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General Broadcasting Service Questions about FCC comment page

 
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Regulations / Law
Last Post by Thelegacy 8 years ago
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Mark
 Mark
(@mark)
Posts: 2302
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Took a look at this radio Thelegacy mentioned....a little boom box like thing that costs $250US($300 CAD) and sound would be typical of a little thing like that.

For half that price you can get a new Grundig field radio 450 that will have way better performance and WAY better sound. So will any Sangean, GE super, CCrane EP Pro etc.

 


 
Posted : 29/09/2018 7:52 am
Mark
 Mark
(@mark)
Posts: 2302
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As Artisan and I know that here(Canada) with Bets-1 FM is the better way to go and that is already hi-fi and stereo(in mono you get even better range and better hi-fi) so why would we go AM and try to get people to listen and have to get a special $$ radio to get the CCquam? That is if a CQuam transmitter was usable here.


 
Posted : 29/09/2018 8:14 am
ArtisanRadio
 ArtisanRadio
(@artisan-radio)
Posts: 1869
Member Admin
 

I guess what I was trying to say was that, in the U.S. at least, having a CQUAM transmitter doesn't hurt.  It adds to your station's uniqueness.  People can still listen in mono with regular AM radios.  And if you want to hear the full benefits of AM stereo, you can go out and buy a special radio.  Part 15 broadcasting as it was meant to be.  Not a cookie cutter imitation of a licensed station.

Canada is a whole different ball of wax.  You can build an RSS210 or BETS compliant transmitter from scratch, and that transmitter could be CQUAM if you wanted.  That is allowed in the rules.  FM is still the better choice here, though.

And while I fully support a Part 15 broadcaster going CQUAM, you're not going to be able to make that requirement mandatory - at least, in my opinion.


 
Posted : 29/09/2018 12:02 pm
Mark
 Mark
(@mark)
Posts: 2302
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Artisan said....And while I fully support a Part 15 broadcaster going CQUAM, you’re not going to be able to make that requirement mandatory – at least, in my opinion.

Agree!

And even if you designed your own here, you still need the broadcast certificate or get it certified to use it. Quite awhile back I asked about this.

Getting the Sean Cuthbert one for example even though it's a kit wasn't designed by you(general term).  It would have to get approved and if not you would have to get a broadcast certificate or worse $3000 lab fee to use it IF it passes the tests. One of the drawbacks here.

Maybe it could be suggested to  Procaster to make a CQuam version? Certified BETS-1 as well as RSS-210 to get around the broadcasting thing.


 
Posted : 29/09/2018 12:46 pm
 Thelegacy
(@thelegacy)
Posts: 300
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Topic starter
 

Maybe someone in Canada should write Chez Radio with that request.


 
Posted : 29/09/2018 2:18 pm
Mark
 Mark
(@mark)
Posts: 2302
Member Moderator
 

Emailed Chezradio  and when I get a reply I will post the answer.


 
Posted : 29/09/2018 11:34 pm
ArtisanRadio
 ArtisanRadio
(@artisan-radio)
Posts: 1869
Member Admin
 

Mark said "And even if you designed your own here, you still need the broadcast certificate or get it certified to use it. "

I knew that I had researched this previously.  Mark, that is not correct.  Section 7.1.7 of RSS Gen states:

7.1.7 Home‑Built Devices

Except scanner receivers, home built devices (not from a kit) in quantities of five or less, for personal use and not to be marketed, are not required to be certified or labelled by Industry Canada. Home‑built devices must conform to all the technical requirements set out in the applicable standard(s).

So, in Canada, you CAN build your own transmitter, for RSS210 at least, as long as it meets all technical requirements.   Currently, that does mean that if you want CQUAM, you would have to build one yourself, but maybe ChezRadio will come through.

I have not found a corresponding exception for BETS, so you may not be able to build your own, license exempt, transmitter for broadcasting use, unless you get it certified for that use after the fact.


 
Posted : 30/09/2018 5:37 am
Mark
 Mark
(@mark)
Posts: 2302
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Clearly states that it can't be from a kit so the Sean Cuthbert one is out and since we aren't electronic engineers that means nothing to us as we can't homegrow our own.

But BETS-1 says clearly that this wouldn't apply there but like I said for us it doesn't matter.

I would only go AM if, like in the USA, it was the ONLY option. And I don't really care about CQuam.

Tried to post the email I sent to Chezradio but for some reason you can't copy and paste an email here.....that I sent at least. It comes out all scrambled with DIV all over the place but I have posted replies in the past and it worked OK.

 

 


 
Posted : 30/09/2018 6:37 am
ArtisanRadio
 ArtisanRadio
(@artisan-radio)
Posts: 1869
Member Admin
 

There's nothing to stop someone in Canada from using an existing circuit found somewhere else, gathering together the components, and building a CQUAM transmitter.  You don't have to be an engineer to do it.

The reason that exception is there in the RSS rules for unlicensed devices is to encourage experimentation.

Of course, it would be nice if an existing manufacturer, such as ChezRadio, offered a CQUAM option.  The thing to remember, however, is that even the ProCaster is certified under RSS210, so that, theoretically, you're not supposed to use it for broadcasting.  You can use it in the many applications that Industry Canada and the CRTC define as non broadcasting (such as transmitting to an area with fixed property boundaries).

I like the idea of CQUAM.  It makes your radio station somewhat unique, and that's good for a micro broadcaster.  At the end of the day, though, it's programming that will make or break any radio station, licensed or not.


 
Posted : 01/10/2018 1:25 am
 Carl Blare
(@carl-blare)
Posts: 2621
Famed Member Registered
 

Logic & Reason Has Limitations

Artisan Radio comes so close to being right about this: "There’s nothing to stop someone in Canada from using an existing circuit found somewhere else, gathering together the components, and building a CQUAM transmitter."

Unfortunately, yes there is something that would stop someone from using an existing circuit found somewhere else if that "somewhere else" is a kit.

And the same is true in the World's Largest Empire under the FCC.

Which brings us to a gripe I've had for a long time... I believe that building a kit is exactly homebuilding, rendering the exclusion of kits by the regulatory agencies foolish, silly, ridiculous, absurd, dumb, nonsensical, stupid, outrageous and goofy.

I refuse.


 
Posted : 01/10/2018 3:28 am
Mark
 Mark
(@mark)
Posts: 2302
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OK here is the answer I got from Chezradio(procaster) This may come out all scrabled but it can still be read.

I asked about the BETS-1 VS RSS-210......broadcasting and not broadcasting and here's my answer. Mentioned CQuam for Thelegacy but no comment on that.

<span style="font-size: large;">Hi Mark,</span>
<div><span style="font-size: large;"> </span></div>
<div><span style="font-size: large;">When we had the Procaster certified under FCC Part 15.219 (for the US), we simultaneously filed for RSS-210 (Canada's equivalent) it was the same test with parallel paperwork.</span></div>
<div><span style="font-size: large;"> </span></div>
<div><span style="font-size: large;">The Procaster was approved for unlicensed use for <u>any purpose including broadcasting</u> in North America so I don't understand the purpose of BETS-1 or why it would exist for this application.</span></div>
<div><span style="font-size: large;"> </span></div>
<div><span style="font-size: large;"> https://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf01062.html </span></div>
<div><span style="font-size: large;"> </span></div>
<div><span style="font-size: large;"><br clear="all" /></span>
<div>
<div class="yiv8680076501gmail-m_6066716531696852771gmail_signature" dir="ltr">
<div dir="ltr">
<div>
<div dir="ltr">
<div>
<div dir="ltr">
<div>
<div dir="ltr">
<div><span style="font-size: large;">Gerry Herlinger<br clear="none" /></span></div>
<div><span style="font-size: large;">Chezradio Inc.</span></div>
<div><span style="font-size: large;">chezradio.com<br clear="none" /></span></div>
<div><span style="font-size: large;">416-278-0467</span></div>
</div>
</div>
</div>
</div>
</div>
</div>
</div>
</div>
</div>
</div>

Personally I don't think that he has read carefully RSS-210 and where it says for "non broadcasting" and broadcasting is defined. But he brings up a good point, about this grey area of broadcasting.


 
Posted : 01/10/2018 5:06 am
Mark
 Mark
(@mark)
Posts: 2302
Member Moderator
 

Reply to Carl about kits.....AGREE fully.


 
Posted : 01/10/2018 5:16 am
 Thelegacy
(@thelegacy)
Posts: 300
Reputable Member Registered
Topic starter
 

As long as your not running a station for profit and clearly announce the word Hobby it should not draw any unwanted attention!!

Apparently some FCC agents have the same sentiment as the agents who came and visited me clearly expressed when I was talking to them of using AM instead of FM due to the limited legal range I'm allowed to use.  Believe me I talked to the two agents at the house and then when I called David Dombrowski after I got two more copies of the same NOUO one hand delivered from UPS and the other in first class mail telling me I had 10 days I didn't even wait 10 seconds after it was in my hand to pick up the telephone and call the FCC and David said he has the recording on voice mail saying I'd never use FM ever again for anything more than going 10 feet from a smartphone to a Radio in the house or car Radio.

Getting back to AM the agent said I could legally broadcast my Album Rock station on AM so long as I didn't do anything stupid such as attempt to run a transmitter 24 stories with a long ground to earth (Apparently they've been paying attention to what I write on social media).  But here is where the agent told me he has been listening to my Internet station which had ads and clearly commended me for omitting them from the transmissions I maid.  If I had done so on FM I may have been writing to you from a prison library somewhere.  There is a grey law about sending solicitations to a mass audience without a business license and could get me not only in state trouble but Federal according to the electronics engineer from the region one office of the enforcement office in Columbia, MD.  As stated they have tapes of my programming and thought it sounded good.

So possibly Canada is in the same sentiment here and as long as your not advertising with out a business license to do so you should be fine.  But I suggest you call or write to the spectrum management team for your country and ask.  I've heard of no busts in Canada for someone running a Radio station following the field strength rules.


 
Posted : 01/10/2018 6:52 am
Mark
 Mark
(@mark)
Posts: 2302
Member Moderator
 

I haven't either, and "busts" are so rare here that if their is a "pirate" or someone gets shut down it makes the papers....it's news!

I think that if I was on AM using the Procaster which is certified, and use it according to set up instructions as it is certified to be used I don't think the technicality of whether I am broadcasting or not would get me shut down by industry Canada. They may say I need a broadcast certificate if the public is my intention but there's to grey an area here and Artisan knew someone where he was cited for that technicality and when the person informed the agent there is no BETS-1 AM transmitter they backed down.

Non-broadcasting is defined as to the public but to a defined space indoors or out.

Broadcasting is to a non defined space where the general public will hear.

The Procaster is RSS-210 which is for non broadcasting

The MS-100(Decade) is BETS-1 for broadcasting

Crazy! huh! But when I looked up broadcasting in the dictionary it says a signal via radio waves to the general public.

As Gerry from Procaster said, he doesn't understand the purpose of BETS-1 as this was certified for ANY purpose!

All I know is that BETS-1 allowed field strength with the Decade gives me enough to be good enough on FM and if for some reason I can't do FM I will get a procaster and do the same thing I'm doing now.

At least now I am comfortable as I am compliant with all rules here....even with the broadcasting thing.

 


 
Posted : 01/10/2018 7:22 am
 AMRadiolegend
(@amradiolegend)
Posts: 335
Reputable Member Registered
 

OK. Reality Check Time. CQUAM NOT necessary for quality AM broadcasting. Restore transmit audio back to >5KHZ. Restore receiver capability to listen to 10 KHZ audio. MONO with wide audio sounds great. Find an old AM receiver and listen to AM even with the 5KHZ. You will be impressed.


 
Posted : 01/10/2018 10:46 pm
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