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Post by Deleted on Mar 19, 2018 12:32:25 GMT
Unknown Transmitter
Jim H.: "...but it's different.Any opinions on this one?"
It definitely is a different transmitter than the one Tha Dood in WV has been using, although someone along the way has referred to a "yellow" AM transmitter, but we have no reports from anyone who has tried this one.
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Post by Deleted on Mar 19, 2018 12:46:14 GMT
Here's the One We Know AboutGreek AM-20 Carrier Current TransmitterTha Dood has sent some further info about his experience which I will mention here, perhaps I've already posted this info: He says the power supply is "switching" and puts noise on the power lines which listeners will hear on carrier current. The solution is either a 1:1 high current AC isolation transformer or better power supply. I have obtained a current quote from pll.gr, the Greek source, of $560. However, I see on E-bay the same xmtr is $500.
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Post by Druid Hills Radio on Mar 19, 2018 13:30:07 GMT
The Greek transmitter is probably not legal for use in the United States. See Here
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Post by Deleted on Mar 19, 2018 13:41:06 GMT
Under Advisement
Thank you Druid Hills for the FCC caution. We have put our transmitter plans on hold pending deeper study of the FCC requirements.
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Post by mark on Mar 19, 2018 15:23:04 GMT
The Greek transmitter is probably not legal for use in the United States. See HereSo many things in that list of rules when it could be summed up in one paragraph. But Amazon continues to sell imported transmitters from China meeting none of these rules. But as noted in a past post it's the customs department not the FCC which looks after anything coming into the country. That greek transmitter while illegal unless you have LPAM licence would be sent to me and all I'd have to do is click add to cart and check out.
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Post by Deleted on Mar 19, 2018 17:15:03 GMT
Hold Them Horsies!!
Mark over-interprets what Druid Hills said: "That greek transmitter while illegal unless you have LPAM licence..."
But read again what Druid Hills said: "The Greek transmitter is probably not legal for use in the United States."
The word "probably" is not the same as the word "definitely", which leaves room for uncertainty about the legality.
AND, we are not talking about LPAM licensed over-the-air transmission, we are talking about carrier current, which has different requirements!
Many of the points in Druid's linked list of Import legalities obviously don't apply... such as the rules that refer to "ordering in large quantities" or any of those referring to importing for re-sale.
I am slicing and dicing and comparing to the part 15 section which refers like a pin-ball-machine to a confusing string of rules and exceptions to the rules regarding carrier current, and the fact that it's for personal use as a hobby project, and is in part "self made"... it could be perfectly legal to use the Greek transmitter using "the best engineering practices", as it says in the rules.
As a Part 15 Home Consultant I will prepare a Gray Paper on the subject.
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Post by Druid Hills Radio on Mar 19, 2018 19:37:15 GMT
I have discovered that the ISS transmitter is FCC "Certified."
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Post by thelegacy on Mar 19, 2018 20:37:55 GMT
Druid Hills this is interesting that you found out that the Information Station Specialists carrier current transmitter is FCC certified. That was something that I was going to bring up as I have not talked about carrier current with any of the agents.
Keeping this statement as a reference as I spoke to agent about using transmitter on the am broadcast band they had told me that I need to use a transmitter that has the part 15 compliance label with the FCC ID on it. That being said as we see that the Information Station Specialists transmitter which is Carrier current is certified and we don't see the certification on the Greek transmitter I would safely advise that yes the Greek transmitter would not be considered legal to use in the United States for a part 15 section 221 compliant transmitter. Thus if the operator uses this transmitter and there is a complaint and the FCC comes out to inspect your transmitter you may get a warning letter and a verbal warning telling you you need to shut down.
So the best advice at this time is 2 points. Number one if you have any questions about this you are advised to call the FCC department of engineering and Technology and ask that question. I am also sure that David Dombrowski will have the same sentiment that I had discussed here regarding this.
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Post by part15engineer on Mar 19, 2018 21:16:59 GMT
the ISS / Radio Systems TR-6000 is Part 73 and Part 90 Certified.
there is no real certification for part 15.221 transmitters because of too many system variables. each installer of carrier current systems must self certify their installs conform to 15.221
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Post by Deleted on Mar 19, 2018 21:20:28 GMT
This Will Make a Good Rainy Day Project
Here in the midwaste we have rain rain and rain, so it's a good time to study FCC rules.
Remember, even if you have an opinion about the rules, don't trust yourself because you might not know everything. I know I don't know everything.
We have been talking about carrier current transmitters being "certified", but I sincerely think that maybe they need to be "FCC authorized", which is not the same thing as "certified".
But even at that, under part 15 it is legal to build homemade transmitters that do not need to be either certified or authorized and the requirement is to use "good engineering practices".
Carrier current is a part 15 category, and using a collection of parts and components to build a carrier current transmission system could qualify as being "homemade".
Someone once said that carrier current isn't in the "intentional radiator" category but then I looked and found that yes it is an intentional radiator because it radiates a certain distance from the power line.
I am not 100% sure yet whether the Greek transmitter can properly be used for carrier current, but I know a guy who is using it for carrier current and it is doing the job exactly in compliance with the field strength and other measurable characteristics. It would be hard to think of a way in which it would be "illegal".
ALSO, even though I trust and respect the FCC engineers befriended by TheLegacy, I wouldn't take their opinion about theoretical unusual situations like this carrier current situation... it would be like asking a policeman his opinion about the law, and as Jim Henry has said, the real authority on the law would be an attorney who specializes in the type of law being asked about.
And in this rare specialized case which may have very little precedent an attorney might not be sure unless he does an in depth study of the rules which might cost several thousand dollars to have done!
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Post by Deleted on Mar 20, 2018 4:15:20 GMT
Important Please Stop What You Are Doing and Look Here
It's in the FCC Rules Part 15.221 (c)... it's what we've been wondering about and it says...
A grant of equipment authorization is not required for intentional radiators operated under the provisions of this section.
Therefore the Greek Transmitter qualifies on that score and potentially could be used for carrier current.
But hold on. Nothing is ever free or easy and the federal government keeps it that way.
Reading on: In lieu thereof, the intentional radiator shall be verified for compliance with the regulations in accordance with subpart J of part 2 of this chapter.
That is something you can do if you know what to do, or have done by a qualified radio engineer.
There's more: This data shall be kept on file at the location of the studio, office or control room associated with the transmitting equipment. In some cases this may correspond to the location of the transmitting equipment.
The carrier current rules point and criss-cross reference to a batch of additional rule sections, but our main question here was whether authorization was required for the transmitter, which we've answered.
I would like to see part 15 people read the rules once in awhile. From most of the posts day after day people guess and speculate and ask, but most show no indication they actually look at the rules.
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Post by Druid Hills Radio on Mar 20, 2018 13:18:02 GMT
Having spent a significant amount of my post navy life performing compliance testing, I can assure you that I am not guessing. The bottom line is that any transmitter imported into the United States needs to show compliance with applicable FCC rules, whether "verified" or "certified." Our LPFM transmitter is made in Italy. It is certified.
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Post by Deleted on Mar 20, 2018 16:01:26 GMT
Maybe they can supply the on/off switch separately and call it a kit...
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Post by Deleted on Mar 20, 2018 16:10:59 GMT
Inside Knowledge
We know what that means! (Maybe they can supply the on/off switch separately and call it a kit...)
I was already viewing carrier current as a "kit" because of all the parts needed to have an entire transmission system:
1.) some power lines; 2.) a coupler unit; 3.) the part called a "transmitter"; 4.) interconnecting cables; 5.) AC power; 6.) a studio.
Or, it can be called "home made".
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Post by Deleted on Mar 20, 2018 19:05:33 GMT
Let's Not Be Hasty
Let us take the time to go over Druid Hills Import Conditions in respect to importing a Greek transmitter for carrier current use:
2.1204 Import conditions.
(a) Radio frequency devices may be imported only if one or more of these conditions are met:
(1) The radio frequency device has been issued an equipment authorization by the FCC. READ THE NEXT CONDITION
(2) The radio frequency device is not required to have an equipment authorization and the device complies with FCC technical administrative regulations. THIS CONDITION BEING TRUE TAKES PRECEDENCE OVER CONDITION 1
(3) The radio frequency device is being imported in quantities of 4,000 or fewer units for testing and evaluation to determine compliance with the FCC Rules and Regulations, product development, or suitability for marketing. The devices will not be offered for sale or marketed. YES WE WILL DETERMINE COMPLIANCE WITH FCC RULES AS A CARRIER CURRENT DEVICE
(i) Prior to importation of a greater number of units than shown in paragraph (a)(3) of this section, written approval must be obtained from the Chief, Office of Engineering and Technology, FCC; and NA
(ii) Distinctly different models of a device and separate generations of a particular model under development are considered to be separate devices. NO PROBLEM
(4) The radio frequency device is being imported in limited quantities for demonstration at industry trade shows and the device will not be offered for sale or marketed. The phrase “limited quantities,” in this context means: NA
(i) 400 or fewer devices. NA
(ii) Prior to importation of a greater number of units than shown above, written approval must be obtained from the Chief, Office of Engineering and Technology, FCC. NA
(iii) Distinctly different models of a product and separate generations of a particular model under development are considered to be separate devices. NO PROBLEM
(iv) Distinctly different models of a product and separate generations of a particular model under development are considered to be separate devices. THIS REPEATS THE LAST CONDITION
(5) The radio frequency device is being imported solely for export. The device will not be marketed or offered for sale in the U.S., except: NA
(i) If the device is a foreign standard cellular phone solely capable of functioning outside the U.S. NA
(ii) If the device is a multi-mode wireless handset that has been certified under the Commission's rules and a component (or components) of the handset is a foreign standard cellular phone solely capable of functioning outside the U.S. NA
(6) The radio frequency device is being imported for use exclusively by the U.S. Government. NOT NECESSARILY
(7) Three or fewer radio frequency devices are being imported for the individual's personal use and are not intended for sale. Unless exempted otherwise in this chapter, the permitted devices must be from one or more of the following categories: TRUE SO FAR
(i) Unintentional radiator as defined in part 15 of this chapter which may include radio receivers, computers or other Class B digital devices in part 15 of this chapter. NA
(ii) Consumer ISM equipment as defined in part 18 of this chapter. NA
(iii) Intentional radiators subject to part 15 rules only if they can be used in client modes as specified in § 15.202 of this chapter. I THINK SO
(iv) Transmitters operating under rules which require a station license as subscribers permitted under § 1.903 of this chapter and operated under the authority of an operator license issued by the Commission. NA
(8) The radio frequency device is being imported for repair and will not be offered for sale or marketed. NA
(9) The radio frequency device is a medical implant transmitter inserted in a person or a medical body-worn transmitter as defined in part 95, granted entry into the United States or is a control transmitter associated with such an implanted or body-worn transmitter, provided, however that the transmitters covered by this provision otherwise comply with the technical requirements applicable to transmitters authorized to operate in the Medical Device Radiocommunication Service (MedRadio) under part 95 of this chapter. Such transmitters are permitted to be imported without the issuance of a grant of equipment authorization only for the personal use of the person in whom the medical implant transmitter has been inserted or on whom the medical body-worn transmitter is applied. NA
(10) Three or fewer portable earth-station transceivers, as defined in § 25.129 of this chapter, are being imported by a traveler as personal effects and will not be offered for sale or lease in the United States. NA
(b) The ultimate consignee must be able to document compliance with the selected import condition and the basis for determining the import condition applied. EASY TO DO
[ 56 FR 26619, June 10, 1991, as amended at 57 FR 38286, Aug. 24, 1992; 61 FR 8477, Mar. 5, 1996; 63 FR 31646, June 10, 1998; 64 FR 69929, Dec. 15, 1999; 64 FR 72572, Dec. 28, 1999; 69 FR 5709, Feb. 6, 2004; 74 FR 22704, May 14, 2009; 78 FR 25162, Apr. 29, 2013; 82 FR 50830, Nov. 2, 2017]
We have made our case. of course we recognize that Druid Hills is a professional qualified broadcast engineer in the licensed services but like most such engineers has very probably not been assigned with developing a carrier current facility and would therefore most likely be only passingly familiar with the category.
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