- July 10, 2018 at 1:34 pm #104987
Canada’s unlicensed intentional radiator regulations for the broadcast bands (AM & FM) are a dog’s breakfast. They can be very confusing, as the official words are spread out across multiple documents, and manufacturers intentionally or unintentionally make the waters even more murky.
Canada distinguishes between broadcasting applications, and non broadcasting applications. That is the key. The definition of broadcasting is not definitive; it is considered anything that can be listened to by a member of the general public.
The reason for this split is that Canada has a regulatory body that is responsible for broadcasting programming, or content. A licensed broadcaster has to obtain an Industry Canada license and a CRTC license.
The BETS-1 rules define the technical requirements for unlicensed broadcasting. And if you are using a transmitter certified for BETS-1, then there is an exemption from requiring a CRTC license. BETS-1 defines a maximum permissible field strength only; 100uv/m@30 meters for FM, & 250uv/m@30 meters for AM.
Transmitting intended for yourself only is not considered broadcasting. How you determine whether your intent is to transmit to yourself is not defined; I suppose if you have an elevated outdoors antenna, then it might be difficult to convince an Industry Canada inspector that you were intending to transmit only within your house and yard. Although I’d try, particularly if I didn’t let it be generally known that I was doing it. Now, if you’re sending out flyers to the neighborhood, and advertising, that would be a problem.
Transmitting to a targeted audience within a confined space, such as a large building (i.e., church), arena, or even a shopping mall is also not considered broadcasting. These uses therefore do not require a CRTC license.
RSS210 contains the regulations for unlicensed, non broadcasting use. They are very similar to Part 15 in the U.S.
RSS123 is a licensed (from Industry Canada) form of RSS210, which allows more power within a confined space, and defines the maximum field strength at the confined space boundaries. Up to 1 watt is permissible.
Unlicensed, low power FM broadcasting in Canada is actually much more useful than in the U.S., as the BETS-1 rules are more generous than the corresponding Part 15.239 ones. Decade made & still makes the only available BETS-1 certified FM transmitter, the MS-100. The previously available CM-10 is discontinued (I have one).
Unlicensed low power AM broadcasting is a problem, as the maximum permissible field strength is barely above noise levels in most populated locales. There are also no BETS-1 certified AM transmitters, which Industry Canada requires.
The RSS210 rules contain a provision similar to Part 15.219 for AM, but technically you are not allowed to use these transmitters for broadcasting. The ONLY AM transmitters that can legally be used in Canada are RSS210 certified, and include the ProCaster and the Talking Sign.
There were, and still are, some RSS210 certified FM transmitters. The maximum allowed field strength used to be identical to BETS-1, but revisions have cut that back to Part 15.239 levels (250uv/m@3 meters). However, transmitters previously certified under the old rules are still permissible, and those include the Whole House 3, the Lamdmark FM350 (I have one of those), etc.
The biggest problem with RSS210 certified transmitters, if you want to be strictly legal, is intent. If you are intending to have members of the general public listen to your transmissions, then theoretically you should be using BETS-1, and then there are not many options available to you. The good news is that, in 12 years of operation, I’ve only heard of one incident (it was directly from the horse’s mouth, so to speak) where someone was told to stop broadcasting with an RSS210 transmitter (a ProCaster). And when they explained there were no AM BETS-1 options available, Industry Canada backed off. Still, not every Industry Canada agent is the same (much like FCC agents), and everyone needs to be aware of the potential problem.
RSS123 allows transmissions to cover large confined spaces, such as shopping malls. They’re intended for FM use. Up to 1 watt may be used within that confined space, as long as the field strength of your signal at the space boundaries is 100uv/m or less. RSS123 does require an Industry Canada license (basically, a general radio license) and it has a yearly fee.
Of course, all of this just defines the transmitting licensing requirements in Canada. It does not touch upon the copyright licensing requirements, which again can be very complicated, particularly if you also stream over the Internet.
Canada does like to keep the lawyers busy.
- July 10, 2018 at 2:10 pm #104999
At least the agent understood the argument that there are no BETS-1 AM transmitters(why I wish I knew) and let the owner keep “broadcasting”. After all setting it up as per the manual and as certified to be used and then being told you can’t broadcast doesn’t make sense.
With FM fortunately if you are “broadcasting” with a RSS-210 certified transmitter and are told you have have to stop you couldn’t get away with that as there is a BETS-1 certified transmitter available.
By the way the RSS-210 version that had the choice of the same field strength as BETS-1 was in 2007. The wholehouse 3 was certified here after that when a newer amendment was in effect which didn’t have that option anymore. Also the Waio was certified with that still in effect (2007)
- July 10, 2018 at 3:32 pm #105000
Oh yes, I should add that in the BETS-1 document there’s a provision that if you have a transmitter(like the Procaster) that’s not BETS-1 certified you can apply to ISED(Industry Canada) for a broadcast certificate to allow you to use a particular transmitter under BETS-1 but I never looked into what is involved in getting this.
Not all is lost as there seems to be a road you can still take.
- July 10, 2018 at 3:53 pm #105001
Thanks Mark. I had forgotten about that proviso. I’m not sure what getting a TAC (Technical Acceptance Certificate) would mean in terms of procedure and cost, but it is an avenue one can pursue, if necessary.
The only reason I can see going down that road would be for BETS-1 AM, however. Rich has stated that you need a 100uv/m field strength for acceptable reception in urban environments, because of background noise. That might give you a range of 60-75 meters at best, which is not very useful for broadcasting.
BETS-1 FM, even with it’s lower field strength, gives you much greater range due to better quality receivers, and much lower noise backgrounds (plus better building penetration).
There’s really no reason to use BETS-1 AM in Canada.
Currently, I use an RSS210 transmitter to broadcast to myself, in and around my neighbourhood. Both my antenna and transmitter are indoors, on the 2nd story of my house, in front of a window. If someone chances to come across my signal, so be it. I don’t advertise its presence. As far as I’m concerned, that’s good enough to meet the non broadcasting aspects of RSS210.
- July 10, 2018 at 9:06 pm #105032
I read when reading through all this awhile ago that if you are indoors and the intent is in your house or your own property like the yard but your signal gets out to the general public even unintended it is considered broadcasting.
After all If you have an RSS-210 transmitter or a Decade sitting on that same shelf by a window, the only difference between the two is a technicality.
That part about applying for a broadcast certificate is with Industry Canada(ISED) not a separate lab that charges $3000. Since I use the Decade I never had a reason to look into this. As for AM I think you are pretty safe using a Procaster and if used as certified I can’t see an agent not allowing it on the broadcasting technicality. But I guess if he/she wanted to be mean could just say you need a broadcast certificate. Maybe I should find out about this……it’s got my curiosity now.
I use the MS-100 by a window with the intent of getting out to the public, I could also set it up outside with no worries. I advertise on the mailbox with a homemade sign that it’s there and I sound like a regular station(jingles Id’s), no worries.
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