Time For a Change

I don't want to start a YAID (Yet Another Initiative Discussion).  And I also recognize that part of this is tongue in cheek.

This would be a big change.  Bureaucrats don't deal with change all that easily.  It's one of the biggest difficulties in all of this.

But sometimes, you can achieve a lot by changing very little.

So what if we're lumped in with interference, and labeled 'Intentional Radiators'?  They can call me anything, including Hank.

What if we don't focus on actually changing the rules, but changing the way that they are interpreted.  Because, after all, words are imprecise, and can only go so far in describing intent (that's why we have lawyers).

There is precedent for it.  Ten years ago, when I first started broadcasting, it was quite common for FCC inspectors, when looking at AM installations, to let you ground to whatever you wanted, as long as that ground wire + antenna + feedline didn't exceed 10 feet - that led to elevated installations on metal masts, signposts, buildings, etc.  Now, somehow, those grounds are considered part of the ground wire because they can potentially radiate.  It's important to know that nowhere is 'radiating' found in the rules).

What changed?  Only the interpretation.  You can argue until you're blue in the face about which interpretation is correct, or scientific, or factual, but the reality remains that if the FCC chooses to go back to their original interpretation, that's their perogative.  And nothing in the rules changes.  They did it before!  The only thing that the FCC has to do is to issue a circular, or bulletin, or whatever they would call it, clarify that interpretation (much like they've done with the 200 foot rule for Part 15 FM).  In fact, I'm rather surprised that they never really have clarified the ground rule, when it would be rather easy to do (either way), eliminating endless discussions about said rule in Forums such as this.

Another possible interpretation change, this time for FM, would be to measure field strength at the border of your property, as opposed to from your antenna.  This topic (about whether it should/could/is done), which seems to make its rounds in the various every few months, just reared again in another recent thread here.  Again, it's another thing that would be easy to do.

Rather than focusing on difficult, if not virtually impossible, efforts to change the rules substantially, perhaps someone could actually do something and organize an effort to accomplish this sort of thing.  After all, this is something that the FCC can do on its own, without going out to its various stakeholders.

Then again, there are always those that never want to rock the boat, as they feel that they could fall out (i.e., the FCC could change their interpretations to reduce Part 15 range, rather than slightly enhance it).  I say, that's just hiding your head in the sand, and tacitly admitting that you recognize that there is some playing loose and fancy free with the rules already.  For believe me, I'm sure that there are many licensed stations already pushing for further restrictions on Part 15, and sometimes doing nothing is worse than trying to do something.

Artisan I always enjoy your reasoned feedback on ideas that get flung around.

You said, "Because, after all, words are imprecise, and can only go so far in describing intent (that's why we have lawyers)."

When I used the word "initiative" I probably triggered a subliminal feeling that my idea was part of The Initiative, aka New Radio Revolution, yet I used the word anyway. Perhaps a lawyer would have advised against it.

When you boil part 15 intentional hobby radiation down to its fundamentals there's really not much to say, so I would argue that we need these occassional side issues to keep us talking.

If Rich and morningDJ have their way we will only recite verbatim rules in a very serious manner and eventually the website will consist only of those two guys, happy only that I will be out of their way.

I'm a little disappointed, Artisan, that you don't think my idea of having our own rule number is the best idea you've heard in years.

I have only one other hobby to turn to, The Retired Jackhammer Hobby Society.

Hey, Jackhammers can be fun too!

I have a story here.  There's a guy in Canada who claims that he has convinced Industry Canada to interpret our RSS123 rules in a different way to come up with a licensed, very low power FM service.

RSS123 here is intended primarily for event broadcasting, but it can also be used in churches and other public venues (the intent is large buildings or properties).  It allows for up to one watt average modulated output power, but the field strength at the boundary of the coverage area has to be 100uv/m or less.

The key to this is that a CRTC license is not required.  A CRTC license is much, much more difficult to get than an Industry Canada license.

I've often wondered if an argument could be put forth to extend the interpretation of event or a public place to include, say, an area frequented by tourists, such as a scenic village or downtown core.  This indidividual claims to have worked with his local Industry Canada office for a number of months and convinced them of something just like that - a license that can be used almost anywhere, with up to that 1 watt power.

I've contacted him, and am getting the details.  The kicker is that he charges to fill out the license forms in order to get it, so you never know.  I want to know prices, licenses fees, duration of the license, etc. before getting involved.

Anyway, this might be an example of the interpretation issues that I discussed, and how it could be used in a positive sense.

Interpretation can be a playground for creative exploration just as you say, Artisan!

The fun really begins when our resident rule dogmatists start shouting "violation!"

Let's do it now.... let's see, my wife and I both have been on the faculties of two universities and did a lot of class preparation right here at home, making us virtual extension campuses. See where I'm going?

If we fly a Canadian flag here in the Homeland we could go by the Canadian rules!

These are not polished ideas, just warm-ups.

Morningdj won't approve of the controversy, but he might actually come up with a new interpretation of his own, although he'd have to talk Rich into it.

Well, the nice thing about the interpretion in my story is that it apparently has been approved by Industry Canada (although time will tell - I'll keep this Forum up to date with my due diligence).  Those are the best ones - that are rooted in what could be, as opposed to fantasy..

The performance of Part 15 AM/FM systems is governed by well-investigated and proven physical principles -- not by anyone's "interpretation" of those principles.

I saw Joel Legace's post about RSS-123 also and he makes it seem that you can get this licence for a certain area and have up to a watt of power with a RSS-123 certified transmitter(Decade LX75 or FM 800 ) for example and broadcast to your hearts content even though it's not an event.

The fee for the licence is $56 a year and it applies to a particular area and a certain frequency.

You can't go outside of your "area" without getting another license for that area.

He made it seem like you can, once you get the licence(about a couple of months wait), you can broadcast like BETS-1 with a watt of power like New Zealand.

I spoke to him about this and read the RSS-123 rules on the IC website and realized not quite.

By the way Decade does this paperwork also and the fee is $100 or near there(it's on the website)

The biggest expense to this is the transmitter thats RSS-123 certified like the Decade 800 which is a watt and a half and $1600....Joel admitted he just uses a Chinese 1 watt you can get for $150 and if ever inspected he shows a certified Decade.

Questioned further and realized that, really this is for a specific event and not to have a radio station at a watt broadcasting day and night, and, if you are now registered with IC they can at any time check and if they see you are not doing this for an "event" and just broadcasting from your house they can cancel the license and that's it and you spent $1600 for a 1watt RSS-123 transmitter for nothing.

Sounded so good to me but after coversation with him realized that just using this to broadcast like BETS-1 with more power is not quite the way it is.

I'm sure on the form for the application for the license you have to specify the "event" it's for, the exact area and frequency it's for.

Mark

Rich, you're just not 'getting' it.  As I've stated previously, the rules, such as Part 15.219, are just words in a document used to express intent.

Both words and intent can be interpreted differently.  That's why individuals and corporations hire lawyers to go over contracts.  And it's also why both the FCC and Industry Canada sometimes feel it necessary to issue technical bulletins or (in the case of Canada) circulars, which narrows down that interpretation.

The 200 foot bulletin for Part 15 FM is a good example of defining intent.  The FCC never intended that Part 15 FM travel more than 200 feet to a typical radio (it would have been nice if they had defined typical, though). That single bulletin makes a mockery of those who claim that they are getting 1/2 mile to a mile range (with ANY radio) and are still Part 15 compliant.

What exactly the FCC means by limiting the length of an antenna system (ground+feedline+antenna) would be another, particularly since that same organization used to allow grounding Part 15 antennas to metal masts, signposts, etc.  Now they don't.

But the rules haven't changed.  Just the interpretation and implementation.

It has nothing to do with the technical or scientific definition of 'ground'.

In fact, not once are physical, scientific or technical principles mentioned in the rules, other than field strength, and a limit to the size of the antenna system (however you define that).

I invite you to step back, take a look at the forest rather than the trees, and view the rules as they really are (and perhaps not what you would like them to be) - an imprecise rendering of the FCC's intent to limit Part 15 intentional radiators.

Responding to Reply 9 above:

But the rules haven't changed.

Neither have the physical principles on which they were/are based.

Just the interpretation and implementation.

Both of which are not based on the underlying physical principles.

Mark, he claimed, at least in his response to my initial questions, that this was something new and never done before (I pushed him on the RSS123 things myself).  He claims to have worked with the local Ottawa Industry Canada office to get them to agree to a more general purpose license (maybe based on RSS123).   Right now, I'm just doing my due diligence and attempting to find out if those claims are accurate.

RSS123 all boils down to an interpretation of what an 'event' is, or what a 'public place' is.  If one can get it interpreted as a tourist area, as an example that I used previously, then I could see getting such a license for the area that I now live in.

I am currently located in Pitt Meadows, BC, in a community known as Osprey Village, which is located right on the Fraser River.  It consists of a small 'downtown' core of local and somewhat eclectic storefronts, surrounded by residences.  There are a number of townhouse complexes immediately around the core, with some single family homes a little further out.  All in all, it's probably got a radius of about 1/2 km from where I am (for 270 degrees, the other 90 is river).

Osprey Village is a tourist area for both locals and foreigners.  There are miles of trails along the river (you can, in fact, walk bike or run over 15 miles and get to Pitt Lake, which is a famous boating haven here).  It would be perfect for a locally-oriented radio service.

BETS-1 just doesn't have enough power to penetrate the core and townhouses never mind get to the single family homes.  My transmitter is installed at ground level, and can get out 200-300 meters to a car radio in some places which are relatively free of obstructions such as streets, but that's about it.

1 watt is a lot of power.  I don't know exactly how much would be needed here, but certainly in the milliwatts level (to enable a typical receiver to listen in).  If this license is the real deal, it would work perfectly for my situation.

And if it isn't the real deal, I may just attempt to convince Industry Canada myself that Osprey Village could be considered a 'public place' for event-like broadcasting, and see what happens.

By the way, Mark, you don't have to spend that kind of money on an Industry Canada certified RSS123 transmitter.  The Decade LX-75 (maximum output of 60mw) is certified for that use, and can be picked up relatively inexpensively on e-bay these days.  I've seen them for under $100.

Rich, at least you're consistent.

Are you correct in this?  Not in the slightest.  But in your defence, I think that you just don't understand.

AR wrote:  Are you correct in this?  Not in the slightest. ...

Certainly you are free to believe so, but would you please post your proof (not your opinion) of such?

Thanks.

"Certainly you are free to believe so, but would you please post your proof (not your opinion) of such?"

You're providing the proof yourself with the content in your posts.

Unfortunately, you can't see that either.

But you're welcome to your own opinion on that.

AR wrote:  You're providing the proof yourself with the content in your posts.

So you write, but with no attempt to provide proof of such.

Can/will you do so?