ES Exercise Simulated Victim Using FRS/MURS/Amateur Radio?

[RADIOMAN015]

I'm looking at incorporating into an ES exercise in the future a simulated search victim using a Family Radio Service portable radio to call for simulated help during the mission.  Select CAP aircraft would be equipped with an FRS radio (along with an earphone) and would monitor for the call & respond to the victim.  I believe ES exercises should teach us how to think out of the box and utilize alternative radio systems in emergency conditions.

This is sort of the "poor man's" emergeny radio, versus buying A PLB.  However, the simulated search victim did tell his spouse that he would have an FRS Radio and would be on channel 1 (462.5625 mhz) no CTCSS/DCS code employed. 

My understanding is that with an aircraft flying at around 5K that the signals can easily be heard for over 30 miles.

Has anyone else did any experimentation on using a portable radio in an aircraft and having someone call from the ground using:
FRS ? http://en.wikipedia.org/wiki/Family_Radio_Service
MURS ?  http://en.wikipedia.org/wiki/Multi-Use_Radio_Service
VHF/ UHF Amateur Radio (146, 222, 440 mhz) (simplex frequencies)?
http://www.dxer.com/bandplan.html

Do you think that the outcome of some searches would have resulted in a quick discovery with the use of the "poor man's" radio system and prevented undue suffering & even death?

Could CAP be an advocate in first emphasizing the importance of buying or renting a PLB, but also as an alternative use the "poor man's" radio with appropriate disclaimers.

Could the James Kim tragedy in Oregon 2006 have had a different outcome with the use of a simple poor man's radio?
http://en.wikipedia.org/wiki/James_Kim

RM 

[lordmonar]

We cannot use non-CAP frequencies for ES training.

However......you can give your simulated victim an ISR radio and have one in your aircraft.

The ISRs are in the same frequency range as the FRS and are of the same power range....so it would be a good simulation of searching for someone who has an FRS radio.

[JoeTomasone]

We cannot use non-CAP frequencies for ES training.

However......you can give your simulated victim an ISR radio and have one in your aircraft.

The ISRs are in the same frequency range as the FRS and are of the same power range....so it would be a good simulation of searching for someone who has an FRS radio.

Except that ISRs are not permitted in flight.

[wuzafuzz]

100-1 does allow limited Emergency Services FRS use.  Section 9-12 a states in part:  "If it is believed that the victims or search target may be carrying FRS, ES personnel MAY use FRS in an attempt to contact the victims directly."   It is reasonable to conclude training in that use would be permissible.   

That section goes on to say "FRS will not be used for communications between ES personnel or for any other manner of ES communications support."  If your practice target is not a CAP member you run no risk of running afoul of that provision.

Here's the catch:  can we only allow ground teams to use FRS?  Section 9-12 b discusses other permissible uses of FRS in CAP.  That section prohibits airborne use, but it's not clear to me whether that also applies to the limited ES uses described in the previous section.  There may be non-CAP regulations addressing that question.   

Presumably "use" means transmitting.  I can't imagine that merely listening would be an issue.  Still, if we can hear the subject of a search, it's a huge stretch to think we wouldn't answer a real call for help.  I would answer even if I were airborne, and let the CAPTalk lawyers debate it!

BTW, 100-1 Section 9-11 is very clear that ISR's may not be used in flight.  So ISR's would not be an acceptable stand-in for FRS if you operate from an aircraft.

[arajca]

Use of FRS to contact victims is acceptable. That change resulted from a mission a couple years ago when a CAP aircrew (in SW COWG) used one to make contact with a lost party of ~12.

Use of FRS to talk to ourselves during ES missions, is not. That's what ISRs are for.

[RADIOMAN015]

Use of FRS to contact victims is acceptable. That change resulted from a mission a couple years ago when a CAP aircrew (in SW COWG) used one to make contact with a lost party of ~12.

Use of FRS to talk to ourselves during ES missions, is not. That's what ISRs are for.

IF a CAP member is the simulated victim it stands to reason that one would use the radio system that the potential real victim would use, so that the practice exercise is as real as possible and would give experience to air crews in what they could expect from FRS radio communications range to include potential inteference due to significant use by others.
RM

   

[lordmonar]

We cannot use non-CAP frequencies for ES training.

However......you can give your simulated victim an ISR radio and have one in your aircraft.

The ISRs are in the same frequency range as the FRS and are of the same power range....so it would be a good simulation of searching for someone who has an FRS radio.

Except that ISRs are not permitted in flight.

Neither are FRS....so then the exercise is moot.

[davidsinn]

We cannot use non-CAP frequencies for ES training.

However......you can give your simulated victim an ISR radio and have one in your aircraft.

The ISRs are in the same frequency range as the FRS and are of the same power range....so it would be a good simulation of searching for someone who has an FRS radio.

Except that ISRs are not permitted in flight.

Neither are FRS....so then the exercise is moot.

Can the DF gear in the aircraft be tuned to FRS freqs? If so you could still have a ground based radio simulate someone in distress and the airplane can at least listen and possibly DF.

[MSgt Van]

Have them transmit on 121.75 from a hand held aviation radio. DF'r will hear that.
I guess that wouldn't jive with your requirement unless your hikers carry aviation gear.

[CFI_Ed]

Can the DF gear in the aircraft be tuned to FRS freqs?

Nope.

[davidsinn]

Can the DF gear in the aircraft be tuned to FRS freqs?

Nope.

That sucks. Just have to use a hand held scanner and attempt to body block I guess.

[Spaceman3750]

Can the DF gear in the aircraft be tuned to FRS freqs?

Nope.

That sucks. Just have to use a hand held scanner and attempt to body block I guess.

I recall a few years ago someone told me the new Little L-Per (cheeseblock) can DF FRS transmissions (only good for ground DF but it's better than nothing). That was a long time ago however so my recollection may be off.

On another note I find it very unfortunate that our regulations are written in ways which prevent us from training for real-life scenarios.

[davidsinn]

Can the DF gear in the aircraft be tuned to FRS freqs?

Nope.

That sucks. Just have to use a hand held scanner and attempt to body block I guess.

I recall a few years ago someone told me the new Little L-Per (cheeseblock) can DF FRS transmissions (only good for ground DF but it's better than nothing). That was a long time ago however so my recollection may be off.

On another note I find it very unfortunate that our regulations are written in ways which prevent us from training for real-life scenarios.

Blame the FCC and FAA.

[RADIOMAN015]

We cannot use non-CAP frequencies for ES training.

The ISRs are in the same frequency range as the FRS and are of the same power range....so it would be a good simulation of searching for someone who has an FRS radio.

Except that ISRs are not permitted in flight.

Neither are FRS....so then the exercise is moot.

Family Radio Service is license by rule by the FCC.  There's no regulation that prevents the use of the FRS radios in flying aircraft.

I don't recall seeing in CAP regulation that states that an FRS radio can't be used in a CAP aircraft.  (BTW This already has been tested by a CAP member in a private aircraft with no affect on airband radio comms).  The individual made the mistake while talking to the ground station by stating he was airborne & than all heck broke loose because anyone hearing him on an FRS radio tried to call him.

I think it is a resonable exercise that would have minimum transmission from the aircraft.  In fact I would run the exercise with a good idea of geographically where the "injuried" hunter had stated he/she would be in to a relative.  When the aircraft was close to the area the simulated injuried hunter hearing the aircraft would call out and the aircraft would answer.  After the discovery and team response & treatment.  Ground personnel would then just have some continous voice transmissions as the aircraft flew away to get a good idea as to furtherst range of receipt.

Everyone in ES (ground or air) needs to learn how to "think out of the box" and experimenting with relatively inexpensive communications devices is reasonable and could be very effective.   Now personally I would also like to run an exercise with an FRS radio actually being dropped from an aircraft -- but that would really be pushing the envelope beyond CAP's acceptable risk level.     
RM   

[MSgt Van]

I think the FAA would be the governing reg, not a CAPR. I'm sure they have an approved equipment list, and unless it's certified, no go in the airplane...

[lordmonar]

Anyone know why IRSs are specifically forbidden for in flight use?

The FAA rule is pretty lenient and open for interpretation.

§ 91.21   Portable electronic devices.
(a) Except as provided in paragraph (b) of this section, no person may operate, nor may any operator or pilot in command of an aircraft allow the operation of, any portable electronic device on any of the following U.S.-registered civil aircraft:

(1) Aircraft operated by a holder of an air carrier operating certificate or an operating certificate; or

(2) Any other aircraft while it is operated under IFR.

(b) Paragraph (a) of this section does not apply to—

(1) Portable voice recorders;

(2) Hearing aids;

(3) Heart pacemakers;

(4) Electric shavers; or

(5) Any other portable electronic device that the operator of the aircraft has determined will not cause interference with the navigation or communication system of the aircraft on which it is to be used.

(c) In the case of an aircraft operated by a holder of an air carrier operating certificate or an operating certificate, the determination required by paragraph (b)(5) of this section shall be made by that operator of the aircraft on which the particular device is to be used. In the case of other aircraft, the determination may be made by the pilot in command or other operator of the aircraft.

Emphasis mine.

[wuzafuzz]

I really don't see this as a choice to make, we should do it.  It's an emergency.  After all, who wants to tell the family of a missing hiker that we won't even try to raise their loved one on an FRS radio?  Just imagine the heyday the news media would have with that.  Game over man. 

Of course this assumes we have a clue which channel the missing hiker might be using.  Also remember that FRS radios have less range than our VHF handi-talkies, especially in and around foliage.  An FRS equipped ground team is far less likely to make contact with our hiker than an aircrew. 

Absent an FCC or FAA rule, which no one has found, that absolutely prohibits FRS use in an airplane then we should train for this.  If anyone finds a CAP rule prohibiting this, it should be changed YESTERDAY.

[lordmonar]

But 100-1 absolutely forbids us to use the IRS in flight and absolutely forbids us from using FRS in ES training.

We can use FRS during a real search....but we have no way to train for the eventuality.   

Rock.....Hard Place.  Hard Place....meet rock. 

[RADIOMAN015]

But 100-1 absolutely forbids us to use the IRS in flight and absolutely forbids us from using FRS in ES training.

We can use FRS during a real search....but we have no way to train for the eventuality.   

Rock.....Hard Place.  Hard Place....meet rock. 

I don't think anyone in CAP is going to loose sleep over an exercise using the FRS radio specifically as follows:  The CAP ground team is talking to the aircraft using a CAP channel e.g. AIR 1 and the aircraft is guiding the team to the simulated victim.  Another aircrew member is talking to the simulated victim on an FRS radio.  When the ground team gets close enough they could also talk with the simulated victim using FRS radio.  The FRS radio is not used by the teams for intra team communications.

BTW generally FRS channel 1 (462.5625 mhz) without any tone settings is considered the unofficial calling channel.  It will also likely have the most user on it because when you put the batteries into the portable it defaults to this channel with most equipment.    Any of the 14 channels could be picked.   Many of the FRS radios have channel scan mode and also some have the capability to find the tone being used also.    BTW some FRS radios have scramble capability (voice inversion).

IF anyone conducts an FRS radio exercise please post a summary of your results.         
RM

[wuzafuzz]

From 100-1 Section 9-12 (a)  "One exception to the prohibition against ES use of FRS is when attempting to contact victims or the objects of a search.  If it is believed that the victims or search target may be carrying FRS, ES personnel MAY use FRS in an attempt to contact the victims directly.  FRS will not be used for communications between ES personnel or for any other manner of ES communications support."  Emphasis mine.

Have a non-CAP member play the victim.  As long as CAP ES folks aren't talking to each other, you're good.  Also note that 9-12 (a) does not exclude a practice search.  It just says a search.

Section 9-12 (b) allows simulated ES messages over FRS, but suggests that occurs in a communications class.  It also says FRS should not be used while airborne. 

Does subsection (b) trump subsection (a)? Or vice versa? Or does each stand alone?  It seems odd to prohibit training for permitted search activities.  A memo from NHQ clarifying these points would be helpful, followed by an appropriate change to 100-1.

[EMT-83]

Amateur radio use is prohibited, but is considered fair game in an emergency. Do you extend the need for training into that arena as well?

[lordmonar]

RM says ignored the rule
Wazafuzz says break another rule so we can circumvent the first rule.

[Al Sayre]

From 100-1 Section 9-12 (a)  "One exception to the prohibition against ES use of FRS is when attempting to contact victims or the objects of a search.  If it is believed that the victims or search target may be carrying FRS, ES personnel MAY use FRS in an attempt to contact the victims directly.  FRS will not be used for communications between ES personnel or for any other manner of ES communications support."  Emphasis mine.

Seems like this would allow you to use it for a practice mission

[wuzafuzz]

RM says ignored the rule
Wazafuzz says break another rule so we can circumvent the first rule.

Whoa boy!  First, I pointed out potential opportunities in THE RULES and instances were those same RULES seem to be in conflict with other RULES.  Muddy at best. 

Second, most communicators are aware the FCC is pretty darn lenient about communications related to actual emergencies.  That's not carte blanche to do whatever a person wants, which is why I also suggested obtaining a "ruling" from NHQ and having any unnecessarily restrictive CAP rules changed. 

Third, 100-1 9-12 (a) defines exceptions to the remaining rules on FRS use, while the following section (b) defines the normally acceptable uses.  It seems reasonable to me that operating within those exceptions is not breaking or circumventing any rules.  Again, ask NHQ and let them clear it up.  That should prevent concerns about being sneaky, overly creative, or flat-out breaking of the rules.

Ultimately our job, in a search scenario, is to help people.  We can't do that if we "outlaw" reasonable actions in the course of the search.

Please be careful with the accusations.   

[wuzafuzz]

Amateur radio use is prohibited, but is considered fair game in an emergency. Do you extend the need for training into that arena as well?

Since you mention it, why not?  Are there any rules preventing a ham radio operator from coming along for a ride and using THEIR radios? 

If I recall correctly, our regulations say that person can't be a CAP member signed in to the mission, and may not talk to CAP people on the ham radio.  As long as we obtain necessary approvals for giving them al lift, I'm not aware of a reason it couldn't work.  We took local sheriff's SAR team members on flights during a SAREX I planned.  National allowed that. 

Drag out the quotes from 100-1 and duke it out!  Let's learn from this discussion.   

[a2capt]

Since you mention it, why not?  Are there any rules preventing a ham radio operator from coming along for a ride and using THEIR radios? 

We have discussed that very thing, and seen it in action. Having a representative from amateur radio, preferably a CAP member, but not signed into the mission in any capacity, as part of the Op Plan.  Particularly out in the west where we have terrain interference .. it makes things a bit more challenging and with practically every other agency using some form of amateur radio assistance and CAP being on the flip side, you basically have to have someone in the 'shack with you.

[lordmonar]

9-11. Intra-Squad Radios (ISR). ISR radios are authorized for all CAP units and activities, except that they must NOT be utilized in flight. Only radios specifically manufactured for the ISR service (currently available only from ICOM) are authorized and they will not be modified in any way, including the addition of external antennas or amplifiers. Because these radios operate only on federal frequencies, personal use of ISR radios is prohibited. For this reason, wings will develop policies regarding personal purchase of these radios that will ensure they are not resold or used outside of CAP. Wing DCs have the information needed to purchase these radios directly from ICOM America.

9-12. Family Radio Service (FRS). While use of ISR is preferred, the use of FRS radios is authorized IAW NTIA Regulations section 7.5.8. FRS radios are authorized for all CAP units and activities not directly supporting Emergency Services (actual missions and training). Emergency/disaster response, medical communications, and command and control communications are examples of emergency services functions which are prohibited from using FRS.
a. Limited Emergency Services FRS Use. One exception to the prohibition against ES use of FRS is when attempting to contact victims or the objects of a search. If it is believed that the victims or search target may be carrying FRS, ES personnel MAY use FRS in an attempt to contact the victims directly. FRS will not be used for communications between ES personnel or for any other manner of ES communications support.
b. Permissible FRS Use. Some examples of permissible FRS activities would include encampments, air shows, fund raisers, model rocketry, conferences, meetings, and non-direct mission supporting activities of a similar nature. They would also be ideal as a hands-on training tool for communications classes such as demonstrating how to call other stations, transmitting and receiving formal traffic and simulated ES radio traffic. Do not use FRS radios while airborne.
c. All FRS radios and operations must meet FCC Part 95 rules, including the necessity of using FCC-certified FRS equipment. FRS radios must not be modified in any way, and modified/illegal FRS radios are subject to confiscation by the FCC.

9-15. Limited Support for Amateur Radio Training. In CAP units making use of Amateur Radio as a unit training activity, corporate radio equipment which is no longer NTIA compliant, and therefore is no longer authorized for operational missions, may be used on amateur frequencies, with advance permission from National Headquarters requested via wing and region headquarters. Equipment used for this purpose shall have all CAP frequencies and/or frequency determining elements removed. At no time shall Amateur Radio frequencies be used in conduct of Civil Air Patrol business or missions, IAW para 11-2. Operation on amateur radio frequencies requires an FCC-issued amateur radio license.

11-2. Use of Amateur Radio Service by CAP. CAP members acting in any CAP capacity may not use amateur radio frequencies on behalf of CAP.
a. When the Civil Air Patrol conducts operational missions for the Air Force, it functions as an "instrumentality of the United States", IAW CAPR 20-1, para 4. Because CAP uses federal frequencies managed by the NTIA and assigned to the Air Force, CAP is defined as a federal frequency user, regardless of the customer." Under federal law and regulation, instrumentalities of the United States and federal frequency users are prohibited from encroaching on civilian frequencies regulated by the Federal Communications Commission, including amateur radio frequencies.
b. FCC rules prohibit conducting the business of any organization on amateur radio frequencies for pecuniary (financial) interest. Because CAP members receive Federal Tort Claims Act (FTCA) insurance and Federal Employee Compensation Act (FECA) insurance, CAP members have pecuniary interest while signed in to Air Force tasked missions and have the status of a federal employee.
c. Where amateur radio third party traffic is needed to support a CAP mission, CAP communication managers may seek the support of local amateur radio clubs and organizations. CAP members who are licensed amateur radio operators and who are not acting in any CAP capacity (e.g. not signed into a mission) are not prohibited from exercising their amateur privileges and supporting affiliated amateur organizations using privately owned amateur equipment.
d. Amateur radio frequencies shall not be programmed into corporate radios, including those purchased with local assets, except as provided in para 9-15.

Here are the appropriate reg citations.

By my read.....we can't use ISRs in flight, we can't FRSs for training.

We can pass CAP messages on amateur frequencies and CAP member can do it.....but we skirt a legal/regs issue if we set up a training scenario where CAP members are not signing in just so we are meeting the letter of the law.

Asking non CAP HAM operators to "ride along" is opening up a big can of worms that I don't know if we really need to go there.

[blackrain]

I've wondered about FRS radio use as a way to contact persons in distress myself. Lot of people including whole families have them. Naturally the legalities have to make things complicated.

While we don't do much in the offshore rescue business the potential for having to do so does exist and the same capability with marine radios would be a good thing to have. The ability to find (by the GPS chip or DF) a specific cell phones in an emergency and at law enforcement behest could really be a lifesaver too.

Strictly hypothetical and the very large legal issues would have to be addressed by those way above my paygrade. I wouldn't think it would be to much of a technical issue though.

[davidsinn]

I've wondered about FRS radio use as a way to contact persons in distress myself. Lot of people including whole families have them. Naturally the legalities have to make things complicated.

While we don't do much in the offshore rescue business the potential for having to do so does exist and the same capability with marine radios would be a good thing to have. The ability to find (by the GPS chip or DF) a specific cell phones in an emergency and at law enforcement behest could really be a lifesaver too.

Strictly hypothetical and the very large legal issues would have to be addressed by those way above my paygrade. I wouldn't think it would be to much of a technical issue though.

We have a gentleman out west that can turn cell phone data around in a matter of hours. His is based of the towers so it's not as precise as GPS but if we had the GPS in the first place we wouldn't even be called.

[RRLE]

Absent an FCC or FAA rule, which no one has found, that absolutely prohibits FRS use in an airplane then we should train for this.

95.192 (FRS Rule 2) Authorized locations expressly allows the use of FRS in aircraft.

(a) Provided that you comply with these rules, you are authorized to operate an FRS unit:

(3) Aboard any vessel or aircraft registered in the United States, with the permission of the captain, that is within or over any area of the world where radio services are regulated by the FCC or upon or over international waters;

The CAP prohibition on FRS may deal with a now obsolete NTIA rule. NTIA not the FCC governs the use of frequencies by federal agencies. At one time the NTIA rules expressly forbid the use of FRS by government agencies. That is the prime reason DOD got the ISR service. The NTIA relented and now government agencies may use FRS. I researched this a while back for the USCG Aux. The Aux also banned FRS and only allowed IRS useage, which is almost not found in the Aux. I recommended the Aux change its policy vis-a-vie FRS but they never did.

[blackrain]

I've wondered about FRS radio use as a way to contact persons in distress myself. Lot of people including whole families have them. Naturally the legalities have to make things complicated.

While we don't do much in the offshore rescue business the potential for having to do so does exist and the same capability with marine radios would be a good thing to have. The ability to find (by the GPS chip or DF) a specific cell phones in an emergency and at law enforcement behest could really be a lifesaver too.

Strictly hypothetical and the very large legal issues would have to be addressed by those way above my paygrade. I wouldn't think it would be to much of a technical issue though.

We have a gentleman out west that can turn cell phone data around in a matter of hours. His is based of the towers so it's not as precise as GPS but if we had the GPS in the first place we wouldn't even be called.

I was thinking more in terms of areas too remote for reliable coverage by towers. I should have been more clear. Granted coverage is constantly improving as more towers are added. I've been in some areas in Arizona that felt like the dark side of the moon as far as cell coverage.

[wuzafuzz]

Asking non CAP HAM operators to "ride along" is opening up a big can of worms that I don't know if we really need to go there.

The other points have already been beat into the ground and are currently tunneling.  However, I am curious, what can of worms is opened by taking hams along for a ride?