Garmin Astro: Legal?

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In general, putting your radio up higher gives you more range because it removes obstructions and other nearby interfering sources of RF. Higher frequencies at a given power level will travel farther in clear air, but they tend to be more susceptible to obstructions because an obstruction of a given size obscures a larger proportion of the radio wave.

The FCC regs account for this behavior, in general they allow the lower frequency bands to use more power than the higher frequencies. When they decide that a given band is going to be used for a handheld communication device, that's when they put the height restrictions on the antennas. They're intentionally limiting the range. They also do the same in many cases by limiting the type of antenna you can use to a single-element "stick" antenna of a given length; this sends out an omnidirectional signal with a limited range.
 
I think is a good place for one you to write an article of clarification in one the sports publications. If you feel so strongly, get it published. Research and get an official from the FCC to give and official statement on the topic.

As for me, if it is illegal in a rocket, it should be illegal on a dog on a mountain top at 10-15000 feet above the valley bellow. It technically should have a stronger effect than the rocket launched that never clears said mountain top.
 
RadManCF said:
I'll give a more in depth explanation. First, according to the FCC site's description of MURS, one can expect a useable range of about 25 miles on the ground. By putting the tracker on your dog, the dog in the car, and driving accross the state, you are not increasing the transmit range, you are merely moving while transmitting. This is legal. Everywhere you go, your transmit distance is in the neighborhood of 25 miles. You only tie up the channel you're transmitting on for a radius of 25 miles. At an altitude of 2000-4000ft I would guess that your transmissions could easilly travel 150 miles, at least. So, you would be tieing up the channel for a radius of 150 miles. True, it's not in the same category as causing physical harm to someone, but it certainly isn't playing fair with other users of the service.
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(150/25)^2= 36 times larger area ... I bet those on dogs 24/7 are using them far more than 36 times as long per week. If you want to talk fairness instead of legality ... I have no interest in using them personally, but....
 
cwbullet said:
I think is a good place for one you to write an article of clarification in one the sports publications. If you feel so strongly, get it published. Research and get an official from the FCC to give and official statement on the topic.
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It's on my to do list.
 
I just think it is more useful to get an official statement form the FCC and publish an article. I suspect that people might get a surprise or 2.
 
troj said:
In a way, I agree with you.


However, someone did that with the California State Fire Marshall, and caused months of grief for the entire rocketry community.


If it's possible to do so without any fallout, beyond getting clarification on specific issues, then it would make sense. Unfortunately, it doesn't necessarily work that way, and there can be other side effects.
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You make a good point Kevin that I hadn't thought about. Sometimes it does NOT pay to be the squeaky wheel. You ask for oil and end up getting greased.

Unless that was your goal all along....

RadManCF said:
It's on my to do list.
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I'm not going to lie, this makes me a little nervous. I think it would be great to have some clarification from the FCC. But you also just told us:

RadManCF said:
....I am so adamant in opposing the use of devices such as the Garmin Astro for rocketry purposes....
Click to expand...

Obviously you are not a neutral party in this discussion. If you are so strongly opposed to the use of MURS in rocketry, it's hard to imagine you would be anything but pleased to have the FCC make a statement against it. And the way in which you word a question or describe a situation can be very leading, and easily incline the recipient to answer one way or the other.

So I'm simply asking you, as a fellow hobbyist, if you do take it upon yourself to bring this question to the attention of the FCC please do so as objectively as possible. Just give the facts, describe when and how and why these trackers are being used, and what the points of disagreement or confusion are. If they decide for whatever reason that such use should be prohibited then so be it. If they decide that such use is fine then even better (wouldn't it be better to have the official blessing of the FCC, put all the concerns to rest and have more options for the hobby instead of less?). If you approach the FCC as a representative of our hobby, please try to represent the best interests of our hobby and don't let any personal vendetta color your presentation.
 
beezwax said:
So I'm simply asking you, as a fellow hobbyist, if you do take it upon yourself to bring this question to the attention of the FCC please do so as objectively as possible. Just give the facts, describe when and how and why these trackers are being used, and what the points of disagreement or confusion are. If they decide for whatever reason that such use should be prohibited then so be it. If they decide that such use is fine then even better (wouldn't it be better to have the official blessing of the FCC, put all the concerns to rest and have more options for the hobby instead of less?). If you approach the FCC as a representative of our hobby, please try to represent the best interests of our hobby and don't let any personal vendetta color your presentation.
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I agree with this 100%. I have discussed this issue with several experts in the communications arena. They have encourage me to reach out to the FCC 2 days ago. I have done that. I requested clarification on the issue. The initial response by email has been reassuring that we would get an answer. I would recommend that you do the same if you have the ability to call. I do not.
 
beezwax said:
You make a good point Kevin that I hadn't thought about. Sometimes it does NOT pay to be the squeaky wheel. You ask for oil and end up getting greased.

Unless that was your goal all along....
Click to expand...

cwbullet said:
I agree with this 100%. I have discussed this issue with several experts in the communications arena. They have encourage me to reach out to the FCC 2 days ago. I have done that. I requested clarification on the issue. The initial response by email has been reassuring that we would get an answer. I would recommend that you do the same if you have the ability to call. I do not.
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One person has contacted them. Let's leave it at that. Multiple inquiries on the same topic, I think, is more likely to generate alarm on their side.

-Kevin
 
beezwax said:
Obviously you are not a neutral party in this discussion. If you are so strongly opposed to the use of MURS in rocketry, it's hard to imagine you would be anything but pleased to have the FCC make a statement against it. And the way in which you word a question or describe a situation can be very leading, and easily incline the recipient to answer one way or the other.
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True. Which is why I'd like to find a co-author for anything I write on this subject. Anyone interested?
 
Since we're all paying our dues to NAR/Tripoli, why don't we have THEM be the official voice of hobby rocketry and contact FCC/FAA on this subject?

I'm not a fan of the "we'll keep doing it until we get caught" mentality. It's asking for trouble. Except for licensed HAM radio units and low-power units in the ISM bands (i.e. BRB900), all of these inexpensive public-use radios are explicitly meant for use on the ground. Unless the regs specifically prohibit it, you CAN use them to transmit location information ONCE YOU'RE ON THE GROUND, but you cannot send transmissions in-flight.

Those cellular dog collars MIGHT be an exception because cellular use on "aircraft" [FAA/FCC clarification required...] IS permitted at the pilot's discretion on GA flights that are under VFR. Although a ballistic unmanned hobby rocket would appear to fit into this definition, it would be a good thing to get a written confirmation.

troj said:
One person has contacted them. Let's leave it at that. Multiple inquiries on the same topic, I think, is more likely to generate alarm on their side.

-Kevin
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Let me see if I am understanding this.

The argument that it is illegal is because of the antenna height above ground rule 60' or 20' higher than the structure and that it cannot be operated from an aircraft with the conflicting rule that it can be used on an aircraft with captains permission. However, the rules are not conflicting because it states that you cannot use it from an aircraft unless you have the captains permission.

As I read the rules and the faqs provided in the links above it seems that the height limits presume a fixed structure to the ground and attaching an external antenna to that structure. Since you are not adding an external antenna then you are not violating a height regulation, the antenna is built into the device. You could also explore the reason for the external antenna is to increase the range of the device. If you are using this device in a rocket for tracking purposes then you are not attempting to extend the range of the transmission.

Next up would be the definition of an aircraft and if a model rocket fits within that definition as intended by the FCC. If you are the captain of your rocket then you would have to give yourself permission to use your device during the rocket flight.
 
beezwax said:
I think this type of discussion reveals a lot about people, and I am not trying to be antagonistic here. For one, it is a completely natural to rationalize or justify a decision (or purchase) that you've made because people don't like having buyer's remorse. I'm going to go out on a limb and guess that most of the folks who wag their finger at Garmin users have bought into an RF tracking system. Everyone is a fan of whatever they've just spent $500 on.

Then there are folks who raise an objection because the law says this period. I am not advocating any criminal behavior. But I would argue that the legality here is not as clearly defined as the one camp would have you believe. If the use of dog-trackers in sport rocketry was clearly illegal and prohibited by FCC regulations then there is no way they would be allowed at sanctioned launches. As it is, they are being used at launches all across the country and thus far there has been no legal action or negative consequence that I am aware of.

In a case of muddled regulations, I think you need to use your brain. If someone can point to an instance when putting an Astro up in the air caused some kind of harm I would be very interested to learn of it. There is no obvious path to harm. I don't think the argument that increasing the altitude increases the range makes any difference. Yes okay, I can also increase the range by putting the collar on my dog, my dog in the car, and driving across the state. How exactly is this harmful? This is also exactly why the comparison to the Rocket City Rednecks is a false analogy, because as other have pointed out in that case there have been some clear safety violations and real-world risk of harm.

So are all the Astro-nauts breaking the law? Maybe, but not in any meaningful way. I enjoy trivia, and one thing I like to learn about are crazy laws that for whatever reason are true and somehow continue to exist on the books. Go ahead and google stupid laws in your state, it's a guaranteed chuckle. Apparently in Washington state it is illegal to buy a mattress or meat of any kind on Sunday. Hamburger on the Lord's Day??? Take him away! You're breaking laws all the time without ever knowing it. It's almost certain you've broken some of the laws pertaining to sexual intercourse in your state, unless you're abstinent. Folks just need to use their heads. If something you're doing could be damaging, then stop.

Full disclosure: yes, I have a Garmin Astro. I am also currently studying for the Ham Technichian license and hope to pass the exam later this month. Not because I feel concerned in any way about using the Garmin, I just want to have more tracking options available to me. The preceding is all merely my opinion. Your opinion will vary.
Click to expand...

I see stuff at sanctioned sport launches at least occasionally that isn't allowed by our own rules. Clearly that must mean the rules don't exist! Amazing!

I really want to see this argument in court sometime. Judges need a good laugh every now and then.
 
You pretty much got it right, remember that these rules are defined in the context of handheld-to-handheld communication devices. FCC doesn't want anybody taking a handheld device and putting a big antenna on top of some building to circumvent the purpose of the intended use. They certainly do NOT intend to keep people from using them in buildings or in the mountains somewhere while camping.

It's obvious that the FCC has really never considered hobby rocketry applications, this is where the grey area come into play. Many years ago the only ISM frequency that was in general public use was 27 MHz, if you look at the Part 95 regs you'll see that one-way telemetry from model aircraft is specifically allowed. It's obvious the regulations in this area have not been reviewed in many years, apparently they're overdue.


mkadams001 said:
Let me see if I am understanding this.

The argument that it is illegal is because of the antenna height above ground rule 60' or 20' higher than the structure and that it cannot be operated from an aircraft with the conflicting rule that it can be used on an aircraft with captains permission. However, the rules are not conflicting because it states that you cannot use it from an aircraft unless you have the captains permission.

As I read the rules and the faqs provided in the links above it seems that the height limits presume a fixed structure to the ground and attaching an external antenna to that structure. Since you are not adding an external antenna then you are not violating a height regulation, the antenna is built into the device. You could also explore the reason for the external antenna is to increase the range of the device. If you are using this device in a rocket for tracking purposes then you are not attempting to extend the range of the transmission.

Next up would be the definition of an aircraft and if a model rocket fits within that definition as intended by the FCC. If you are the captain of your rocket then you would have to give yourself permission to use your device during the rocket flight.
Click to expand...
 
troj said:
One person has contacted them. Let's leave it at that. Multiple inquiries on the same topic, I think, is more likely to generate alarm on their side.

-Kevin
Click to expand...

I see your point. I will post the results when I get them. What I have been told so far is that they need to review laws and regulations. I have been told I will have an answer in 3-4 business days.

I have reviewed the laws and regulations on MURS myself and it is far from clear so I appreciate help from the experts at the FCC. My coms officer had indicated a similar opinion to multiple people on the forum but agrees that the intent was to limit communication and not telemetry or GPS coordinates.

I have been very careful not to direct opinions. I have no agenda. If the Garmin is illegal, I have other means to track my rockets and other uses for my Garmin astro.
 
Chuck, thanks for taking the lead on this. We'll all be waiting to hear back, 3-4 days is pretty quick for the feds.
 
Asking regulatory agency employees for statutory clarity is not necessarily going to garner the black & white ruling on legality you're after... this is reminiscent of similar efforts made by many in the motor-making business who would call and discuss statutory fine points with the BATFE and DOT employees...

With that said, I'm curious to see where this lands...
 
I'm not expecting much of an answer either.

I'm guessing you are going to get rtfm for a response. :D
 
Nerull said:
I see stuff at sanctioned sport launches at least occasionally that isn't allowed by our own rules. Clearly that must mean the rules don't exist! Amazing!

I really want to see this argument in court sometime. Judges need a good laugh every now and then.
Click to expand...

I think the key word in your statement is "occasionally." Yes at sanctioned launches, as well as any other kind of event in which there are rules, sometimes you will find people who are not following them. Not exactly an earth-shaking observation. If the RSO or other launch organizer becomes aware of the rule violation do you think they will move to correct it? Of course they will, or that launch/club/organization isn't going to be around very long.

The point that I was making is that the use of the dog-trackers in rocketry has become quite routine. People are regularly using them at sanctioned launches all across the country, and doing so openly. Certainly enough that NAR and Tripoli are aware of it, and yet to my knowledge there has been no action by either organization to prevent their use. So yes I think it's safe to conclude that this practice at the very least is not "clearly illegal" as some had suggested.

I know a lot of judges, and for the most part they do seem to enjoy a good laugh. But there was no logical fallacy in my argument, at least nothing illuminated by your comment. But thanks for chiming in :wink:
 
RadManCF said:
True. Which is why I'd like to find a co-author for anything I write on this subject. Anyone interested?
Click to expand...

I'd be happy to work with you on this if no one else volunteers, because I think the hobby needs an answer. However I also feel as Kevin said that we should wait for their response to Chuck since he has already contacted them. A sudden hail of inquiries can only raise eyebrows and cause alarm.
 
As cerving indicated a few posts ago NAR or Tripoli should take the lead on this.
 
The FCC is usually quite direct in their answers. I suggest we wait till Chuck gets his answers. No sense speculating until then.

Bob
 
Thanks guys. There are strong feelings on both sides. I currently just want to get it right when I am at the RSO table.
 
beezwax said:
I'd be happy to work with you on this if no one else volunteers, because I think the hobby needs an answer. However I also feel as Kevin said that we should wait for their response to Chuck since he has already contacted them. A sudden hail of inquiries can only raise eyebrows and cause alarm.
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PM sent.
 
It's unrealistic to expect an RSO to monitor trackers. The RSO's job is safety
 
troj said:
It's unrealistic to expect an RSO to monitor trackers. The RSO's job is safety
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It doesn't strike me as unrealistic. Espeecially since the safety code changes that took effect in August. If the RSO is supposed to verify that the ejection charges are disarmed, checking on what kind of tracking device is installed in the rocket doesn't take much more effort.
 
mkadams001 said:
As cerving indicated a few posts ago NAR or Tripoli should take the lead on this.
Click to expand...

It may not be Tripoli, but at least one Prefecture has taken action:

Tripoli Minnesota Board of Directors said:
Rocketeers,

The Tripoli Minnesota Board of Directors has recently discovered a regulatory complication with regards to the use of the Garmin Astro GPS system.

It has come to our attention that the use of the MURS (Multi-Use Radio Service) band for telemetry purposes in an aircraft (yes, model rockets are considered aircraft) is against FCC regulations.

In order to protect Tripoli Minnesota and its members, Tripoli Minnesota unfortunately can no longer support the Garmin Astro system for rocket tracking.

The Board of Directors is investigating and researching other alternatives for GPS tracking.

If you would like more information please do not hesitate to contact myself, or any other Tripoli Minnesota Board member.

The Board of Directors sincerely apologizes for any inconvenience this may cause.

Cordially,

Steve Anderson on behalf of the Tripoli Minnesota Board of Directors
Click to expand...
 
I wonder how Tripoli Minnesota is dealing with BP, igniters and ematches? Are they checking everyone who uses them for LEUP's?

Tony
 
tonka said:
It may not be Tripoli, but at least one Prefecture has taken action:
Click to expand...

Well that is actually the first time I've read of any club or section taking a stance on this, thank you for adding that info to this discussion. I'm really curious to hear what the FCC response is to Chuck's request for clarification....
 

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