- Posts
Here it is!….the facts!
Spoke to an agent at Industry Canada, Which is now called Innovation Science and Economic Development(ISED).
About broadcasting and not broadcasting….RSS-210 is meant for personal use only and not to be heard by anyone but yourself. If you are heard by others other than yourself intentionally or not you are considered broadcasting and outside the scope of RSS-210 which puts you in the BETS-1 category. If we in Canada use a Broadcastvision TX for example certified under RSS-210 and you get a visit they will take measurements and ask to see the transmitter. If the transmitter is RSS-210 certified but can be heard by others outside your personal space even though you are not over BETS-1 field strength they can still say you need a BETS-1 certification which is your “license”. You cannot operate a RSS-210 certified transmitter OUTSIDE or INSIDE for others off your property to hear.
I gave the agent the numbers on the back of the Decade and he verified that the certification numbers are BETS and not RSS-210 as BETS certification also can be used for your own use also.Now for the info. we’ve always wanted to know….THE COST of certification.
The ISED agent gave me a list of all the certification labs worldwide and I called the one in Oakville Ontario and spoke with Dan Nita.
The cost to have a transmitter certified operating in the FM and AM bands is $3000 and this includes everything and receiving the certification label and number. The same cost for BETS and RSS-210 and RSS-123.
Now here’s the interesting part……the cost is the same for FCC part 15 and BETS-1 and RSS-210
The cost is also the same whether you are a private person or a company…no difference! I can submit a transmitter for certification or a company can submit a sample for certification. The only way you wouldn’t get the certification is if the transmitter can’t be adjusted to meet the regs. like the Chinese ones for example.
He also said that ANY transmitter cannot be sold or shipped here and in the US legally unless it’s certified making the Veronica, the Chinese makes, EDM for example not legal to even ship here let alone get it certified. All transmitters made by US or Canadian companies have to be certified either Part 15 or RSS-210 and BETS is optional.
Now, for a company $3000 is not much so why wouldn’t any transmitter manufacturer here or overseas just get the product certified as it’s a one time cost? What we’ve heard about the cost being so much for a company to get certification is not true. EDM could easily get a certification and for BETS. and sell them legit here.
As for the AM Procaster, Why since the cost is the same, don’t they get the BETS certification and not the RSS-210? That’s what makes it OK to have the public hear you.
Since the Decade is BETS-1 certified it can be put anywhere inside or out and as long as you are not causing interference to something else.
As for the EDM being a kit therefore making it legal to sell here and in the US, in Canada I still have to spend $3000 to be able to legally use it. The test facility also gives you the cert. label and number and not ISED as thought….they just see the results of the testing and put it in their data base. The test facility(s) are approved to do this as anyone can’t.
So 2 transmitters can be used as received here in Canada for “broadcasting” Decade and Procaster which because of the outdoor install as part of the certification with the Procaster there’s a grey area and if you are told you are broadcasting you have to spend $3000 for the BETS certification.
Total posts : 45366So, if you’re in Canada and you purchase the parts to built an FM transmitter that meets the BETS-1 specifications, you cannot use it unless you personally send it to a lab to be certified?
At least in the USA you’re allowed to build one from scratch and use it as long as it meets the rules. You can also build a kit and use it, as long as it meets the rules. All with no sertification or inspection required.
The EDM remains legal to ship to the USA because it is a kit and does not need certification. A very loose interpretation of “kit” I’ll agree.
Many I’m sure do not get their transmitters certified because there is no way their transmitters will pass the tests. Look at the certified units I’ve tested. Broadcastvision. Whole House 3.0, etc. How about the Fail-Safe! Now THAT was a real doozey! Every one of them was substantially over the legal limit, yet boasted certification. Clearly there is some playing around with certifications. I bet dollars to donuts that some send the lab transmitters that were specially adjusted to pass certification. And of course we know of cases were certifications were faked as well.
There are other tests (in the USA) that an FM transmitter must pass to be certified other than output. Permanently attached antenna, or a supplied antenna with a unique connector. Can’t have adjustable power. Can’t operate out of band.
Many of these “companies” are one man operations and $3000 is a lot of dough. I’ve had the price lists for certification from several US labs. Ranges from around $3500 to about $6500 total (there are a few other costs besides just the lab charges).
TIB
Total posts : 45366Asked about knowing someone who has the qualifications and test equipment to test a transmitter for compliance instead of a lab, like you Tim for example and was told hesitatingly you could but then you still need the certificate label. The certified labs that do the testing do all that included.
Yes here in Canada you can build or obtain a transmitter and have to get it certified under BETS-1….$3000….to broadcast with it. With the intent to be heard by anyone but yourself.
By the way the Decade MS100 that’s BETS-1 certified has a RF adjustment and they(Decade) have the tech. and meter and adjust before sent out.
Mark
Total posts : 45366The interesting thing, to me anyway, is that here in the USA the FCC has pretty much completely removed themselves from the testing and certification process. All the major labs that are certified to do the testing (and they did have to be certified by the FCC before being allowed to do the testing) do the entire thing, from testing the transmitter, to filing the FCC paperwork for you, to issuing the certificate with ID number. Not long ago the test results from the lab were submitted to the FCC and then you’d get the certification. Often the FCC would require some tweaks — either mechanically design wise (antenna connector for example) or electrically, before a certification is issued. Now, they don’t even see any paperwork at all. The only way someone marketing sloppy or downright illegal transmitters is going to be flagged is by people turning them in. Not to mention the fact that transmitters are obviously passing certification when the production models being sold clearly do not. With that and the faked certifications, it’s quite the mess. That Fail-Safe transmitter I tested is a good example. It looked to me like the unit sold to me was NOT the exact same device as shown in the photographs for the certification that the FCC had on file. Wihtout even going near it with a field intensity meter it would have failed by having user adjustable power output, operating out of band, no certification label, and no country of origin labeling (which is not FCC, but still required by law to be imported and sold in the USA). it’s simply not possible for that transmitter to have a valid FCC certification. It looks to me like they picked up the certification from another transmitter. But anyway… there’s clearly no real oversight as to what’s being made, sold, and imported.
TIB
Total posts : 45366How could anyone reasonably expect to prove that the radiation from their unlicensed AM/FM broadcast band transmit system is legal under Part 15, if/when an FCC field inspection shows otherwise?
Even transmitters with proveable FCC certification as being compliant with Part 15 rules when measured in a test lab can be installed and adjusted by the final buyer/installer/operator of same so as NOT to be compliant with Part 15.
And likely moreso for such hardware never having been officially certified as compliant with FCC Part 15 — as shown by the measurements of same reported on Part15us by TIB.
Total posts : 45366Tim, it’s been a while since I’ve looked at the RSS210 rules in detail, but I believe that they allow for home brew transmitters – but again, remember that RSS210 is NOT for broadcasting. Canada regulates ALL broadcasting very tightly, mainly because of the existance of a regulatory body that is concerned with program content – the CRTC.
However, broadcasting in Canada is defined as transmitting to members of the GENERAL public. You can aso use RSS210 as an information service to transmit to, say, shoppers at a mall, or cars parked in a parking lot. And there’s no restrictions on content, so music can be part of the programming. Canada also has a licensed, non broadcasting service (RSS123) if you need more power – up to 1 watt – as long as the signal is 100uv or less at the property boundaries. I would imagine that if an RSS210 signal escapes property boundaries (i.e., is more than 100uv), then it would technically not be allowed either (although that isn’t specifically stated in the rules). Because you’re transmitting on private property to targeted listeners, Canada doesn’t consider these services broadcasting.
It should also be noted that I am aware of at least one individual who uses a ProCaster for broadcasting purposes, was visited by the then Industry Canada, and was left to continue. He was given a bit of a hassle, but is still, as far as I am aware, broadcasting today.
In many ways, Canada’s unlicensed transmitting laws are more complicated than those of the U.S.
Total posts : 45366Here the certification lab submits the results and Industry Canada(now under new name) sees the test results and the test lab also attaches the certification to the transmitter.
Mark
Total posts : 45366Wouldn’t a parking lot being outdoors be considered broadcasting to the public?, other than your own personal use? Just wondering.
Also have been thinking that since I called the person I talked to at Industry Canada from my home phone(returned his call), if he had call display and was inclined to check me out he could find out from my name and number my location….Maybe nothing to worry about.
Mark
Total posts : 45366Re the parking lot issue, yes, it does seem to go against logic. But it appears, at least from my interpretation of the rules, that it is felt that if you are broadcasting only on private property, you are NOT broadcasting to the general public. That is what RSS123 is all about, and it is not considered broadcasting (so you don’t have to get the CRTC involved).
Like I said previously, I believe it’s part of the complications of having a body such as the CRTC existing.
If you take a look at the whitespace device proposals for Canada, they even specifically state that these devices are not to be used for broadcasting. Devices such as wireless microphones are for TARGETED audiences (such as church attendees), not general audiences, and thus can be considered not broadcasting.
Go figure.
Total posts : 45366As honked up as the FCC is, at least it’s only one agency.
Total posts : 45366Agreed.
Total posts : 45366Inquired further about transmitters AM and FM and RSS-210/BETS use and certification.
The reason a transmitter that “meets” the rules isn’t compliant is they(the on site inspector) don’t know if a transmitter is actually compliant as with RSS-210 AM especially as they can’t take someone’s word for it that it meets rules and needs the certification they can look up and see that an approved test facility has determined this. Any transmitter you get online from somewhere other than Canada has to be certified to be compliant to use…so I can’t order a Spitfire for example and use it, well I can, but if I ever get inspected they just have to see this isn’t in their data base and say it’s not compliant for use here.
Also in the case of the Procaster which is the only approved AM transmitter for Canada which is RSS-210 certified set up and used as per instructions and according to the certification the thing about broadcasting and not broadcasting would most likely be ignored as it’s use is compliant with the certification unless it’s causing interference. This from an agent. I could use the Spitfire but have to spend $3000 to get the approval…first thing they do is look in their data base and if transmitter isn’t there…..no good.
Now with FM certification under RSS-210 a transmitter is limited to the same as the USA but BETS-1 is more. A transmitter certified under RSS-210 can’t be also used for BETS-1 because of the two different catagories and allowed field strengths.
When I asked about AM, and how the allowed coverage with BETS is potentially less than RSS-210, as RSS210 is like the USA and is transmitter power not field strength and BETS is field strength(250uV/M@30meters) I couldn’t really get an answer to that…..just that we can’t bring techs to your home to go into your transmitter and actually see if it’s really 100mW into the final so we need to see a certification as that’s what we go by. So a follow up question was, with AM you measure more than BETS-1 field strength but I show you a compliant Procaster what would happen?….the operation that is compliant would be allowed…..you can do 250uV/M@30meters OR 100mW into final with 3 meter antenna.
Bottom line…..in Canada any transmitter used has to be certified as that’s the most important thing they look at. That and don’t cause interference.
Mark
Total posts : 45366From Reply 12 of this thread :
… When I asked about AM, and how the allowed coverage with BETS is potentially less than RSS-210, as RSS210 is like the USA and is transmitter power not field strength and BETS is field strength (250uV/M@30meters) I couldn’t really get an answer to that. …
____________
Thanks, and hope that you will investigate this issue further, and post your findings.
Might there be some confusion here between the Canadian Rules applying to unlicensed users of the AM broadcast band vs. the FM broadcast band?
Total posts : 45366No. RSS210 in Canada is for non broadcasting unlicensed use, and essentially is equivalent to the FCC’s Part 15 for both AM & FM.
BETS-1 is for unlicensed broadcasting, and is governed by field strength only for both AM & FM (although each have their own, different, limits). In addition to that, all transmitters used for BETS-1 must have a TAC (Technical Acceptance Certificate) from Industry Canada. That can be either obtained by the manufacturer, or the individual using the transmitter (if a TAC has not been obtained by the manufacturer).
Total posts : 45366The RSS-210 rules have changed effective Aug 2016
https://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf01320.html Section B2
AM band 510-1705KLZ can be either 100mW into the final with 3 meter antenna OR 250uV/M@30meters
There are about 4 conditions and ONE has to be met.
But the main thing is nothing here can “meet” the rules, the proof has to be there with the certification label with number and it has to be in their data base.
This leaves out some of the transmitters you can use in the US as not compliant here.
Mark
- You must be logged in to reply to this topic.
