REF: FCC REGULATIONS ABREVIATED VERSION
There has been some confusion about the legality of using hobby or model
R/C frequencies and equipment for promotional robots or other vehicles for sale or for
hire. In fact, the only problem has been a few robot companies who sell or operate robots
on frequencies assigned for model AIRCRAFT use only.
I don't want you, me, or your customer to be in violation of the law.
After reviewing the law we believe that R/C operations of robots for sale,
lease, or hire and paid performances are all legal without complicated licensing. Vantec
can supply legal type accepted 8 through 44 channel radio control equipment on 75 MHz as
required. You should confirm our understanding with a qualified FCC attorney.
Here are some extracts and notes from FCC regulations pertinent to Robot construction
Vantec comments in bold italics. Part 95
Subpart C-Radio Control (R/C) Radio Service
95.201 (R/C Rule 1) What is the Radio Service?
The R/C Service is a private, one way, short distance non-voice communications service
for the operation of devices at remote locations.
95.202 (R/C Rule 2) How do I use these rules?
(b) Your R/C station must comply with technical rules found in Subpart E of Part 95.
(c) Where the rules use the word "you", "you" means a person
operating a R/C station.
(d) Where the rules use the word "person", the rules are concerned with an
individual, a corporation, a partnership, an association, a joint stock company, a trust,
a state, territorial or local government unit, or other legal entity. ....
(f) Where the rules use the term "R/C station," that means a radio station
transmitting in the R/C Radio Service.
95.204 (R/C Rule 4) Do I need a license?
You do not need an individual license to operate an R/C station.
(a) Your R/C station may transmit only on the following channels (frequencies):
(1) The following channels may be used to operate any kind of device, including a model
aircraft device (any small imitation of an aircraft) or a model surface craft device (any
small imitation of a boat, car, or other vehicle for carrying people or objects, except
26.995 MHz .... ....27.255MHz
(2) The following channels may only be used to operate a model aircraft device: 72.01
MHz... ...72.99 MHz
(3) The following channels may only be used to operate a model surface craft devices:
(b) You must share the channels with other R/C stations. You must cooperate in the
selection and use of the channels. You must share the Channel 27.255 MHz with stations in
other radio services. There is no protection from interference on any of these
(c) Your R/C station may not transmit simultaneously on more than one channel in
the 72-76 MHz band when your operation would cause harmful interference to the operation
of other R/C stations.
(f) Stations in the 26-27 MHz range are not afforded any protection from interference
caused by the operation of industrial, scientific of medical devices....
(g) Stations in the 72-76 MHz range are subject to the condition that interference
will not be caused to the remote control of industrial equipment operating on the same or
adjacent frequencies or to the reception of television transmissions on Channels 4 and 5.
These frequencies are not afforded any protection from interference due to the operation
of fixed and mobile stations in other services assigned to the same or adjacent
95.209 (R/C Rule 9) What equipment may I use at my R/C station?
(a) Your R/C station may transmit only with:
(1) An FCC type accepted (or type approved) R/C transmitter.
VANTEC - It appears the FCC regards 72 Mhz and 75 MHz in the same band. Type
accepted transmitters may be adjusted to 75 MHz by qualified certified
persons, like Vantec. Alternatively, Futaba equipment with certain plug-in transmitter
modules is available on either 72 Mhz for multi-channel units marketed to the aircraft
modelers and 75 Mhz for 3 channel units marketed to surface model modelers.
However, the module design, and more importantly, the FCC transmitter approval number,
is the same. FCC ID on Futaba FP-7UAP and FP-8UAP 72MHz transmitters are: AZPFP-TP-FM-72A.
Therefore by judicous purchasing Vantec can supply 8 or more channel equipment with
75MHz modules, despite Futaba marketing policies.
(2) A non-type accepted R/C transmitter on Channels 26.995-27.255 MHz .....etc
(b) You may examine a list of type accepted transmitters at any FCC field
(c) Your R/C station may transmit with a transmitter assembled from a kit.
(d) You must not make, or have made, any internal modification to a type-accepted
transmitter. (See R/C Rule 22) Any internal modification to a type-accepted transmitted
cancels the type-acceptance, and use of such a transmitter voids your authority to operate
VANTEC - Later, in Subpart E transmitter is defined as the portion or module
converts electrical energy into RF energy. I interpret this to mean I can legally modify
the non RF encoder portions of the transmitter to add the Keykoder.
95.210 (R/C Rule 10) How much power may I use?
Channel Transmitter power(carrier power)(watts)
... 72-76 Mhz...........................0.75 .....
95.211 (R/C Rule 11) what communications may be transmitted?
(a) You may only use your R/C station to transmit one-way communications. (One-way
communications are transmissions which are not intended to establish communications with
(b) You may only use your R/C station for the following purposes:
(1) The operator turns on and/or off a device at a remote location (Refer to Diagram
(2) A sensor ....
(c) Your R/C station may transmit any appropriate non-voice emission.
VANTEC - This means unique FM modulation and codes, such as developed by Futaba
are OK as long as sideband emissions are limited according to law, subpart
E. It means adding a Keykoder is not illegal because Vantec Keykoder designs always
operate within the framework of the approved transmitters encoder.
95.212 (R/C Rule 12) What communications are prohibited?
You must not use an R/C station-
(f) To transmit data. Tone or other signal encoding, however, is not considered to
be data when only used either for the purpose of identifying the specific devices that the
operator intends to turn on/off, or the specific sensors among multiple sensors intended
to turn on/off indicating device for the operator.
95.213 (R/C Rule 13) May I be paid to use my R/C station?
(a) You may not accept direct or indirect payment for transmitting with an R/C station.
(b) You may use an R/C station to help you provide a service, and be paid for that
service, as long as you are paid only for the service and not for the actual use of the
VANTEC - You can rent your R/C robot at a trade show.
95.214 (R/C Rule 14) Who is responsible for R/C communications I make?
You are responsible for all communications which are made by you from an R/C
95.221 (R/C Rule 21) How do I have my R/C transmitter serviced?
(a) You may adjust an antenna to your R/C transmitter and you may make radio checks. (A
radio check means a one-way transmission for a short time in order to test the
(b) You are responsible for the proper operation of the station at all times and are
expected to provide for observations, servicing, and maintenance as often as may be
necessary to ensure proper operation. Each internal repair and each internal adjustment to
an FCC type accepted R/C transmitter (see R/C Rule 9) must be made in accord with the
Technical Regulations (see subpart E). The internal repairs or internal adjustments should
be performed by or under the immediate supervision and responsibility of a person
certified as technically qualified to perform transmitter maintenance and repair duties in
the private land mobile services and fixed services by an organization or committee
representative of users in those services.
VANTEC - I read this to mean an internal adjustment can include a crystal change
within the proscribed band. An experienced electronic engineer is tantamount
to certification of a person technically qualified.
95.222 (R/C Rule 22) May I make any changes to my R/C station transmitter?
(a) You must not make or have anyone else make an internal modification to your R/C
VANTEC - Transmitter here means the module which converts the electrical energy
into RF energy which can be radiated.
(b) Internal modification does not include:
(1) Repair or servicing of an R/C station transmitter (see R/C Rule 21, 95.221);
(2) Changing plug-in modules which were type-accepted as part of your R/C
.... Subpart E-Technical Regulations
95.601 Basis and Purpose
These rules provide the technical standards to which each transmitter (apparatus that
converts electrical energy received from a source into RF (radio frequency) energy capable
of being radiated) used or intended to be used in a station authorized for any of the
Personal Radio Services must comply. They also provide requirements for obtaining type
acceptance of such transmitters. The Personal Radio Services are the GMRS (General Mobile
Radio service), the R/C/ (radio Control Radio Service), and the CB(Citizens Band Radio
Service). For operating rules for R/C see ...part 95; subpart C.
95.603 Type Acceptance required....
95.605 Type Acceptance procedure...
95.607 CB transmitter modification...
95.623 R/C transmitter channel frequencies
(a) The R/C transmitter frequencies ....
(as in Subpart C)
(c) All R/C transmitters capable of operation in the 72-75 MHz band... marketed
after March 1993, must be maintained within a frequency tolerance of .002%
95.627 Emission types
(b) An R/C transmitter may transmit any appropriate non-voice emission which meets
the emission limitations of 95.631.
95.629 Emission bandwidth
(a) The authorized bandwidth(maximum permissible bandwidth of a transmission) for
emission type H1D, J1D, R1D, H3E, J3E or R3E is 4 KHz. The authorized bandwidth for
emission type A1D or A3E is 8 KHz. The authorized bandwidth for emission type F1D, G1D,
F3E or G3E is 20 KHz.
(b) The authorized bandwidth for any emission type transmitted by an R/C transmitter
is 8 KHz.
95.631 Unwanted radiation
(a) In addition to the procedures in part 2, the following requirements apply to each
(b) The power of each unwanted emission shall be less than TP(Transmitter Power at
antenna terminals) as specified:
...for the 72-75 MHz R/C band sub-paragraphs 1,10,11,12, ... for transmitters marketed
after March 1, 1993.
(1) At least 25 db on any frequency removed from the center of the authorized
bandwidth by more than 50% up to and including 100% of the authorized bandwidth.
(10) At least 45 db on any frequency removed from the center of the authorized
bandwidth by more than 100% up to and including 125% of the authorized bandwidth.
(11) At least 55 db on any frequency removed from the center of the authorized
bandwidth by more than 125% up to and including 250% of the authorized bandwidth.
(12) At least 56 +10 log10 (TP) db on any frequency removed from the center of
the authorized bandwidth by more than 250%.
95.633 Modulation standardize...
95.635 Maximum transmitter power
... (3) 0.75 W in the 72-76 MHz frequency band.
95.641 Control accessibility
(a) No control, switch or other type of adjustment which, when manipulated, can result
in a violation of the rules shall be accessible from the transmitter operating panel or
from exterior of the transmitter enclosure.
(b) An R/C transmitter which incorporates plug-in frequency determining modules
which are changed by the used must be type accepted with the modules. Each module must
contain all of the frequency determining circuitry including the oscillator. Plug-in
crystals are not considered modules and must not be accessible to the user.
VANTEC - You cannot attempt changing crystal to get to 75MHz operation. It must be
done by someone certified as above. Tuning is required.
95.643 R/C transmitter antenna
The antenna of each R/C station transmitting in the 72-75 MHz band must be an integral
part of the transmitter. The antenna must have no gain..