Does RSS-210 actually say it is required to adhere to CRTC regulations?
Part 15 actually specifies that we are not required to adhere to any broadcasting rules. Does RSS-210 actually specify CRTC rules apply?
Arguably, the FCC has never classified part 15 radio stations as "broadcast stations", that's why we dont have to follow its rules.
Your indicating that the CRTC does? -Does it specifically say that somewhere?
The thing is, RSS-210 doesn't cover broadcasting, only non-broadcasting use.
That's because Canada has another regulatory body, the CRTC, which handles the content of broadcasters. Unlicensed low power broadcasters have to follow the BETS rules. ...All broadcasters in Canada have to have a CRTC license, but there are exemptions for BETS devices (which restrict content).....As for the definition of broadcasting, good luck. It appears to be anything that is transmitted to a member of the general public.
Sorry I had apparently missed your response and kept right on talking..
RSS-210 actually specifies "non-broadcast use"? What are the Canadian rules govern things like wireless speakers, or... oh right, it specifies that wireless microphones can not be be used for broadcast purposes, does it say the same about wireless speakers?
Ok, so the BETS devices, if I understand you correctly, fall under RSS-Rules. And it is only the category of RSS-210 BETS devices in which arn RSS-210 device is permitted to broadcast on the AM band.
Is that the general gist of it?
No, BETS is a separate set of rules from RSS-210, and therein lies the confusion. RSS-210 is for unlicensed intentional (but not used for broadcasting) and unintentional radiators. BETS is specifically for broadcasting.
Here is BETS-1. It covers what ISED or Industry Canada terms Low Power Announce Systems or, in FCC terminology, FCC Part 15 transmitters used in the AM and FM broadcast bands.
All broadcasting is covered under the CRTC, both licensed and unlicensed. The CRTC makes exemptions re the requirement for a CRTC license for certain types of broadcasting content, and use. Low Power Announce Systems are one such exemption, but they still have to adhere to certain restrictions.
LPAS's have to be BETS certified by ISED/Industry Canada. The only transmitters I'm aware of are the Decade MS-100 and the Decade CM-10 (discontinued, effectively a neutered CZE Chinese transmitter to meet the field strength requirements). All the others currently available, including the ProCaster, the BVE AXS-FMT, the Whole House 3, the Talking Sign, are RSS-210 certified. Technically, they should not be used for broadcasting.
The definition of broadcasting is not clear cut. ISED and the CRTC do not deem it broadcasting if you keep your signal within a defined boundary and use it for an information service such as tourism - such stations can either be unlicensed or licensed under another set of rules, RSS-123.
It's also not considered broadcasting if you transmit a limited time special event over a limited coverage area.
You are not considered to be broadcasting if you're using the transmitter for your personal use. I'm currently using the Talking Sign to transmit to my SDR, and that by itself is OK. But, of course, you can't keep that signal bottled up and people can overhear it elsewhere. There, I believe you have to go by intent.
If you using an RSS-210 certified device, are investigated and deemed to be broadcasting, the CRTC does reserve the right to require you to obtain a broadcast license. Similarly, if you have a BETS LPAS device but are not following the restrictions outlined in the CRTC's license exemption, they can require you to get a license. Good luck with that. Unless you're in a really rural area, or have a couple of hundred thousand dollars to pour into your station, you'll be out of luck.
With all that being said, the reality is that, as I stated previously, there are no BETS certified AM transmitters. So you have to use RSS210 devices. And generally, unless there have been complaints and ISED wants to shout you down, there's usually no problems. I've heard of one individual who was ordered to stop using an AM transmitter here because they were broadcasting, but have few details to know exactly why that happened.
So you can see, you actually have it pretty good with the FCC in the U.S. No content regulation. Reasonably clear rules, even with the 15.209 vs 15.219 issue. The only advantage we have in Canada is that we get a higher maximum field strength for BETS FM - 100uv/m @ 30 meters vs 250uv/m @ 3 meters.
But even then, ISED considers that our FM field strength is only enough for a signal to travel 30 meters (100 feet). Like the 200 foot maximum often touted by the FCC and others in the U.S., there's no mention of the factors that most affect reception range, such as the sensitivity and selectivity of the radio, it's antenna, etc. There's also no mention of what the signal at the end of this range would sound like (barely heard or strong). That's why I take these ranges, viewed by some as THE WORD, with a huge grain of salt.
If you have a highly sensitive and selective radio, with a great antenna and direct line of sight to the transmitter antenna, you'll get more range than either the FCC or ISED states. Whether it's listenable or not depends on your ear.
Suffice it to say that both sets of rules are there to severely limit range for unlicensed use, and therefore limit potential interference to licensed stations.
I have to add to this for Rich Powers. I am friends with Gerry, the one man owner of Procaster and the issue Artisan refers to, about someone who was ordered to stop using a Procaster even though certified I found out from Gerry the whole story. The user was in Winnipeg and he had several....yes several Procasters and was installing them all around on different areas other than his own to cover half the city and one of the 3 AM stations found out and complained and there was two issues. First when you are installing transmitters everywhere you can't really say you are not broadcasting, and the other rule broken was unlike the USA where you can have several transmitters in different areas to cover a large area like a large town or even part of a small city as long as each transmitter operates with the rules, in Canada you can't do that. BETS or RSS-210.
I was talking to Gerry about this and I was trying to tell him about broadcasting and nonbroadcsting and I said with a Procaster, if you put it up on the roof here from your house you are broadcasting to the general public in an undefined area outdoors. BUT...if you go down to the school yard down the street and set up there in the school yard you are now "nonbroadcasting" as you are on a defined area/property for the specific people at the school.
So Gerry said to me, but the signal goes out of the school yard boundary and the residential areas around beyond...the general public! It's stupid! And that sums up the whole issue.
Now, I am on AM using a legal certified Procaster from indoors from my house. The signal covers the area I posted on this forum. And, of course my intent is to cover the neighborhood around me, for listeners and to be a listener to my own station indoors and out. There are no BETS AM transmitters. If I can't use a Procaster from inside my own home, where can I use it? Is it legal or not? Why did the manufacturer go through the hoops and great expense to get a certification from an approved lab?
And one more thing....The Talking Sign that artisan is using was intended for similar use as the talking House in the USA. For selling a house with a sign on the lawn and turn to 1610 on the AM dial for info.
Isn't that broadcasting to the general public? For all drivers within a Km of you to hear the message? And there's no restrictions how long you can be on the air.
But you are not supposed to be broadcasting! Go figure.
@artisan-radio Just think, there's a guideline the FCC puts out with an estimation of 200ft for FM as a guideline for legal range but BETS FM in Canada which is 4 times that says your expected range is only 100ft. Now how can that be?
I really want to explore/converse on some of the things you've expressed, but later. For now I just want to say that the Csnadian rules are beginning to become less confusing to me.
It looks to me that in regard to the AM band, Part 15.209 and RSS210 are essentially identical.
What BETS appears to be what is Canada's version of 15.219 (an alternate method which provides extended range).
This. I think really wipes away a lot of confusion.
But I'm really not sure if Artisian is correctly interpreting that RSS210 is not permitted to "broadcast" AM to a surrounding area. That somehow just doesnt seem to make any sense.
By the way, theres no question that using multiple transmitters to extend range is permitted by the FCC. Not only are there no rules prohibiting it, but the FCC has actually officially clarified that you can, and it's been done without issue numerous times over the last 50 years.
From the Scope section of RSS-Gen (which provides an overview of the RSS rules):
Radio Standards Specification RSS-Gen, General Requirements for Compliance of Radio Apparatus, sets out general and certification requirements for licensed and licence-exempt radio apparatus used for radiocommunication other than broadcasting. “Broadcasting” refers to any radiocommunication in which the transmissions are intended for direct reception by the general public.
For non broadcasting applications, you use RSS. For broadcasting, BETS.
BETS is something different from the FCC Part 15 rules. It uses field strength exclusively to measure compliance. The FM field strength allowed is greater than the FCC's Part 15.239. For AM, there is no alternative method for compliance (i.e., 3 meter antenna & ground, 100 milliwatts into the final).
RSS210 is almost identical to the FCC's Part 15 rules, for both AM and FM. Note that the FM field strength used to be the same as BETS, and was then reduced to bring it in line with Part 15.
RSS210 (or BETS for that matter) does not allow homemade transmitters (or kits). All transmitters must be certified under the appropriate rules.
You do not require a CRTC license for RSS210 because it is defined as not broadcasting. The CRTC has exemptions for the requirements of a CRTC license for BETS, even though it is for broadcasting, providing you follow their restrictions.
To make matters even more confusing, there is a 3rd standard that I alluded to earlier, RSS-123. It requires an ISED license, but not a CRTC license, as it is also defined as not broadcasting. It only seems to apply to FM, and allows up to 1 watt of power, but your field strength at the boundary of your intended coverage area has to be 100uv/m. It is intended for use in restricted boundary areas, such as malls, parking lots, parks, etc. and does not generally allow music except for limited time events. The most common use is as an information service such as tourism, weather, events, special notices, etc.
Hope that helps.
Remember, it's the existence of the CRTC, and the desire in Canada to regulate broadcasting content, that has generated these different classes of rules. The U.S. does not have their equivalents.
"Radio Standards Specification RSS-Gen, General Requirements for Compliance of Radio Apparatus, sets out general and certification requirements for licensed and licence-exempt radio apparatus used for radiocommunication other than broadcasting. “Broadcasting” refers to any radiocommunication in which the transmissions are intended for direct reception by the general public".
So that being said, is a Procaster, certified as legal being used from my home or property with the intent to get to the neighbourhood( and myself and property) set up as directed broadcasting? Is the Talking Sign intended to get directly to the public as certified to advertise a house for sale with a sign telling the general public to turn to 1610 for info and that signal could cover 1km around, is that broadcasting? Again I ask, can I use a Procaster
from my home? If the Procaster is set up in a mall parking lot(private property) isn't that targeting the general public that frequents the mall? What is the difference?
Again I say if I can't use a legally certified Procaster from my home where can I? I asked you if this(broadcasting) would matter to you and would you use a Procaster if you had a house and set it up as intended outdoors and you said yes, so that was good enough for me.
Why can't I say I am targeting myself and I want to hear it when I go out shopping? It's intended for me?
I think that Rich Powers, us, and any other rational thinking person would find this hard to understand.
There are no BETS AM transmitters, bottom line, And unless you are in an indoor arena or stadium you are targeting the general public, and you are still targeting the general public inside the stadium are you not?
Crazy!!!!
The guy in Winnipeg, as Mark pointed out, was doing 2 things wrong.
First, broadcasting with an RSS-210 certified device. The definition of broadcasting is pretty nebulous, but it all boils down to intent. Is your intent to broadcast to members of the general public? If so, use BETS. If not, it's fine to use RSS-210.
I think that with a single RSS-210 device, such as the ProCaster, you can argue that you had no intent to broadcast. A lot tougher when you have 3 to increase your coverage area. I guess you could try to say that it's still for your use throughout these areas.
But there are other considerations. Was this guy advertising his station? Was he actively seeking listeners from the general public? And was he attempting to get revenue from the station by accepting advertising? All would point to the fact that his intent was to broadcast, a no no with RSS-210.
And secondly, even if you're using BETS-certified devices, you are not allowed to transmit the same programming into multiple devices. The intent of the CRTC there is to limit your single coverage area, much like restricting field strength.
On the other hand, it would be perfectly OK to have multiple BETS transmitters, and broadcast similar but not identical programming. Different playlist, programs in a different order, etc.
Rich Powers said:
"But I'm really not sure if Artisian is correctly interpreting that RSS210 is not permitted to "broadcast" AM to a surrounding area. That somehow just doesn't seem to make any sense."
And it just doesn't make sense. I don't think I am doing anything wrong. If I let people know it's there, I don''t think it's wrong. It's for me and them. It's a certified legal device.
I ask again isn't a talking sign telling the general public to turn to a frequency intent to broadcast to the general public? Really, the Talking Sign should be BETS. A Procaster set up as certified with 100mW and 3 meter antenna even from indoors in your own residence it can cover a km around you. I guess if an agent listened and I have station promos and the like it could be assumed my intent is to broadcast.
But am I worried for nothing? Will it ever come to that?
There are no BETS AM transmitters.
There is no clean space on FM in the Toronto area(GTA)
No one is ever going to complain about interference on AM.
This band is not important anymore, even the few commercial stations left in all of Canada say you can get us with streaming or other apps like smart speakers etc. and encourage that. They don't care about this band.
As far as I am concerned I am using a legal device that someone went through a lot of expense and time and aggravation to get certified and if it's legal, operating according to technical rules, I am not illegal.
And the intent of the certified device was to broadcast no license needed!
And the manual for the Procaster states have your own neighbourhood radio station no license needed.
There's nothing more I can add to this.
I'm not arguing with anyone here. Just attempting to clarify what the Canadian rules say and potentially mean. I don't necessarily agree with the RSS210/BETS split either.
It seems to me that the CRTC (along with ISED) could just as easily have said that RSS210 devices operating in the AM or FM broadcast bands can broadcast there without a CRTC license, as long as they follow the CRTC restrictions linked to previously (to get the exemption from the requirement for a CRTC license). The RSS210 FM field strength could be increased to current BETS levels, as it was previously.
It's not like intent of use is a foreign concept within RSS-210. Wireless microphones, the original subject of this thread, have that definition. Other frequencies do as well (such as the ISM ones). The only common sense use intent for the broadcast bands is ... broadcasting (duh).
Then you'd only have one set of rules, RSS210, and not this level of confusion.
I'd be willing to bet that the only reason they split off BETS from RSS was that the CRTC wanted their own set of rules, separate from ISED. Government bureaucracy at its finest.
Right now, BETS FM is the only viable option for my radio station. If I were in a house and could do a proper installation, I would likely go (and have gone in the past) with RSS210 AM (like a ProCaster). I'd continue along with that until someone from either ISED or the CRTC told me I was doing something wrong (and I'd be willing to discuss that I wasn't).
@artisan-radio Same with me, AM seems to be the best viable option now in the GTA(Toronto area) So we are on the same page. AM works for me here. FM is iffy and there's no really free space left as on every frequency there's something near or far or a repeater and no way that even BETS will do near as good as AM will. And any interference(FM) even from weak signals from other places that no one would be listening to will have the capture ratio getting the other and drastically eliminating any range I could get if on a clean open space. Which has been happening on 89.9, the only spot left in Toronto. And the few other clear spots are adjacent to locals. But as I see it I will not likely ever have to try to explain or discuss to an agent why I am not doing anything wrong and why I can't use a Procaster. And I like AM, I am old school, I grew up with it.
I feel like I missed so much since yesterday, so zim just going to go right down the line..
@ Artesian Aha! So that's what all this sdr experimentation is about. Your out to show that your intent is not broadcasting. Aiming for a loophole!
And you mentioned one guy who had been shut down that Mark elaborated on, - what is a violation like an NOUO called I'm Canada? Does they have something like the FCCs NOUO database online? Proubly not, looked around and cant even find pdf of the rules (I know theres the online versions but I prefer the digital hard copies)
It jumped out at me when Artsian said:
"The definition of broadcasting is not clear cut. ISED and the CRTC do not deem it broadcasting if you keep your signal within a defined boundary and use it for an information service such as tourism - such stations can either be unlicensed or licensed under another set of rules, RSS-123."
Perhaps the key can be found in that "unlicensed ..other set of rules, RSS-123" you mentioned. If tourism can do it unlicensed, theres no legitimate reason that any private citizen shouldn't be able to as well.
Mark commented, quoting Gerry: "...if you go down to the school yard down the street and set up there in the school yard you are now "nonbroadcasting" as you are on a defined area/property for the specific people at the school."
So set up the Procaster in the "defined area/property" of Windsor Heights, or whatever the name of your neighborhood, subdivision, or apartment house is called. How would that be any different than a school property?
Artesian, I suspect the Scope section of RSS-Gen is certainty an excellent source for an overview, but I wouldn't count on it (not that I've read it), because citing from it might be like citing from FCC "overviews", take the FCCs low power broadcasting page for example, with its 200ft AM signal. The overviews slide right over the details - and as they say; the devil is always in the details.
And I know the BETS and Part 15 are not the same, but I was likening it to 15.219 in that they are both an alternative method which provides extended range... We both have two options for unlicensed transmission on AM which was my point (and for me puts it in a clearer perspective).
I have this theory, considering BETS came into existence after witnessing all the controversies that arose with the NAB here in the states over the use the 15.219, which nearly caused it to be abolished. I presume that Canada, in light of the fiasco, created BETS with it's fixed field strength so they could control it, unlike the FCCs unrestricted field strength of 15.219, that's not controllable.
Note: I'm just talking off the cuff here, all speculative. I'm not trying to say I know something I dont.
Mark says "I don't think I am doing anything wrong." - and your not, like you say it doesnt make any sense, I agree, there's no legitimate reasoning.
Artesian says: "It's not like intent of use is a foreign concept within RSS-210. Wireless microphones, the original subject of this thread, have that definition."
Right, the wireless microphones that broadcast but can not be used for broadcasting. Love it.