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WILW Radio Site Updates

> Some new stories in the News and Commentary pages that will
> interest ALL part 15 broadcasters.
>
> www.wilw.com
>

WCWalker,

Why do you wish to re-visit this rant on kits being illegal in 'your' view as you state in your commentary, when we both know this has been stated to death here on this board and other boards about the 'kit' issue?

Has the letter I submitted from the FCC not been sufficient or the email from Kieth Hamilton?

Is there an issue with trying to sell only FCC certified Rangemasters only?

Please inform all of us there!

You will notice that the word 'kit' is in the response of the FCC respondant in charge of Office of Engineering Technology 'OET'. The tracking for this email is below if one wants to review it at the FCC office in Washington!


Original letter from the FCC...


-----Original Message-----
From: OET Generic account [mailto:eek:[email protected]]
Sent: Monday, April 04, 2005 4:25 PM
To: EXT-Rios, Nicolas
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.





Do not reply to this message. Please select the Reply to an Inquiry Response link from the OET Inquiry System to add any additional information pertaining to this inquiry.
 
No, Sorry, looks like they had a policy change, dated Sept 20, 2005. Read the law at
http://gullfoss2.fcc.gov/prod/oet/cf/kdb/forms/FTSSearchResultPage.cfm?id=20992&switch=P

Or do a search on the FCC OET knowledge base for (radio service rules) (part 15 general) (kits)

I'm not going to respond to any ranting about the new policy, I don't want to start another board whirlwind and frankly I'm pretty busy. No we didn't have the law written to sell more of our product, we just try to follow FCC law here, we don't write it. I'm thinking that most people will just do what they want anyway. I do think it is important that people have (no spin) good information about what the law is, some care about that. When the FCC agent comes calling is a bad time to find out what the law really is, & it wasn't at all the heresay you heard on the boards, or an letter from an FCC employee.
Our advice: go to the source, the FCC rules database, not heresay. I realize people will be angry about the new policy but it is still possible to broadcast legally by homebrewing, look into it. The ARRL website has some great information to get started.
 
> No, Sorry, looks like they had a policy change, dated Sept
> 20, 2005. Read the law at
http://gullfoss2.fcc.gov/pro> d/oet/cf/kdb/forms/FTSSearchResultPage.cfm?id=20992&switch=P
>
>
> Or do a search on the FCC OET knowledge base for (radio
> service rules) (part 15 general) (kits)
>
> I'm not going to respond to any ranting about the new
> policy, I don't want to start another board whirlwind and
> frankly I'm pretty busy. No we didn't have the law written
> to sell more of our product, we just try to follow FCC law
> here, we don't write it. I'm thinking that most people will
> just do what they want anyway. I do think it is important
> that people have (no spin) good information about what the
> law is, some care about that. When the FCC agent comes
> calling is a bad time to find out what the law really is, &
> it wasn't at all the heresay you heard on the boards, or an
> letter from an FCC employee.
> Our advice: go to the source, the FCC rules database, not
> heresay. I realize people will be angry about the new policy
> but it is still possible to broadcast legally by
> homebrewing, look into it. The ARRL website has some great
> information to get started.
>


Keith,

I never said you guys were trying to write the rules for selling the Rangemaster!

The so called FCC employee you mention happened to be the Chief Engineer in charge of the Office of Engineering at the FCC!

Below is a post of the above link you added... it's for TV kits' and not for AM or FM broadcasting, read carefully before posting.


Publication Number: 927445 Rule Parts: 15.209 Publication Date: 09/20/2005
First Category: Radio Service Rules
Second Category: Part 15 General
Third Category: Kits
Question: Kits, marketing, unintentional and intentional radiators : What are the FCC Rules for building and marketing of kits of products, which when completed are subject to the FCC Rules?
Answer: 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.
 
Leave it be.

Hello all,

I have read the threads and the Part 15 rules. I see problems with the interpretation of the rules, indeed I see contridictions in the rules. Rather than start a debate about the meaning of this section and the meaning of that section, I suggest we stop the debate now. Leave it be.

Follow the rules as best you can given that there may be problems in interpretation.

We are not going to decide what the law means. Ultimately, the interpretation can be decided in court, and I don't want that to happen. We all may not like the outcome.

Neil
 
Re: The FCC Kits Factor

I verified Radiopilots post not because I did not believe him but to show others .
Logic would have it if was illegal to sell such kits the FCC would go after the biggest fish first, Ramsey being the big fish making and selling debatable quality AM & FM kit transmitter for years.
You can print the document to show an FCC agent in the highly unlikely event you get a visit for your part 15 AM Sstran kit connected to Carl’s antenna.
As I have said in an earlier post our affiliates make heavy use of both Rangemaster and Sstran transmitters. If you are going to use it for a for profit business the Rangemaster is a must because the certification puts a stop to anyone trying to kill your business on the basis it’s illegal.
Another reason the Rangemaster is favorable in a business environment is expandability. The Rangemaster sync ability is a must if you plan on expanding your service area on the same frequency. I have also found it’s easier to convince a business to mount Rangemaster on their roof when they see it’s FCC certified. Businesses interpret the certification to mean they are off the hook with the government in the event of a visit
The Sstran is an outstanding transmitter I have no problem using them, in fact I use them in a marketing business mainly promoting new housing developments where only one transmitter is needed. The Sstran also has one advantage: If someone rips one off them off from you are only out $150 bucks versus $1000+ for the Rangemaster.
I don’t think anyone should blow a fuse over this debate the FCC has spoken. It’s a matter of public record. The FCC really is like the IRS: never the same answer twice!

Returning radio to the people one station at a time.
Steve
RadioBrandy.com

> For those that believe such a response was a fake letter...
> go to the link below and add the tracking number: 621612,
> and the email address: [email protected]
>
>
http://gu> llfoss2.fcc.gov/prod/oet/cf/kdb/forms/ResponseReplyEntry.cfm
>
>
>
>
> See for yourself if the FCC did not respond correctly to the
> issue of the kits.
>
> Radiopilot
>
 
Re: Leave it be.

I'm assuming that most people go to school to learn to read "understand" not just articulate words that they see.

15.25 permits the use of "kits" IE: a design made by the user and the FCC understands such user does not have the test equiptment to follow the radiation limits so they are "ussualy" more understanding if you are over ;). now the catch if you use kits that are sold you have to follow 15.209.

this is rediculious that we are going back to this topic. it is out in the clear that some people have no clue how to market a product so they misinform people or they just bash other prducts.

Can we please have a board that has topics on technology or programs some mumbo jumbo about part15 radio please????


because these debates all end up being, "who has the biggest weener between their legs"













> Hello all,
>
> I have read the threads and the Part 15 rules. I see
> problems with the interpretation of the rules, indeed I see
> contridictions in the rules. Rather than start a debate
> about the meaning of this section and the meaning of that
> section, I suggest we stop the debate now. Leave it be.
>
> Follow the rules as best you can given that there may be
> problems in interpretation.
>
> We are not going to decide what the law means. Ultimately,
> the interpretation can be decided in court, and I don't want
> that to happen. We all may not like the outcome.
>
> Neil
>
 
Re: Leave it be.

Hi Viberadio,

You wrote:

"I'm assuming that most people go to school to learn to read "understand" not just articulate words that they see."

Maybe you could help me understand what you wrote.

Thanks

Neil
 
Re: Leave it be. To Viberadio

Hi,

I broke my comments into two posts on purpose.

You wrote:

"Can we please have a board that has topics on technology or programs some mumbo jumbo about part15 radio please????"

Aren't we saying the same thing?

Neil
 
Re: Leave it be.

come on, you are just being funny. :)



> Hi Viberadio,
>
> You wrote:
>
> "I'm assuming that most people go to school to learn to read
> "understand" not just articulate words that they see."
>
> Maybe you could help me understand what you wrote.
>
> Thanks
>
> Neil
>
 
Re: The FCC Kits Factor

> I verified Radiopilots post not because I did not believe
> him but to show others .
> Logic would have it if was illegal to sell such kits the FCC
> would go after the biggest fish first, Ramsey being the big
> fish making and selling debatable quality AM & FM kit
> transmitter for years.
> You can print the document to show an FCC agent in the
> highly unlikely event you get a visit for your part 15 AM
> Sstran kit connected to Carl’s antenna.
> As I have said in an earlier post our affiliates make heavy
> use of both Rangemaster and Sstran transmitters. If you are
> going to use it for a for profit business the Rangemaster is
> a must because the certification puts a stop to anyone
> trying to kill your business on the basis it’s illegal.
> Another reason the Rangemaster is favorable in a business
> environment is expandability. The Rangemaster sync ability
> is a must if you plan on expanding your service area on the
> same frequency. I have also found it’s easier to convince a
> business to mount Rangemaster on their roof when they see
> it’s FCC certified. Businesses interpret the certification
> to mean they are off the hook with the government in the
> event of a visit
> The Sstran is an outstanding transmitter I have no problem
> using them, in fact I use them in a marketing business
> mainly promoting new housing developments where only one
> transmitter is needed. The Sstran also has one advantage: If
> someone rips one off them off from you are only out $150
> bucks versus $1000+ for the Rangemaster.
> I don’t think anyone should blow a fuse over this debate the
> FCC has spoken. It’s a matter of public record. The FCC
> really is like the IRS: never the same answer twice!
>
> Returning radio to the people one station at a time.
> Steve
> RadioBrandy.com
>
> > For those that believe such a response was a fake
> letter...
> > go to the link below and add the tracking number: 621612,
>
> > and the email address: [email protected]
> >
> >
> http://gu>
> llfoss2.fcc.gov/prod/oet/cf/kdb/forms/ResponseReplyEntry.cfm
>
> >
> >
> >
> >
> > See for yourself if the FCC did not respond correctly to
> the
> > issue of the kits.
> >
> > Radiopilot
> >
>

For the FCC to ban transmitter kits is practically un-American. I mean, kids have been building receiver and TX kits for decades. Even I built a Heathkit FM transmitter (with the clear plexiglass cover)as a boy. Future engineers were spawned on those kits.

While it's good to know that this isn't happening, it wouldn't surprise me if it did given NAB lackey Marsha McBride's comments at the IEEE Broadcast Symposium a few days ago. She cited three major forces threatening broadcast space today, one of them being unlicensed devices.

I have no doubt the NAB would love to see a ban on the use of part-15 TX's and would influence the FCC in that direction if they could.

BTW, as wonderful as having a type-accepted TX is, I notice that whenever the FCC does a field check on an unlicensed broadcaster or writes up an NAL, it's all about signal strength at a given distance; they never comment on whether a TX is type-accepted or not. And I think, this is the key: keeping it legal, not type-acceptance.

I also think that part-15 on FM is a dead loss and a waste of time (except for yardcasting), particularly in urban areas, given the FCC enforcement stats: over 91% of the FCC busts were for illegal FM users, while only 6% of the busts were for LW and MW combined. FM is clearly radio's closely guarded 'golden boy' (and AM the forgotten step child).

db
 
Re: Leave it be.

> come on, you are just being funny. :)
>
>
>
> > Hi Viberadio,
> >
> > You wrote:
> >
> > "I'm assuming that most people go to school to learn to
> read
> > "understand" not just articulate words that they see."
> >
> > Maybe you could help me understand what you wrote.
> >
> > Thanks
> >
> > Neil
> >
>
Yeah, you caught me.

Neil
 
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