Today I was going through RSS GEN in the most depth possible and went from category to category, section to section, from one thing leading to another. Spent half the afternoon and read everything about category 1 equipment, broadcasting certificates, the exemptions, what I could see about broadcasting....everything. Also about the CRTC exemptions to needing a broadcast certificate. All I was researching was the latest versions and amendments.
Firstly, Nowhere, I repeat, nowhere, was any mention of a definition of broadcasting and not broadcasting and ANYTHING about being on a bounded area private or not, indoors or out, nothing!
Here's what I saw, broadcasting doesn't matter whether transmitting to the public from your house, or in a parking lot to the public there....the location doesn't matter. All that matters is that if the equipment is in the ultra low category like BETS-1 and BETS-1 is specified as radio equipment used for selling property or announcing events to the public with no distinguishing where that may be is exempt from needing a broadcasting certificate. This implies that it is for just that....announcements....not being a neighbourhood radio station! And that is referred to quite clearly.
As for category 1 equipment(RSS-210)....needing no license but needing a technical standard certification which the Procaster would fall under, these come under the category RSS-210 annex B....."operation in all frequency bands for any application" This includes the AM and FM broadcast bands.
No more info is given. I looked high and low for anything more in RSS GEN and came up with nothing. Not anything about general public or not and what it's uses are for. Nothing in the CRTC.....nothing, is mentioned about programming content with RSS-210. "Any application" implies for whatever purpose intended with no specifics set forth. I think the assumption that BETS-1, being in the broadcast equipment category means you can be a neighbourhood radio station is not accurate. It is specified what that is for. We do it but that is not it's intent, any more than RSS-210. Maybe less as nothing is specified with RSS-210.
Now here is the thing.....if RSS-210 is not for the general public why is the AM band rule, 100mW and 3 meter antenna, that set up as legal according to the rule and certified, in your own home be heard a kilometer all around you if it's not meant for the public?
Now FCC part 15's intent was not to be a neighbourhood radio station either but because there's no specific rule against it you can get away with it.
I say again, a legal certified AM transmitter set up on your own property or in your own home as allowed by the rules can, even with no ground be heard a km/.62 mile around you, and more, so how is it that it's intent wasn't for the general public? Sure wasn't just to get to your antique radio! You'd just need 10mW for that.
Food for thought.
I've only attempted some rather passive stabs at not only trying to decipher the current rules but also trying to figure out its history.. The info just doesn't seem to be readily accessible, but as I've mentioned before, the 1992 CRTC Public Notice, although outdated, provides some intriguing info.. Below are two interesting excerpts.
Ottawa, 12 March 1992
Public Notice CRTC 1992-21
A REVIEW OF CRTC POLICIES GOVERNING THE USE OF LOW-POWER RADIO FREQUENCIES
Low-Power Announcement Service -- an LPAS is an AM or FM undertaking with a very limited coverage area. In the case of AM (535 - 1605 kHz), transmitter power must be such that it does not produce a field strength level of more than 0.25 mV/m at a distance of 30 metres (note that the daytime protected contour of a regular, protected AM undertaking is 0.5 mV/m). In the case of FM (88 - 107.5 MHz), transmitter power must be such that it does not produce a field strength level of more than 0.1 mV/m at a distance of 30 metres (note that the protected contour of a regular, protected FM undertaking is 0.5 mV/m).
LPAS undertakings can be referred to as "30-metre coverage" undertakings. Operators of LPAS undertakings are not licensed to make use of specific frequencies or transmitting sites. Usually, the licensee operates a system of multiple transmitters at different transmitting sites in the community, using any frequency within the bands defined above. These undertakings can operate only as long as they do not cause interference to other broadcasting services. LPAS undertakings are not protected against interference from other broadcasting services, not even from other LPAS undertakings....
f. Special Events undertakings: These usually operate on low power, are on the air for a few days or weeks, either on an annual or sporadic basis, and are used to provide information to those attending a specific sports or social event.
As with Work Camp undertakings, the Commission has recently called for comments on its proposal to exempt operators of this class of undertaking from the requirement to hold a licence.h. Low-Power Announcement Service undertakings: These undertakings usually carry paid announcements pertaining to real-estate ("Talking Signs") or to tourist sites ("Heritage Messages"). There are currently 54 of these services.
What's important to note is those two services cited above were all licensed operations at the time, and this proposal was suggesting to remove the licencing requirements for such operations.. which, it appears is what they did.
If nothing else it defines the kinds of operations.
Ok, this is more current but I suppose you already seen it, but I just saw it- it breaks down in detail every catagory of legal unlicenced broadcasting in Canada:
https://crtc.gc.ca/eng/forms/form_206.htm
Broadcasting Exemption Orders
Exemption order for low-power
tourist information
Exemption order for low-power radio programming undertakings providing programming that is derived solely from houses of worship
Exemption order respecting certain Indigenous radio undertakings
Exemption order respecting low-power radio: Limited duration special event facilitating undertakings
Exemption order respecting carrier current undertakings who
Terms and conditions of the exemption order for terrestrial broadcasting distribution undertakings serving fewer than 20,000 subscribers
Exemption order respecting certain native radio undertakings
And more....
Here ya go.. lower in the page:
https://crtc.gc.ca/eng/archive/2000/PB2000-10.htm
Exemption order respecting low-power radio: Ultra low power announcement service (LPAS) undertakings
The Commission, pursuant to subsection 9(4) of the Broadcasting Act, by this order exempts from the requirements of Part II of the Act and any regulations, those persons carrying on broadcasting undertakings of the class defined by the following criteria:
Purpose
The purpose of these radio programming undertakings is to allow those such as real estate agents, store owners and local authorities to communicate to the public messages of an informative, sometimes commercial nature, regarding their activities by means of ultra low-power transmitters, e.g., "talking signs."
Description
1. The undertaking operates between 525 and 1705 kHz in the AM frequency band, or between 88 and 107.5 MHz in the FM frequency band.
2. In the case of an undertaking using the AM broadcasting band, the maximum power output of the transmitter into its antenna, without modulation, does not produce a field strength, as measured at a distance of 30 metres, of more than 0.25 millivolts per metre (mV/m) and, in the case of an undertaking using the FM broadcasting band, the maximum power output of the transmitter into its antenna, without modulation, does not produce a field strength, as measured at a distance of 30 metres, of more than 0.1 mV/m.
3. The Commission would not be prohibited from licensing the undertaking by virtue of any direction to the Commission by the Governor in Council.
4. The undertaking meets all technical requirements of the Department of Industry and has acquired all authorizations or certifications prescribed by the Department.
5. The undertaking originates all of its programming.
6. The undertaking does not rebroadcast the programming of another undertaking.
7. The undertaking does not broadcast programming that is religious or political in nature.
8. The undertaking, if it promotes commercial activity, e.g., "talking signs," or is commercially oriented, does not broadcast the same message on more than one transmitter.
@richpowers You see my point...."The purpose of these radio programming undertakings is to allow those such as real estate agents, store owners and local authorities to communicate to the public messages of an informative, sometimes commercial nature, regarding their activities by means of ultra low-power transmitters, e.g., "talking signs."
BETS-1 was never intended to be a neighbourhood radio station. Ultra low power announcement service is BETS-1. We do it, but it's intent was for commercial promotion, selling property and announcements for a neighbourhood event. The only loophole is having
a local radio station or sounding like one, is not specifically prohibited.
@mark Long as your within the legal limits of the technical requirements, I don't see a it being a problem. I'm sure if it wasn't allowed, we would've heard from the powers that be by now, and would have clarified the rule, to state that neighborhood radio like we're doing is not allowed.
@richpowers You see my point...."The purpose of these radio programming undertakings is to allow those such as real estate agents, store owners and local authorities to communicate to the public messages of an informative, sometimes commercial nature, regarding their activities by means of ultra low-power transmitters, e.g., "talking signs."
BETS-1 was never intended to be a neighbourhood radio station. Ultra low power announcement service is BETS-1. We do it, but it's intent was for commercial promotion, selling property and announcements for a neighbourhood event. The only loophole is having
a local radio station or sounding like one, is not specifically prohibited.
Part 15 was never intended for neighborhood broadcasting in the USA either - in fact the FCC has said as much numerous times. But it's irrelevant.
Like you said, it's not prohibited by the rules in either country; the USA or Canada. And in Canada commercial ads for revenue is permitted. In the USA its permitted too but I dont think its specified.
"..The purpose of these radio programming undertakings is to allow those such as real estate agents, store owners and local authorities to communicate to the public messages of an informative, sometimes commercial nature,.."
I see no way that can be interpreted to suggest utilizing it as a neighborhood station is prohibited. Those are just examples, "such as.."
Anyway, I'm having a hard time believing there was no form of "part 15" broadcasting in Canada prior to the 1990s, .... but so far that's what it looks like - but it sure don't sound right.
https://transition.fcc.gov/oet/info/documents/bulletins/oet63/oet63rev.pdf
On Page 10 -
525-1705 kHz Any 100 mW input to final RF stage 15.219
Says any under type of use.
From the date on the document, It was changed in the 1990s. Probably due to the pirate explosion back then, although I can't be certain.
@wefr Yes, it does specifies "Any". I never noticed that before. By the way, I have tried to track down the September 1984 version several times but without success - but hopefully a copy will eventually turn up somewhere.
@wefr You ain't gonna believe this but I just found it!
https://www.google.com/books/edition/Understanding_FCC_Rules_Regulations_Unde/ese0oAEACAAJ?hl=en
However, it's not viewable yet, but it will be in the next day or two, I just a request for them to review it.
The original 1984 OET63 version was titled slightly different as "Understanding FCC Rules & Regulations under Part 15 for Low Power Transmitters"
Here's something from FCC OCE 1973 on Part 15 AM.
https://docs.fcc.gov/public/attachments/DOC-335623A1.pdf
Lots of various information about the history of FCC regulations related to broadcast bands in general can be found here.
https://www.fcc.gov/media/radio/radio-history-documents