Whole House 3.0 Transmitter Test Results of FIVE Units.

... And since the WH 3.0 is certified, people buy it and use it's coverage as a standard for a legal device. Counting last year I've now tested 6 of these all under the same conditions and all were illegal.  I did not test these with the secret "Canadian" setting, nor did I test them with the illegal but still included in the US version, alternative long wire antenna. ...

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Not to dispute such measurements, still they lead to these questions:

How, then, were those units tested, and reportedly FCC-approved for certification as compliant with 47 CFR §15.239 ?

Were these processes faulty in this case?

They do indeed lead to that question.

We do know for a fact that the FCC never even looks at a Part 15 device, or most other devices before they are certified.  Their certification requirements do mention that in rare cases they may ask for an example to inspect themselves. How often this happens is hard to tell.  It looks like to me that most certifications -- at least the ones I've read -- are granted shortly after being submitted by the testing company leaving little time or opportunity for the FCC to have procured one from the factory in China to examine.

But look at the C. Crane results.  If my testing procedures were in error by an amount to make these units read legal, then a C. Crane woulld be 10uV/m. At least I could read the C. Crane on the uV scale on the FIM, I had to go to the 10mV scale to read the Whole House transmitters!

The C. Crane fades out in about 35 feet, line of sight, outdoors. I quickly paced off coverage with one of these WH units and got over 300 feet, and that was with the transmitter sitting on the roof of a car -- not exactly ideal.  The C. Crane I had it sitting out in the open at 7 feet with I range tested it. The range tests are in no way scientific or even directly comparable. But the FS tests were identically setup and were done as humanly possible to be identical.

But look at all the cases we have discovered where there have been faked certifications, etc. It would be pretty simple to submit for testing a unit adjusted for legal, then sell units adjusted for better power. 

But only one unit needs to be submitted for testing and compliance checks -- e.g. label, antenna connector being non-standard, etc..

TIB

The FCC and Industry Canada have their own approved test facilities and before the FCC or Industry Canada issues a certificate they see the results.

When I asked Industry Canada(IC) why a transmitter certified with the FCC still can't be used here even if the certification is under RSS-210 which is the same as part15 they said the FCC and IC have different approved test methods so FCC certified is no good here....has to have the IC certification to be legal.

So I think the FCC and IC actually see the results and test methods before a certificate is given. But that of course doesn't explain how a certified transmitter is way over the max. It also helps if the company is honest and doesn't change things after certification. As for the Chinese tranmitters you can't even legally use them in China either.

According to the BETS-1 rules if I want to use a transmitter that doesn't have the IC technical acceptance certificate(certification) I have two choices:

Have the tests done myself by an engineer with the proper test equipment, someone like Timinbovey for example, or give the transmitter to Industry Canada and they will have it tested and adjusted for compliance at a big cost.

So, a CCrane for example can't be used here because it's only FCC approved.

I can't get a Rangemaster or Talking house and use it here.....not IC approved.

Durham Radio just east of Toronto was selling Ramseys several years back and got a big fine for selling an uncertified transmitter, even the kits.

Told them you could be a Decade dealer and sell their products as they are IC approved but they won't touch it.

Mark

Yes, there are hundreds of FCC accepted and certified test labs all over the world. 

And yes, the FCC does go over the test results before issuing certifications.  In fact, if you read a lot of certifications (I have) you'll see every now and then the FCC demanded changes before issuing certification.  Sometimes as simple as the working on the label wasn't correct (often foreign language translation issues) or the wrong type of antenna connector, etc.  then you can see where the changes have been made and proper paperwork filed as an addendum to the original. Etc. 

But again, you're still relying on the manufacturer to really submit exactly what they're going to manufacture, and then to continue to do it, with the same quality control, etc.  ONce the certification is issued, there's no further inspection of the product to ensure they're still making them the same way.

Then of course you have the companies that simply use the same ID number on many products.  The FCC would never notice unless someone complains. 

TIB

I read through this whole thread with interest, and the results make using FM 88.1 to 107.9MHz very scary at the very least.

I know my reasoning is not going to be well receieved, but it seems like most FM transmitters are illegal and are questionable to use if one does not have the proper expensive equipment to determine legality, why not just raise the limit a bit so there is some leway in legality?

I realize, what I suggested is something those who intntionally want to break the rules can take advantage of, but for the average christmas display event person, they do not take into consideration that they need expensive equipment to determine legality for their christmas display event.

If the FCC was to go around and bust everyone who was unintentionally over the limit, they would have about a minimum of 300 or more cases of violations per day.

Even a CB radio, which allowed 4 watts to the final output stage were capable of putting out more than 4 watts, but they were certified. I am sure if a CB radio did 5 watts maximum to the antenna, the FCC would not issue a violation to the station for that 1 watt over the limit and CB SSB allowed 12 watts PEP.

FM seems to be the exception to the rule, specially with Mr. Bill D on the loose, trying desprately to get his picture and name in a magazine such as "Radio World" bragging about how he helped the FCC bust an FM pirate in Connecticut!! He has a personal vendetta and prophecy about doing that.

The simple solution at everyone's tongue is AM..AM..AM..AM..AM!!

I don't quite know if in 1958, FM was the holy grail like it is now, or if at the time, AM was the holy grail, but time and time again, I see FM talked about like it is the forbidden land to tread on.

It is to the point, that the minute one says FM in the same breath, it is responded to with negativity, and warnings. You can't be there, you can't do that, it is illegal, the list goes on.

What makes FM so off limits? What is everyone's real point? Is FM sacred ground and only a licensee belongs there?

There are many areas in the US where the FM band is not as full as others, but, this rule among the groups, that FM is off limits, still applies even there.

So, what makes FM so the Holy grail here? Stereo? Can't be the range with co-channel and noise to the stereo carrier and even fluorescent lighting kills the FM carrier with noise, signals do not penetrate buildings, or arch over mountains into valleys, so the question, still boggles my mind, why all this anti-FM this and anti-FM that? Modern day FM is just as a total mess of noise and congestion as AM and it is only getting worse each year that goes by, but broadcasters still proclaim FM as their golden arches.

The limit to me is just too low and puts most part 15 FM transmitter owners at risk of being violated, I think the 250 uV/ @ 3 meters rule is too low and should be raised a bit, to bring those TRYING TO COMPLY, into complaince. As for those who are still trying to violate the rules, well, they are the exception. Not everyone is a blatant rule breaking pirate.

Bruce. 

I'm not gong to comment on raising the legal limits for FM.  But I do think that Tim's tests (thanks Tim) illustrate that the FCC really needs to make it easier to measure whatever limits they decide to put into place, given that most peope don't have access to expensive test equipment.  Otherwise, you're relying on the manufacturer, and we're seeing what that means here.

Part 15.219 defines the input power to the final stage of the transmitter for AM, and that, coupled with the length of the antenna system (including ground), makes it an awful lot easier for the average individual to determine if you are operating legally.  Not pefect, admittedly, but still easier.

MrBruce said "As for those who are still trying to violate the rules, well, they are the exception."

I'm not entirely sure about that.  I would agree if you're talking about those participating here, at HB and similar Forums.  However, it seems to me that virtually everyone participating over at the Facebook Part 15 group and operating on FM (present company excluded, of course) is operating illegally, and quite deliberately at that (based on multiple recent threads).

Tim's tests with supposedly certified transmitters demonstrate that it is difficult to operate legally on FM as things stand right now, even if you're attempting to do so (and I believe that that is MrBruce's main point as well).

The fact that there is a large contingent of people that doesn't even try makes for potentially big problems on an already crowded band and muddies the waters considerably for anybody using FM.  The optics are just not great, and to the FCC and licensed stations, perception is reality.  I believe that is why caution is advised at HB, here, and elsewhere.

It shouldn't be that way.  But it's reality.

 there still is that questionable fudge factor that I brought up last year. Remember I kept  discussing and bringing up Frankenmuth discussing and bringing up Frankenmuth Michigan and their Christmas display which runs 365 days out of the year because they have a Christmas store. Well the reason I brought that up as they are very very close to the FCC headquarters in Michigan which is Detroit.

 everyone knows  about the about the Christmas store because it is advertised. In fact people come there from all over the world to see it. Everyone knows the frequency because when you go there they tell you. So again there has to be some sort of fudge factor that is not talked about to the public.

 has the FCC consider changing the rules but they are actually not written? This you would never know but it is questions that we should ask the agent next time we get a chance to do so. That's if they're going to tell you a straight answer. I really don't see why they wouldn't.

ArtisanRadio Said:

Tim's tests with supposedly certified transmitters demonstrate that it is difficult to operate legally on FM as things stand right now, even if you're attempting to do so (and I believe that that is MrBruce's main point as well).

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Yes, ArtisanRadio that is the point I was trying to stress in my post #6 above.

By the way Tim thanks for the informative thread.

That Facebook page, has been moderated a little bit better lately, but, as large a group as it is, there is going to be "the good, the bad and & the ugly" in attendance.

Bruce.

I doubt there's a fudge factor in the Part 15 FM rules, except for allowances in measurement errors.

While we may never know why some marginal broadcasters are pursued, and others aren't, it could be just an FCC agent that is giving them some slack (they are human, after all).  Now, if a complaint from a licensed broadcaster was formally lodged, that might be a different story.  Although, the optics of that for the licensed broadcaster would be pretty bad as well (going after a Christmas lights display that is probably enjoyed by a great many people wouldn't do anything to increase their popularity).

But I wouldn't count on running into too many lenient FCC agents as a general rule.

I have to wonder how a Broadcast Vision transmitter would fare under Tim's tests.

I have another question regarding the whole house FM transmitter 3.0 and this time it has nothing to do with the range. I think it's just as important to know what it looks like on a spectrum analyzer because after all if you're interfering with a bunch of other radio stations that's just as bad. To me that is worse than anything else because if you're interfering with someone's radio station in let's say a broadcaster in vets $30,000 just on the transmitter and antenna alone and we're talking cheap here because I know it's more than that. Well some johnny-come-lately comes along with their transmitter and starts transmitting and it's interfering with their listeners. You have to think about what you would do if it were you. So I think sometimes these transmitters are causing issues because they're not clean. Tim mentioned the Fail-Safe 05 B which is a CZH 05B transmitter. Let's not even mention the fact that it's over the limit on high power what I would like to know is the Spectrum analyzer was brought up on this transmitter and it was fun pretty darn clean. Has anyone ever thought about checking the whole house FM 3.0 and the C. Crane  for harmonics and for harmonics and Spurs another nasty dirty stuff that some of these transmitters generate? I know we keep talking about range until the sun goes down but we need to start talking about how clean certain transmitters are and we need to start testing for that too because after all the dirty transmitter is not acceptable.

 one more thing sorry about the 05 B transmitter and the reason I bring this up is because the mismatched antenna as I have been taught and radio causes all kinds of problems nevermind the fact that it's bad for the transmitter. On an NFJ antenna analyzer the rubber duck was tested on a resonating frequency of 140 megahertz period has anyone ever measured the actual resonating frequency on that little antenna that comes with the whole house FM transmitter 3.0? Well I know it would be a hard thing to do but it could be done. Again the reason I ask is because a mismatched antenna causes issues this we have found in some experiments.

 I raise these valid questions because the FCC should be more aware of things like this that cause a transmitter not to be able to do its job properly. The poor antenna match will cause havoc so I would like to see these tests also include what a transmitter can do on a spectrum analyzer so that when people buy these transmitter they know which ones are clean and which ones are dirty and ugly.

Asked Tim about testing the Broadcastvision already and he mentioned the price and passed on it.

But I'm willing to bet he would find it over because the Broadcastvision has the same range as I get with the Decade MS-100 so it would be working at closer to BETS-1 than part15.

I'm using the Decade exclusively now as I feel comfortable with the BETS technical acceptance certificate that Michael at Decade told me that is in fact your "licence" I also like the fact that the Decade has a 35" telescoping antenna that can be adjusted for the frequency included in the certification.

Mark

Not that I'm opposed to testing a Broadcastvision AXS-FMTD (this appears to be their current model). 

At nearly $300 each I clearly wouldn't be buying a bunch of them to see what the unit per unit variations might be!  However, I might pick up one, just to see how it fares. I presently have about $1000 invested in a stack of C. Crane FM 2 and Whole House 3.0 transmitters that I'll probably put on ebay with a buy it now at a price below retail, just to convert them back into cash.  I don't mind having some $$ invested in testing and I don't really see it as "losing a few bucks" as much as I do find it both entertaining, interesting, and challanging to test them so there's value in that to me, LOL. Such a geek. 

I cannot find on their website anywhere any mention that the Broadcastvision AXS-FMTD is actually certified. In the photos is appears there may be a certification label, but they're such low resolution you can't really tell. 

I'll see what I can do. Then, I have to beat the weather. My test field could be under a couple feet of snow any day now. 

TIB