Here's something from FCC OCE 1973 on Part 15 AM.
The 1972 version however (last time I looked) is nowhere to be found, not even in the national archives of the FCC techical branch (which isn't surprising), but it's time to try again cause I'm certain the other was not available online or in the archives a year or so ago either.
Documents get added to Google Books all the time, but what's strange is the copy didn't arrive there from some college archives or something, it came from the FCC itself, but I know they didnt used to have it because I converse with their curator several times a year, and it wasn't there (nor atrociously is Docket 5335)
Anyway, now it will downloadable from google in a day or two.
Uh... appears we kind of drifted from Canada.
So, was there no "part 15" broadcasting in Canada before 1993 or was there? - I'm still not sure.
The biggest difference between FCC and Canadian rules, imo, is not broadcasting vs non broadcasting, but the existence of the Radio Equipment List (or REL) in Canada, and the way that the rules are enforced.
In the U.S., certification basically means nothing in terms of compliance with the rules. It only means that the certified device can be sold within the country. The FCC can issue summons, particularly under the Pirate Act, without even seeing your transmitter, and whether it is certified or not. Basically, you're assumed to be guilty until proven innocent.
In Canada, an uncertified device cannot be used, period. Never mind sold. All certified devices must also be in the Canadian REL, again, to be used. The very first thing that an ISED agent will question is whether the device you're using is in the REL, and certified. If it is, then unless the device has been modified, or you're interfering with a licensed station, or doing something equally silly (such as attempting to compete with a licensed station), then it's likely they will leave you alone. Here, certification, and placement in the REL, is the important thing.
And if you think about it, this makes the most sense, particularly for FM. Unless you spend lots of money on test equipment, you don't know if your FM field strength is above the limits. And there are lots of things that will unknowingly boost your field strength, including audio/power cables, antenna orientation, the surface the transmitter is placed on, even weather. And you can't rely on range to determine compliance, as range is highly subjective, never mind totally dependent on the characteristics of the receiving device. If an FM transmitter is certified, then that should be the end of the discussion. Period.
Part 15/RSS210 AM is a different story, as even the least technical user should be able to use a ruler and measure the length of a ground lead + antenna.
@richpowers But RSS-210, the other license free part of Canada's no license rules doesn't specify any particular purpose the transmissions were meant for...just any application, and the AM rules we have the same as the USA that can get you up to a mile in range just turning it on and tuning the ATU isn't just for yourself, to stay in a certain boundary, as my arguments with Artisan were about. BETS(ultra low power announce) was never meant for a neighbourhood radio station, anymore than RSS-210. In the current RSS GEN which is all the fine print about everything attached to RSS-210 like I said at the beginning of this thread, there is nothing specifically about intended use/programming or all this about private property or not or bounded areas as we have discussed here before.
If it was there in past versions it is not there now.
BETS-1 has definite purposes mentioned by the CRTC which overlooks programming and being a radio station/sounding like one is not in the intent(intent, a very important word), of a low power announce transmitter intended to get messages to the public about a property, business, event etc., and the CRTC reserves the right to make you get a broadcast certificate if it is used for which it was not intended....like a radio station, which you won't get!
Non of this is mentioned with RSS-210.
In my mind the Procaster is perfectly legal to use to do what I/we are doing. Even more than BETS-1....certified legal, in my own home, or my own property, and 100mW with a 3 meter antenna gets to the general public for a mile around! Not exactly for "personal" use.
@mark Does RSS-210 actually specify it's only for "personal use"?
I can only guess the answers to all these issues are clarified in one or more of the documents found in the CRRT "Exceptions" to licencing catagory that I linked to a few comments back.
If it correct that RSS-210 did not exist prior to the early 1990s, then it's likely the rules had been created and influenced by the FCCs across the board revisions of part 15 here in the states around the same time that had been enacted to simplify and streamline the part 15 rules due to the rapid expansions of technology and potential use of unlicensed frequencies.
But really... I still think there must have been some form of part 15 in Canaa before that.
This Radio Standards Specification (RSS) sets out the certification requirements for several types of licence-exempt radio apparatus. Radio apparatus covered by this standard are primarily low-power and are mainly used for consumer or commercial purposes.
Interesting I found the FM radio band in there too. I thought that was a bit different than AM as far as the rules.
@richpowers You asked "Does RSS-210 actually specify it's only for "personal use"?
No it does not! Unlike BETS-1 RSS-210 does not specify any particular purpose for the transmissions or whether for personal use or not. Same as part 15. It does say for any application. All of this about a bounded area/private property is not mentioned. I raked my brain yesterday trying to find in RSS general what I have heard from Artisan for years. The Talking Sign, which was certified RSS-210 and was intended for getting messages to the general public, same as BETS-1. Go figure. The Talking Sign was the predecessor to the Procaster AM.
I have to stop listening to Artisan and go by what I see with my own eyes.
Since we are talking about Canadian "part 15"..
I didn't recall any stories about college Canadian carrier current stations or about them ever being a member of IBS, so I looked for some and here's a very interesting story about them.. Originally they were licensed operations. Below are the most interesting excerpts in relation to the topic at hand..
Our Story
The First Stations
Campus radio was born in Canada in 1922 on the campus of Queen’s University in Kingston, Ontario. Begun as an electrical engineering experiment, this station, CFRC, remained Canada’s only licenced campus station until CJUS-FM at the University of Saskatchewan was licenced in 1963.
During the 50s and 60s, campus radio clubs began on many campuses across the country. They were.. ..restricted to closed-circuit operations on their campuses....
..The Ontario Association of Campus Broadcasters (OACB) was the first of several Ontario based campus radio organizations. Formed in 1971, one of its main aims was to act as a lobby force in dealing with the CRTC...
...One of the first problems the OACB addressed itself to was the question of distribution. At that time there was no established procedure for carrier current applications and several campus stations considered carrier current to be a better (and cheaper) distribution method than closed circuit. The OACB commissioned Professor Janisch, from the Faculty of Law at the University of Western Ontario, to prepare a brief to be submitted to the CRTC on the subject of a special licence for carrier current. Professor Janisch submitted his report to the CRTC in the summer of 1971. The CRTC issued a policy statement on student carrier current on May 4th, 1972. Despite its ambitious aims, the OACB lasted only one year...
...In November 1972, at the Canadian Entertainment Conference held in Kitchener, Ontario, a meeting was held with representatives of campus radio stations from across the country to discuss concerns and ideas of campus radio in Canada... ...As a result of that meeting, a national campus radio magazine called CCR (Canadian Campus Radio) was set up and mailed to all campus stations across the country... ...Six issues were sent out before it stopped publication in late 1973.
In the fall of 1977, representatives of five Ontario campus radio stations met in Hamilton to discuss the formation of new provincial campus radio organization. In April 1978, the Ontario Campus Radio Organization/l’Organization de Radio Campus d’Ontario (ORCO) came into being...
...community radio in Canada did not begin until 1974/1975 when four stations, CFRO-FM Vancouver, CINQ-FM Montreal, CKCU Ottawa, and CKWR-FM Kitchener began operation. The late start was due primarily to the fact that in Canada, community radio stations must depend on donations from listeners for financial support.
Community radio in Quebec began to grow in 1975...
...As campus radio organizations evolved through the 1970’s, the nature of campus radio stations changed. Only two campus stations held on-air licences at the beginning of the 1970’s – CFRC at Queen’s University and CJUS-FM at the University of Saskatchewan. By the beginning of the 1980’s, FM stations could be found on campuses in Winnipeg, Guelph, Hamilton, Waterloo, Ottawa, London, Quebec City, and Fredericton. Priorities have shifted away from carrier current and closed circuit systems to Cable FM and Low Power FM. The need for campus radio organizations, both on a regional and on a national level, was greater then than it had ever been in the past.....
The First NCRC and the National Campus/Community Radio Organization
In February 1981, the first National Campus Radio Conference (NCRC) was held in Ottawa, Ontario at Carleton University, with 120 representatives from campus and community radio stations from across the country. The CRTC’s FM Radio Policy of 1975 had recently allowed campus and community radio onto the FM band for the first time, and most in this group were either hopeful or very new broadcasters. At that conference, the National Campus/Community Radio Organization (NCRO) was formed to exchange ideas, share experiences, and work on networks to promote campus radio across Canada...
....The CRTC is open to communication with anybody, including all stations, however, as individual stations our opinion was only our own and was not necessarily a reflection of the needs and wants of other stations, even similar stations in comparable markets.
In August 1983, the third annual conference was held at Concordia University in Montreal where the delegates voted to formalize the structure of the NCRO further...
The National Campus and Community Radio Association
At NCRC ’84 (Vancouver) and NCRC ’85 (Fredericton), plans for incorporation were discussed and bylaws for the organization were drafted. In July 1986 the NCRC was incorporated as the National Campus and Community Radio Association Inc./ L’Association nationale de radios étudiantes et communautaires Inc. ..
"..The Ontario Association of Campus Broadcasters (OACB) was the first of several Ontario based campus radio organizations. Formed in 1971, one of its main aims was to act as a lobby force in dealing with the CRTC... ...One of the first problems the OACB addressed itself to was the question of distribution. At that time there was no established procedure for carrier current applications and several campus stations considered carrier current to be a better (and cheaper) distribution method than closed circuit. The OACB commissioned Professor Janisch, from the Faculty of Law at the University of Western Ontario, to prepare a brief to be submitted to the CRTC on the subject of a special licence for carrier current. Professor Janisch submitted his report to the CRTC in the summer of 1971. The CRTC issued a policy statement on student carrier current on May 4th, 1972. Despite its ambitious aims, the OACB lasted only one year...
...In November 1972, at the Canadian Entertainment Conference held in Kitchener, Ontario, a meeting was held with representatives of campus radio stations from across the country to discuss concerns and ideas of campus radio in Canada... ...As a result of that meeting, a national campus radio magazine called CCR (Canadian Campus Radio) was set up and mailed to all campus stations across the country... ...Six issues were sent out before it stopped publication in late 1973.
In the fall of 1977, representatives of five Ontario campus radio stations met in Hamilton to discuss the formation of new provincial campus radio organization. In April 1978, the Ontario Campus Radio Organization/l’Organization de Radio Campus d’Ontario (ORCO) came into being...
...community radio in Canada did not begin until 1974/1975 when four stations, CFRO-FM Vancouver, CINQ-FM Montreal, CKCU Ottawa, and CKWR-FM Kitchener began operation. The late start was due primarily to the fact that in Canada, community radio stations must depend on donations from listeners for financial support.
Community radio in Quebec began to grow in 1975...
...As campus radio organizations evolved through the 1970’s, the nature of campus radio stations changed. Only two campus stations held on-air licences at the beginning of the 1970’s – CFRC at Queen’s University and CJUS-FM at the University of Saskatchewan. By the beginning of the 1980’s, FM stations could be found on campuses in Winnipeg, Guelph, Hamilton, Waterloo, Ottawa, London, Quebec City, and Fredericton. Priorities have shifted away from carrier current and closed circuit systems to Cable FM and Low Power FM. The need for campus radio organizations, both on a regional and on a national level, was greater then than it had ever been in the past.....
Sorry.. just realized I posted most of that copy twice above within the same post.
@richpowers Ok tried to get the spot where you duplicated and edited that part.
Nice bit of history! You are learning quite a bit about Canadian "part 15"
@mark Yeah.. it contains a great overview of Canadian campus stations, but it provides no citations and I'm still not entirely sure exactly when legal unlicensed broadcasting actually began in Canada... The impression I get is still that it was not untill after 1992.
It's interesting that Canada licensed carrier-current stations but the US never has, though they played with the idea of licensing them for several years in the 1940s.
"...The OACB commissioned Professor Janisch, from the Faculty of Law at the University of Western Ontario, to prepare a brief to be submitted to the CRTC on the subject of a special licence for carrier current. Professor Janisch submitted his report to the CRTC in the summer of 1971. The CRTC issued a policy statement on student carrier current on May 4th, 1972... "
But the article doesn't ever mention any transition from licenced to unlicensed carrier-current operations.
The split in the Canadian rules between broadcasting and non broadcasting occurred with the creation of the CRTC, which spawned BETS (including BETS-1, the low power, unlicensed version).
The CRTC was intended to regulate the content of radio & TV stations, and out of it came the (in)famous Canadian Content rules.
There are attempts at defining broadcasting within the CRTC website, and within a circular that describes the path in either getting a license, or utilizing BETS-1. Essentially, it boils down to anything that is intended to be listened to by the general public, which pretty much encompasses everything you can think of (including RSS210 uses).
So really, what does this all mean? I'll admit that I've thought about this for some time over the years, and my opinions have waxed and waned. In practice, I've usually ignored the issue, focusing on ensuring that whatever transmitter I use is certified.
It's probably easier to describe what I believe RSS210 can't be used for. With the BETS-1 split, I believe that RSS210 can be used for anything that doesn't directly compete with radio stations under the umbrella of the CRTC and BETS.
So, if you're going to be potentially taking revenue away from BETS stations, use BETS-1. I used a BETS-1 transmitter (a Decade MS-100) when I ran a community radio station on Bowen Island, with listener sponsorship and heavy promotion from local media. I was a (legal) unlicensed radio station, and made no bones about it.
If you're self funded, have no aspirations for any revenue (and to potentially take away listeners from BETS stations), then as far as I'm concerned, you're not a radio broadcaster in the BETS world. Even if you sound like a radio station, maybe advertise your presence and have a few listeners. After all, you can't stop radio waves.
And that's what I believe the intent of RSS210 on the broadcast bands is - to prevent competition with existing radio stations.
The only individual that I know of that was shut down using RSS210 transmitters had several, networked together, and was obviously attempting to compete with other, local stations. I don't know if he was taking advertising. but that would fit in with the profile.
There's another argument, somewhat facetious, that I thought I'd include here. It does have a few morsels of truth.
With the all-encompassing definition of broadcasting, and the requirement to use certified devices here in Canada, why not turn the argument around?
If you're using RSS210 certified equipment, then, by definition, you're not broadcasting.
Conversely, if you're using BETS-1 certified devices, you're broadcasting.
End of argument.
The only individual that I know of that was shut down using RSS210 transmitters had several, networked together, and was obviously attempting to compete with other, local stations. I don't know if he was taking advertising. but that would fit in with the profile.
Not sure if I anyone caught it but in Canada's Exception Rules (cited earlier in this thread) it said you can broadcast without a license as long as:
"8. The undertaking, if it promotes commercial activity, e.g., "talking signs," or is commercially oriented, does not broadcast the same message on more than one transmitter."
In the US the FCC says "we have no rules concerning multiple transmitters" - not an exact quote, but that's what they say
But also note that Canadian stipulation #8 also seems to imply it's alright to use multiple transmitters if it's not commercially orientated.
