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Post by Druid Hills Radio on Mar 20, 2018 19:14:49 GMT
I am waiting for an answer from the FCC Laboratory. The issues is not how it's used. This is what I sent the FCC:
"Good Afternoon,
Several Part 15 operators and I are having discussions about the legality of importing certain low power am transmitters for current carrier use. Based on my previous life in compliance testing it’s my opinion that importing these devices without applicable evidence that said devices have been tested to show compliance is illegal.
Can you help clear this up. "
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Post by Deleted on Mar 20, 2018 20:25:07 GMT
DHR reports: "I am waiting for an answer from the FCC Laboratory."
Very professional on your part.
Up to the high standards of the ALPB.
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Post by Deleted on Mar 21, 2018 0:24:31 GMT
Druid Hills said "for current carrier use".
I suppose as long as the carrier is current...
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Post by Deleted on Mar 21, 2018 0:59:45 GMT
One Small Flicker of a Bicker
While we await FCC response to Druid Hills inquiry, there is one statement which I find exactly not correct... DHR said: "The issues is not how it's used."
By my reading the issue is precisely, entirely and only "how it is used", in this case involving carrier current use.
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Post by Boomer on Mar 21, 2018 5:34:39 GMT
This i the Greek transmitter that I thought Carl was referencing but it's different.Any opinions on this one? That's it, looks like the same yellow 'Civil Defense' model I'd seen a picture of a year or two ago, except now it's 20 watts instead of 10W. Not much in the way of opinion here, I haven't had experience with it, but it looks like the circuit style is similar to what The FOX AM 20 uses. With that you get a Direct Digital Synthesis frequency generator, low level modulation with a linear power amplifier to bring the signal up to 20 watts. Since the modulation happens before the power amp, the amp is like an isolation stage, so the modulator isn't as affected by how the output is tuned, or hum from the AC line being fed back through the coupler, and it will tend to sound good across the whole AM band. I'd consider this to be like a more modern Radio Systems TR-20 with a digital VFO tuner. Boomer
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Post by Boomer on Mar 23, 2018 10:58:17 GMT
Not long after the yellow 20 watt transmitter came up here, I noticed it was sold. Good wishes in broadcasting for anyone here who might have bought it, have Part-15 fun..
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Post by Deleted on Mar 23, 2018 14:54:56 GMT
What's Up Must Come Down
The Greek Transmitter Manufacturer discussed earlier quoted $560 U.S. dollars for the Model AM-20, and we notice the same company, pll.gr, is selling the same transmitter for $500 U.S. on Ebay.
KDX Worldround Radio is on the fence, at times deciding to obtain one of these units to get back on our carrier current channel, at other times thinking about pocketing the money and repairing our two LPB transmitters.
We may put the decision to aan ALPB poll.
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Post by Boomer on Mar 24, 2018 18:55:43 GMT
I've noticed pricing like that with Ebay items versus on a company's own site, where it's a not so small difference. A few years ago there was another seller that had the same Greek transmitters for $1400, I think they were the FOX ones, and the seller was in Spain I think. It wasn't just someone selling their old transmitter, they had a few of them up.
Now PDM technology is the next phase of transmitters coming up. It's higher efficiency, so more power can be put into the same size transmitter case. The problem is, the transmitters they're making with PDM are far too much wattage for our use. A nice level for carrier current is from 5 to 30 watts.
If you have LPB transmitters Carl, I've done Kung-Fu on them, and studied their discipline a good bit, so I might have some ideas for what you want to do, if you're stuck for ideas that is.
Boomer
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Post by Druid Hills Radio on Mar 26, 2018 17:26:20 GMT
One Small Flicker of a BickerWhile we await FCC response to Druid Hills inquiry, there is one statement which I find exactly not correct... DHR said: " The issues is not how it's used." By my reading the issue is precisely, entirely and only "how it is used", in this case involving carrier current use. From Jim Szeliga at the FCC Lab: Mr. Mouw Operation in the band 525-1705 kHz on a leaky cable system for college, university, education institution campus falls under Section §15.221 (b). This equipment can be operated without an operating license as a apart 15 device. The equipment authorization and testing required would be under a supplier Declaration of Conformity (SDoC) procedure performed on Site with the retention of testing records keep for each site. The testing requirements are to demonstrate that the field strength (including the AM Broadcast band) meets the requirements in the band and distance as specified in §15.209 Radiated emission limits; general requirements.
Since, compliance for this equipment, parts and cable are tested on site, it is technically not illegal to import this into the US as subassemblies as long as the onsite installed system is properly tested in the US to the 15.221 rules. However, If the equipment is intended to be marketed and used as a broadcast station from a radiating antenna under the provision of 15.219 (100 milliwatts into the final stage) then this equipment would require an FCC Certification with an FCC ID identifier to be legally import. So It may depended on the specific items and purpose of the items you are importing. Saying unauthorized devices intended to use with a radiating antenna but installed properly as a leaky cable system on campus (which may be stopped by Customs) would be illegal. (MY COMMENT: This no doubt would apply to injecting to a power line as well)( This may be accommodated on a case by case by using our inquiry system at www.fcc.gov/labhelp Submit an Inquiry allowing you to declare that it will be used legally as a 15.221 campus leaky cable system and authorized on site. In the future you can use our equipment authorization inquiry system at www.fcc.gov/labhelp Submit an Inquiry
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Post by Deleted on Mar 26, 2018 20:34:06 GMT
Full Assurance
Thank you DHR for obtaining and sharing this feedback from the FCC. By my reading it completely corresponds with my reading of the carrier current rules, 15.221 and beyond.
Armed with this assurance we can move forward into our carrier current destiny "Bringing Radio Back to the People" even as people are being taken away toward distant black sites far out of range of this forum.
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Post by Deleted on Mar 27, 2018 14:36:41 GMT
A Thread Breaking Rule
Keeping this forum thread on topic becomes impossible with FCC Rule 15.221 which talks about three entirely different categories of intentional radiation.
15.221 begins with conditions for Carrier Current on the Medium Wave (AM) band, but ties this with Leaky Cable, a form of broadcast with similarities and differences to carrier current, then branches abruptly into description of open radiation (from an antenna) within the campus of an educational institution.
The sections on carrier current and leaky cable say nothing about an educational institutional limitation, but the FCC Opinion linked above from ALPB Member DHR does claim to link carrier current and school broadcasting, spewing confusion as sometimes happens when expecting clarity from an official source.
Here at Worldround Radio, also an ALPB Member, we have done away with the "school" question by declaring our grounds a "campus" and our mission as truly educational under the banner "Home School College" which reflects a lifestyle devoted to learning and teaching.
Today's educational tip is this: Being taught is the same as learning except when teachings are rejected.
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