May I share with you a big idea that could generate cash for the “Part 15 Fund.” A moment ago I praised kc8gpd for the beautiful photo of his AMT-5000, and a few seconds after that I heard me talk about building my AMT-5000 on the “Winter Solstice Edition of Blare OnAir,” and it hit me all at once.
Until today kits have been common place for Part 15 low power projects, but what about full power radio? Maybe there are engineers who get bored purchasing ready made transmitters. What if we got together and made the world’s first “50,000 Watt AM Transmitter Kit”?
Huh? You with me on this?
Sufferance of kits
The word “sufferance” was used in another recent thread. If you really want to know what sufferance means, consider the FCC’s policy on Part 15 kits. An FCC OET KDB publication explicitly states that uncertified transmitter kits are illegal. I will not link the publication here, but it is linked on the Rangemaster home page. Kits are the principal competition for certified Part 15 AM transmitter manufacturers because they are much cheaper than certified transmitters.
Kits are officially not permitted by the FCC, but they are allowed by “sufferance” because of the FCC’s long-standing refusal to enforce their own rule.
Carl’s “proposal” of a 50 kW transmitter kit is an exaggerated jest, but any new transmitter kit, even one compliant with Part 15, would be in legal jeapardy because it would be only allowed by sufferance.
The Brand
That could be the brand.
A SUFFERANCE-5000
No Way Around
The design would still have to be Part 73 certified, and if anyone thinks it will be cheaper or the same cost to certify this flamethrower kit versus a flea kit, better think again.
So..who has the initial up-front investment capital to lead us all, joined by the hands taking that big leap off the cliff saying “We Can’t Wait”?
I would guess we would require about 10 to 15 million in start up capital.
Please fill out the form, press firmly as you are making multiple copies (120) and mail to….
…oh we need a company mailing address….and a name might help too. :p
RFB
That could be the brand.
A
That could be the brand.
A SUFFERANCE-5000
That’s real cute! What’s more, I actually think it’s a good idea!
Kits are officially not permitted by the FCC, but they are allowed by “sufferance” because of the FCC’s long-standing refusal to enforce their own rule.
Why do you think that is? Why does the FCC not enforce it?
Wrong
15.25 Kits.
A TV interfaces device, including a cable system terminal device, which is marketed as a kit shall comply with, etc. ……..
The section on kits DOES NOT apply to either low or high powered AM transmitters.
OET KDB Publication 927445
http://apps.fcc.gov/oetcf/kdb/forms/FTSSearchResultPage.cfm?id=20992&switch=P
Educational Experience
Ermi Roos thank you for your re-direction of attention to the earlier rule which makes a different case for the legitimacy of kits.
Not just for me, but for everyone who follows these threads, the further study provided by this rule will be educational.
I am now busy reading the publication.
Vague
This one is wide open to a shot in the dark:
“All other devices subject to Certification (whether marketed as a Kit or not), must be certified under Subpart J of Part 2.”
RFB
Recital
Having studied the submission from Ermi Roos…..
“Section 15.25 defines the requirements for marketing of a kit for a TV Interface Device. As described in Section 15.23, individuals are permitted to construct a device for personal use without seeking equipment authorization from the Commission, but it may not be marketed as a kit. All other devices subject to Certification (whether marketed as a Kit or not), must be certified under Subpart J of Part 2.”
….. the rule states that an individual who builds a device may not distribute it as a kit, but the rule does NOT restrict a firm, business, corporation or company from developing or distributing a kit.
Devices subject to Certification include only fully built devices.
Individuals
“the rule states that an individual who builds a device may not distribute it as a kit, but the rule does NOT restrict a firm, business, corporation or company from developing or distributing a kit.”
Well aren’t firms, businesses and corporations considered individuals now???
Can’t have it both ways. :p
RFB
Parsing Publicarion 927445
Section 15.25 has rules about the marketing of TV interface device kits, but no other types of kits.
Section 15.23 allows the home construction of up to five devices for personal use only, and not for sale. Only devices built from scratch (not from kits) are covered by 15.23.
The Office of Engineering and Technology provides interpretations of the FCC rules that govern equipment authorization issues. These interpretations are replies to frequently asked questions from the public. In Publication 927445, “all other devices subject to certification” refer to those devices not covered by either 15.25 or 15.23, such as transmitters not constructed from scratch at home that are intended to comply with 15.219.
Up And Down, Left And Right, Forward And Backwards
Am I the only one seeing that incredible loophole that favors the prosecution??
Cmon people….LOOK!
RFB
Loophole that favors the prosecution?
Maybe you mean that the rules and their official interpretations are such that the FCC can be even more restrictive than they are now in practice without even having to change the rules. That is true, and it is the point I tried to make about “sufferance.”
The FCC has been allowing kits for a very long time, and, in practice, they treat kits as if they were home built devices built from scratch under 15.23 (although 15.23 specifically excludes kits). The FCC seem to encourage hands-on work done by hobbyists to some extent, and that may be why they are allowing kits.
Hobbyists, especially young hobbyists, are the ones who eventually become technicians and engineers, and there would be a natinal interest aspect to encouraging hobbyists (Methinks. I am only speculating about why the FCC is behaving as it is).
Spot On
“Maybe you mean that the rules and their official interpretations are such that the FCC can be even more restrictive than they are now in practice without even having to change the rules.”
That and it is open to very wide parameters of interpretation, both in a court and out.
It seems that by declaration..which would be dependent upon interpretation…a transmitter kit intended to fall under one part, can end up falling under another part at will..or on a case by case basis.
We can see that the FCC encourages hands-on experimentation and learning. But they are also putting a serious cap limit on that learning and experimenting, and what people can experiment with, and how many etc etc.
No doubt we are fortunate to have what we have to work with even though those regulations are in need of a precise regulator themselves so they put out the right accurate information.
“Hobbyists, especially young hobbyists, are the ones who eventually become technicians and engineers, and there would be a national interest aspect to encouraging hobbyists”
Yes most “tinkerers” at the younger ages become engineers and technicians. If they follow their path of discovery and limits set by nothing else but one self’s own imposed limits, these future engineers and technicians who are now tinkerers will learn the ropes and know what it takes to send a clean signal versus a garbage signal. Basically knowing how to do things the right way.
But does that curve or eventual position of an engineer or technician allow for continuing the discovery and learning curves after they fill some job position? Or is there really that much more for them to learn under the current limitations of the experimental prospective under Part 15?
Is Part 15 where it ends at? Should it end there, or a whole new service be enacted and under its own part of the whole.
I think that if a person can demonstrate the technical ability to operate a station with several watts of power and prove it is not causing interference, is not causing complaints, is not causing problems for other local broadcasters, then that person should be given authorization to operate that station with a certificate or license if you will, which authorizes that higher power of 10 watts or less.
Proof is in the pudding. So far the efforts to thwart LPAM radio service provides absolutely no proof whatsoever that an LPAM radio service would bring the world to an end, like the NAB wants everyone to believe, or that fleets of airplanes will come falling out of the sky or the local ambulance service wont get the emergency call or fire department or police department wont hear that call.
Over-stating the issue as well as reading too much into something that does not even exist to begin with.
A person who is serious about broadcasting to their community will take every step necessary to meet technical standards to avoid any problems and would not have a problem taking those steps to attain a clean operation. Many now have taken those steps to meet the limits etc with these flea power systems. Granted we have seen a few “over-done” setups where they got tagged, but they knew they were violating a specific rule and should have taken the steps necessary to prevent the problem all together from the onset.
I think it is this kind of thing..the bleh passive attitude in some that the FCC has taken into account that keeps things the way they are. Knowing there are “flakes” out there who just throw on a signal not caring if its knocking out emergency services radio or interfering with the ILS approach system at the nearby airport or wreaking havoc with a marker somewhere or filling up the band with junk and jamming phones, is the very reasons why there is no LPAM or even a real LPFM service to which it was originally intended for, is non-existent.
If the FCC had a different prospective from different data input by those who are serious about broadcasting on a community level, and do away with these special interest groups gobbling up licenses and frequencies left and right only to broadcast the same junk as the channel below and above, there may be some light at the end of the very long and very dark tunnel of a true low power licensed community radio service.
RFB