine and amateur use!


On the other hand, I am screwed because every single piece of radio equipment on board my boat was brought from the US and lacks the CE mark. According to the Ofcom document it is forbidden both to sell and to "put into service" any radio equipment (including AIS and EPIRBs) lacking the CE mark, unless it was bought prior to the rule etc.