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I know this has come up before, but I’m still not sure.
I believe ‘Antenna Guy’ posted that the FCC had responded that kits were OK. What was the actual response?I know this has come up before, but I’m still not sure.
I believe ‘Antenna Guy’ posted that the FCC had responded that kits were OK. What was the actual response?The FCC web site quotes the following:
47 CFR 15.25 set forth provisions for marketing of a kit for a TV Interface Device. Under 47 CFR 15.23, individuals are permitted to construct a device for personal use without seeking equipment authorization from the Commission, but it may not be marketed as a kit. All other devices subject to certification (whether marketed as a Kit or not), must be certified under 47 CFR Subpart I of Part 2.
This would seem to indicate that kits are NOT allowed. So how come kits continue to be sold without FCC interference?
Also, if a kit was supplied that had the PCB already assembled and that all the user had to do was finish off the final transmitter assembly, would that still count as a kit? The reason I am asking is because I would like to offer a kit like this. Any opinions/help would be much appreciated.
Gerry
Total posts : 45366Part 15.23 allows for an individual to build up to 5 kits for personal use only,not to be marketed,and do not require certification. All marketed transmitters need to be certified. The cost of certification will change your mind quickly! Regards,Lee
Total posts : 45366Is the SStran unit certified?
Total posts : 45366Nope. Its a grey area for the rule interpritation. Does a marketed kit meet the kit requirements of the rules? I am not sure. Is it legal to sell uncertified kits? Again,not sure. It may be “compliant” meaning it was built to conform to the rules,but I am not sure where that will leave you if you get busted. You will have to read the rules and draw your own conclusion,tempered by the FCC’s past enforcement actions. Phil of SSTrans says its legal,but that wont help you if the FCC fines you for non-compliance. Clear as mud???
Just maybe Phil will chime in here……..
Regards,Lee
Total posts : 45366if you watch the reports, the FCC *does* bust companies and people selling kits, but it always seems to be when the kit clearly results in operation that is not part15 compliant.
That is not to say they may not go after the person who built it as well, that probably depends on the situation. But they certainly do fine manufacturers and sales places that put out kits that are over-power and etc. In all the cases I can recall, it was where the kits or units would def operate outside part15 rules.
By observation, it seems that the FCC’s actions are largely complaint driven. If someone selling a kit that is resulting in a lot of interference complaints or a lot of the tranmitters being built from them being found to be over allowed part15 power limits for the band they are in, I am quite sure that they definitely would find the manufacturer or seller and take whatever steps they consider appropriate.
But when it’s causing no problems? Maybe they *could* by some interpretations of some of the rules the rules, but why would they want to? The FCC does not exist to keep the airwaves from being used. The rules and regs explain how they may be used and what will get you in trouble and what won’t. They’re there to make sure communication can happen, and the rules are there mostly to prevent interference and/or misuse. Part15 operation is allowed under the rules within the specified limits and etc.
The rules for part15 kits *also* covers part15 for some services where it seems no homebrew is allowed or it is very discouraged. For instance, there are part15 devices that operate on the 11 meter CB band. Notice you rarely if ever see anyone selling actual kits for making a CB band walkie talkie? I think I saw one years ago, but it was basically a non-user built module that you assembled by putting it into the case and etc. Or how about cell phones? I think you can still get a no-frills one from some of the companies providing cell service via prepaid cards for around 20$? Ok, logically if a manufactured unit can be that inexpensive, then there could be a kit or homebrew one, but if there is I’ve never heard of it.
Now since Phil’s kits have come up in the discussion, let’s consider. Phil knows his stuff, and it’s probably safe to say that the instructions for building and adjusting his kit are clear and if followed carefully will not result in power to the final RF amplifier stage in excess of the allowed 100 milliwatts. I’d further bet that the output is clean in that out-of-band emissions are well below the allowed limits.
Kits are perhaps a gray area, but if their operation is causing no interference or problems, then the odds of there being trouble are at least considerably smaller. If some sstrans made from Phil’s kits were causing problems, I’d bet they’d be in touch with him shortly. It’s not like he’s hard to find, considering he has a website contact info and posts in public forums, and his name and will come up in probably any search for info about his kits.
On the other hand, I recall not long ago seeing mention of the FCC hitting a company that had a website and was selling kits to make “police radar jammers”. I believe their website tried to claim they were part15 devices and legal because they put out less than 100 milliwatts. The FCC got a kit, built it, checked it and found it did indeed jam police radars and as such it was a kit to build a device for intentional harmful interference with a licensed service (police radar def being licensed) and was not operating on frequencies allowed for part15. Boom, down they went.
So it’s not like they aren’t on the lookout for kits to build clearly illegal devices or ones that would cause problems, and I figure it’s probably fairly certain they would have been in touch with Phil by now if they viewed his kits as being a source of problems.
But bear in mind that any time that we’re sitting here second-guessing the FCC and how and/or why they’d enforce the rules, it’s *just* guesswork. Don’t take any of it as sure legal advice or anything of the sort.
But they definitely do seem to go after people who sell bad kits.
Daniel
Total posts : 45366Thanks Daniel,
Based on what I have read, I think your points sum up exactly what the FCC does do. By their actions, they definitely do not follow their written rules ‘to the letter’ or some of the installations and devices marketed would not be around. Phil’s unit is great and no doubt the FCC folks appreciate good equipment.
I’m feeling more comfortable marketing the kit I have in mind without getting FCC certification – the cost is quite high. But I’m still wondering if a fully assembled board (surface mount) as a ‘part’ of the kit is acceptable – don’t see why it would make any difference. The advantage of this is that novice builders would have one less technical hurdle to overcome and at the same time would reduce the chance that the transmitter ends up exceeding the FCC Part 15 limits. The user would just do the final assembly and tuning as per instructions.
What do you think?
Neil, what are your thoughts?
Gerry
Total posts : 45366So, what is your kit? A transmitter, or something else?
Total posts : 45366This kit would be an external AM Part 15 transmitter.
Some of the features I am considering…
weatherproof case (UV and IP67)
compact size for minimum mast loading
102″ sectional aluminum antenna
10kHz channel spacing (9kHz optional)
auto power adjust
compressor/limiter
600 ohm input
mounts on standard 1.5″ dia mast
12VDC supply and audio over standard 4-con telephone wire
litz wound antenna loading coil
lightning protection
worldwide shipping
SMT/thru hole mix (SMT would be pre-installed on PCB)
Price TBDAny suggestions/wishes??
Gerry
Total posts : 45366—–Original Message—–
From: OET Generic account [mailto:oetech@fccsun34w.fcc.gov]
Sent: Monday, April 04, 2005 4:25 PM
To: ***********
Subject: Response to Inquiry to FCC (Tracking Number 621612)Inquiry:
Hello, I am inquiring about a kit used for AM broadcasting and the kit”s spec are 100mw to the final stage with the included antenna of 3 meters and the ground…. Now Part15 Rules 15.3 indicates (p) Kit.
Any number of electronic parts, usually provided with a schematic diagram or printed circuit board, which, when assembled in accordance with instructions, results in a device subject to the regulations in this part, even if additional parts of any type are required to complete assembly; and
Part 15.219 indicates: Sec. 15.219 Operation in the band 510-1705 kHz. (a) The total input power to the final radio frequency stage (exclusive of filament or heater power) shall not exceed 100 milliwatts. (b) The total length of the transmission line, antenna and ground lead (if used) shall not exceed 3 meters. (c) All emissions below 510 kHz or above 1705 kHz shall be attenuated at least 20 dB below the level of the unmodulated carrier.
Determination of compliance with the 20 dB attenuation specification may be based on measurements at the intentional radiator”s antenna output terminal unless the intentional radiator uses a permanently attached a! ntenna, in which case compliance shall be deomonstrated by measuring the radiated emissions.
Now does this mean as long as I buy one kit, build it under the manual for assembly and set it according to the above specs… am I legal to transmit under Part15 Rules?
Please indicate where I would be violating the rules?
Thank you,
**************
Response:
Yes, It is legal to transmit under part 15 Rules with a kit (used for AM broadcasting) that you build under the manual for assembly and set it, which meet the specification. Use the tracking number to trace it at the FCC website for verification.
This debate I thought was settled awhile back… but it surfaces everynow and then… The moderators of this board should put this letter in the ‘library’ section…
The above original post is for TV Interface Kits and not for AM Intentional Radiators…
Radiopilot
Total posts : 45366Thats a big assumption that AM BCB transmitters are ok based on a response for a TV kit. Its not one I would count on. But I do agree with Daniel’s comments,bad attention will get you busted,quickly. The FCC is a complaint driven agency. Regards,Lee
Total posts : 45366Lee,
I don’t know if you were responding to my comment about AM transmitters being excluded from 15.25, but if you were, I did not say nor intend to imply that AM transmitter kits were OK due to this omission; rather I was thinking the opposite. That’s why I prefaced it with “unfortunately”.
Hope that helps.
Neil
Total posts : 45366Some previous discussions:
Two patterns I’ve seen
1. A company that earns money from selling a kit or finished product that will violate part 15 when operated will get clobbered by the FCC – example, Hobbytron, Ramsey
2. Firms selling kits without FCC type acceptance that make a good faith effort to produce part 15 compliant products seem to get very little grief – example, PanAxis, SSTRAN, Vintage (Gizmo and Metzo) & EDM
It seems to help a lot if the product requires a good bit of tech savvy to assemble and use, where as ready-built and plug and play get more scrutiny.
Experimental broadcasting for a better tomorrow!
Total posts : 45366Thanks for your input. (you are the right Neil). My decision is veering towards a kit and then if this is successful, maybe certification and a ready built offering. I also have ideas for some add on units. I am also concerned (as you have posted) if the LPAM movement gets going – the airwaves will shrivel up for us Part 15ers. Also concerned with the FCC changing the rules as they now stand, e.g: field strengths.
BTW, I have been in this Part 15 business for a number of years having designed the TalkingSign unit (www.talkingsign.com) intended for realtors. This was a tough slog because these guys seem to be a cheap bunch and prefer their trusted method of sending out flyers and key fobs with their picture on etc. This unit was certified with the FCC and Industry Canada at considerable expense and I’m leery of paying this tax again! It’s a great transmitter, but because it has digital message storage, people think it does not have the range (wrong) – it’s a 100mW transmitter. Some of the best bargains around are realtor units often for sale on Ebay.
Also, what is the size of this Part 15 market? – there does seem to be a lot of activity on this board. Because this type of equipment is for a low quantity niche market, the price cannot be too low otherwise it’s not worth doing – product support can eat into a lot of your time with all sorts of questions asked even if you put FAQ on the web site. Phil’s AMT3000 is an absolute bargain at $89 (I think it’s too cheap!). Rangemaster is at the other end of the price range. There seems to be nothing in between – this is where I would like to aim for.
Enough rambling 🙂
Gerry
Total posts : 45366I have no idea what the size of the market is, but it must be of some size. It obviously supports the SSTRAN, Rangemaster, Gizmo, Talking Sign, Talking House, Ramsey, etc.
I think a unit that combines the best of the SSTRAN and Rangemaster and sells for an affordable price would be a big hit. You probably would take away business from all parties. If it was type certified and still reasonably priced, you probably would capture the Rangemaster market.
Total posts : 45366My suggestions:
First, I would like to see a unit that works as well as the SSTRAN (can’t comment on the Rangemaster, as I don’t have one). Second, I would like to have the capability of linking multiple units (like the Rangemaster). Third, I want to buy selected major subassemblies (I may only want the xmitter). Fourth, it should cost much less than the Rangemaster. If I want to put up several units to cover my small town, I cannot afford the Rangemaster price.
Edit: One other wish. Make the output stage as efficient as possible. Every milliWatt helps.
You asked 🙂
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