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L. P. Ryan / Low Power Radio cited by FCC for selling pre-built AMT 3000

Years ago, I bought some Ramsey kits at the Dayton Ham Fest and put them together.
I hooked up test gear and checked them out. Bad news! Spurs and harmonics. Scary.

I see someone has filed a complaint again.
 
"F" the FCC, they have many bigger fish to fry if they were not so affaid of the Mega Broadcasters. No it's much easier to pick on the little guy, lets face it Hobbytron or Dr Johnny are allot easier to beat up.
Its never been done before but radio Brandy is about to endorse a presdential canidate, we should not for get who are friends are.
I will take Ramseys Spurs and harmonics any day over the crap being fed us by the NAB.

Radio Rebel since 1983
Steve
P.S. Always where a RF condom before broadcasting, it could save fine!
www.radiobrandy.com
 
This is ridiculous and really makes me wonder about the FCC effectiveness.!!!! Up in the North Jersey area there are pirates broadcasting at FULL POWER to all five boroughs - one in particular is on 91.9 and broadcasts some religious programming. All you hear in very distorted audio is constant shouting and screaming - ALL OVER NYC. Don't you think that this may be a little more important than poor Mr. Ryans miili-watt transmitter??? Come on! It makes me have no respect at all for the FCC.


Jim
 
Hold on! The FCC is made up of guys just like you and me. They are required to respond when people make complaints. The NAB has filied legal comments that have opposed some rules that were in the public interest. True. Commercial radio is bad and getting worse. True. But it's not commercial radio or the NAB that is bringing FCC enforcement down on part 15. Until you guys see that the problem is from within your
own low power cause, you won't be able to get your act together! Most part 15 complaints are filed by other part 15ers. And most pirates are turned in by other pirates says the FCC.

Many of these little kit builders never dreamed that they would be charged under rules meant for factories.
 
As a follow up to this case, today the FCC issued a 'denied petition for reconsideration' order against Mr. Ryan.

It seems, according to the FCC, that building the components of an AMT 3000 without a final assembly (that is, not putting the completed circuit boards into the case) does not circumvent the agency's prohibition on selling pre-built uncertified transmitters.

Mr. Ryan had advertised a partially assembled AMT 3000 on his website.

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-08-968A1.pdf

C5
 
Was another certified low power transmitter manufacturer well known that turned Mr. Ryan to the FCC dogs... It's a crying shame to have this done in the name of greed, Mr. Ryan was only doing this as a favor to those who could not assemble their own kits!

Radiopilot
 
Did you guys know that type certified is only required for the sale of transmitters to you LPAM and LPFM stations?
The big boys station equipment does not have to go through all those very expensive tests.
L.P. Ryan was hung on a legal technicality. He shipped it. He had an internet site. I'm sure the FCC hated to
do it. But they have to answer complaints. 100 mw toys! Poor guy! I feel for him!
 
Flying-Dutchman said:
Did you guys know that type certified is only required for the sale of transmitters to you LPAM and LPFM stations? The big boys station equipment does not have to go through all those very expensive tests.
Click to expand...

Maybe you are writing about "Part 15" AM/FM transmitters and systems. Such don't necessarily need to be tested, but they still need to meet the requirements given for them in 47 CFR Part 15.

The FCC does license true LPFM stations. But don't such stations still need to use FCC Type-Notified transmission equipment -- the same as for all classes of FM broadcast stations licensed by the FCC?

From my first-hand experience, the equipment tests and documentation needed for FCC Type Notification of licensed commercial and LPFM transmission equipment is much more rigorous and expensive than required for certification under Part 15 FM.

R. Fry -- FM Applications Engineer (retired) , Harris Broadcast Division FM Product Line - Quincy, IL

//
 
Couldn't he have complied by leaving just one part off the board?
A soldering pencil and solder, 5 minutes of work would complete the xmttr.
Soldering in ONE part is not beyond the ability of the average person.
It is no more difficult than making a sandwich.

I once paid a $1000 N.A.L., and the memory still feels bad, but I guess at least I had a LOT of fun for my money.
I wish I could fine the FCC or Police for the vandalism they did to my car the night of their visit,
but I suppose I should be happy they did not seize any equpment. As it was all hand-built, they did seem to respect that
part of the picture, and they probably figured I could just build another if I chose.
In 30 years of owning that car, the only time it has ever been hurt by anyone was on the night the FCC visited, and when I went to move the car later that evening, there was no juice. They had taken a torch to the positive battery clamp, melted the lead and pulled
the cable out of the clamp.

Could I have sued them at the time? I still have the clamp, which I had dreamed of sending through the FCC's windows facing the Illinois Tollway using a wrist-rocket slingshot. Good sense prevailed, but I wonder how may other enforcement actions have been
accompanied by "official" vandalism such as this? Maybe they already had decided to hit me there, and gave me a lower fine, to get the message across without so much monetary damage inflicted. How did they know for sure it was my car?
It had a short-wave converter under the dash. I was on 7.415 Mhz.

I don't suppose Mr Ryan made anywhere near enough selling these to cover the fine.
 
Mr Fry, I have great respect for Harris equipment. I used Harris transmitters and Harris ERI antennas at every commercial
station I ever built.

But, licensed LPFM stations must use part 73 certified transmitters. My commercial stations only needed part 73 verified.
Verified means a model has passed FCC specs. Certified means the individual unit was tested and passed. This means
about $1,000 extra for the cost of an LPFM transmitter over one of the same power for a translator.

Certified is extra and was prposed by the NAB. And I know because I took part in the FCC rulemaking process for LPFM.
 
Hi Tom, Ryan could have left some parts off and it would have still been a kit. The shame here is he got it for a
marketing violation, not dangerous spurius equipment.

7.415. How much power? Did you meet Chicago's George Sklom of the FCC? He was a friend to me. George
Sklom converted me from a pirate to a legal FM station owner 20 years ago. He really was a great guy.

former owner, WKLU Indianapolis
 
There were two FCC agents, and two Chicago police officers.
One of the agents was a white man, about 60-ish, who we remembered as looking like Burl Ives.
The other agent was black, maybe 50-ish with hair going a bit gray.
I never got their names that evening, I was in that "special condition" that one gets when the FCC arrives unexpectedly.

Their demeanor changed quickly once let in and they saw I had not just put any old ham gear on the air.
They immediately notched down their attitude to more relaxed.

"Where did you learn to do this?" was one comment.
"I don't think I'll be able to get a frequency reading or power measurement off this," was another.
And.."How do you get it to do FM?"
With any commercial gear it would have been easy to determine these things..
Then they asked, "Which part is the transmitter?" It was all spread out on a long teak coffee table, Bogen 100w audio amp,
250w RCA mod xformer, ring stand 1930's microphone, 1920's candlestick carbon mike, mixer and the transmitter proper.

It was a 6 tube open-breadboard transmitter that looked straight out of 1933 with link-coupled stages, hand wound coils,
the output was a pair of 6L6s at 750v that would barely behave in class C, but ran dull orange and gave 95 watts out.
I was in a two flat where the landlord OK'd my roof antenna experiments, the length of the building was perfect for a 40 dipole.
I used a low-pass filter, and was pretty clean. I had perfected a slight coupling of audio back into the osc, so I was AM and
narrow band FM. It sounded good in AM, but REALLY good in NBFM.

I would have to turn it off if my upstairs neighbor wanted to watch TV, etc. We were on very good terms, and she didn't mind as long
as I was accomodating and would shut down for her. But I'm sure it must have gotten into phone lines and other people's electronics.
100 watts is too much power for AM in a dense city neighborhood. Glad I have few airchecks somewhere.
I disassembled the xmitter soon after to lessen the temptation. I kept the output air-wound tank coil, which hangs from a hook
in the basement above the audio/radio part 15 "control room" console. I now look at it and it brings back memories.

When I went to work for Harris Graphics (web presses), which had been split off Harris, I considered staying a year or two, then applying to Harris RF.
Kinda glad now I didn't. I stayed in printing, and it has been good to me.
 
Flying-Dutchman said:
But, licensed LPFM stations must use part 73 certified transmitters. .... Certified means the individual unit was tested and passed. This means about $1,000 extra for the cost of an LPFM transmitter over one of the same power for a translator.
Click to expand...

It is true that LPFM stations must use type-certified transmitters. Quoting Part 73.1660 (2) "An LPFM transmitter shall be certified for compliance with the requirements of this part following the procedures described in part 2 of the this chapter."

However the description for verification as shown in Part 2.907 states that the certification applies to all subsequent units. So later individual units would not need to be re-tested if they met the conditions shown in 2.907 (see paste below).

TITLE 47--TELECOMMUNICATION

CHAPTER I--FEDERAL COMMUNICATIONS COMMISSION

PART 2--FREQUENCY ALLOCATIONS AND RADIO TREATY MATTERS; GENERAL RULES AND REGULATIONS--Table of Contents

Subpart J--Equipment Authorization Procedures

Sec. 2.907 Certification.

(a) Certification is an equipment authorization issued by the
Commission, based on representations and test data submitted by the
applicant.
(b) Certification attaches to all units subsequently marketed by the
grantee which are identical (see Sec. 2.908) to the sample tested
except for permissive changes or other variations authorized by the
Commission pursuant to Sec. 2.1043.
...
 
Here's what that means. The fine Harris exciter that is legal for a full power FM is not legal to use for a
LPFM. This assures that the LPFM people have to pay extra for type certification that no one else does.

The kit builders cited in this thread were cited for breaking rules concerned with marketing. it's not that
the FCC found they built bad transmitters.
 
Flying-Dutchman said:
Here's what that means. The fine Harris exciter that is legal for a full power FM is not legal to use for a
LPFM. This assures that the LPFM people have to pay extra for type certification that no one else does.
Click to expand...

But even if LPFM stations could use type-verified equipment, a small portion of the cost of the initial type verification tests would be a part of the price paid for the unit they bought -- just as with type-certified equipment.

In neither case does extra testing need to be done on each unit sold, as long as each one is identical to the original unit that was tested. So LPFM operators are treated no differently than "full-power" FM operators.

//
 
R. Fry said:
Flying-Dutchman said:
Here's what that means. The fine Harris exciter that is legal for a full power FM is not legal to use for a
LPFM. This assures that the LPFM people have to pay extra for type certification that no one else does.
Click to expand...

But even if LPFM stations could use type-verified equipment, a small portion of the cost of the initial type verification tests would be a part of the price paid for the unit they bought -- just as with type-certified equipment.

In neither case does extra testing need to be done on each unit sold, as long as each one is identical to the original unit that was tested. So LPFM operators are treated no differently than "full-power" FM operators.
//
Click to expand...


OK! Then go ahead and build an LPFM with the same Harris exciter that you could use at a full power FM or translator.
Just don't ask me to put my name on the application for the license. I don't want to be liable for a fine.
 
Flying-Dutchman said:
OK! Then go ahead and build an LPFM with the same Harris exciter that you could use at a full power FM or translator. Just don't ask me to put my name on the application for the license. I don't want to be liable for a fine.
Click to expand...

That idea can be found nowhere in what I posted, sorry. What I wrote is that LPFM and full-power FM both pay a portion of the cost needed for FCC acceptance of their transmitter. LPFMs pay nothing "extra," as you stated.

As I wrote, LPFMs must use type-certified equipment, and full-power FMs must use type-verified equipment. They are not interchangeable.

//
 
A phone call to FCC engineers at 202 418 2700 has confirmed for me that type certified for
Low Power licensed FM is indeed above and beyond type verification for other broadcasters.
Type Certified LPFM equipment is verified plus. This means you can use the certified tranmitter
at any licensed station. But you can't use the verified at a LPFM.

Dutch, Mr Fry will keep you locked in a word game on a sit and spin for months if you let him.
 
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