- WOW! Todays REC newsletter concluded with this statement:
"REC proposes to improve the viability of license-free “Part 15” AM and FM through the adoption of the Canadian BETS-1 standard for these types of transmitters.
REC will review all of the comments filed by others and will be filing Reply Comments when they are due on Monday, April 28, 2025."
View REC’s comments in this proceeding.Download that pdf and on page 45 you find the following proposal:
2. Proposal
VIII. HARMONIZATION OF SHORT ANGE DEVICES IN THE BROADCAST BANDS
Change Type Rule section(s) affected):
Change 15.219, 15.221, 15.239Sections 15.219, 15.221 and 15.239 address the use of intentional radiators operating the AM and FM broadcast bands. While many of these devices are used as consumer purposes such as extending the audio from a user’s wireless device to an automotive sound system through its FM radio receiver for their own personal use, other devices that are covered by these sections can be used for a form of “nanobroadcasting” to reach other persons. Such applications include special event broadcasting, foreign language simulcast, college student broadcasting, church parking lot broadcasting, holiday displays and
neighborhood broadcasting. Devices marketed and used in the United States must be certified through a
Telecommunication Certification Body (“TCB”).Canada has their own standard for such short-range devices which offers a slightly improved performance compared to its United States counterpart. The Canadian standards are published in Broadcasting Equipment Technical Standard 1 (“BETS-1”).
For the sake of international harmonization and to reduce the burden on equipment manufacturers wishing to market certain types of short-range devices in both the United States and Canada, it is REC’s position that the Commission’s Rules regarding license-free short-range devices that operate in the bands of 88-107.6 MHz and 525-1705 kHz that already meet the Canada BETS-1 standard be usable in the United States in addition to the devices that were developed under the existing United States regulation."
(Emphasis mine)
Just a correction BETS is from 88.1 to 107.5.
FCC part 15 is already harmonized with RSS-210 Canada which is the same for both countries, AM and FM. The manufacturers just have to do one universal test for the two countries.
BETS is a separate entity that allows unlicensed broadcasting in Canada or in other words being a "radio station" in your neighbourhood and being able to advertise you are there. You remember the broadcasting/nonbroadcasting subject a while ago?
This gives us the increased field strength for FM. But AM? BETS AM as you see is field strength.....250uV/M@30 meters which is not as good as 100mW and the 3 meter rule and no field strength.
Sounds good if you can get BETS allowed in the USA. Thank Michelle Bradley of Recnet for submitting this proposal to the FCC!
Just a correction BETS is from 88.1 to 107.5.
FCC part 15 is already harmonized with RSS-210 Canada ...
I just copy and pasted directly from the REC pdf. Ok, but it's just an option, not a requirement (if it passes).
So let me see if I got this straight.. with Part 15FM it would give us the option of 15.221 or BETS. Likewise, with Part 15AM our options would be 15.219 or BETS
This is kind of like the compromise the FCC had made to their change of rules in 1989 which allowed leaky cable installs to conform to the higher field strength limits of carrier-current for the sake of simplicity (this had been prompted over LPBs 3-mile Disney World roadway install).
I still tend to stumble over trying to grasp the difference between RSS210 and BETS though..
"The Canadian standards are published in Broadcasting Equipment Technical Standard 1 (“BETS-1”)."
I got some kind of mental block over this topic that remains unresolved though we have talked it to death.
@richpowers Easy! part 15.219 and part 15 239 is what you are concerned with here.
Part 15.239 is FM and part 15.219 is AM These two are exactly the same as Canada's RSS-210 and are harmonized so one test is needed for the two countries.
In the USA you have one set of rules.....part 15. Canada has two sets of rules for the AM and FM bands. RSS-210 and BETS-1. BETS-1 is for the AM(535-1705) and FM(88.1-107.5) only.
The main benefit of the USA adopting BETS-1 is with FM as you will have increased allowed field strength.
If the USA adopts BETS-1 it would change part 15.239 from 250uV at 3 meters to the higher BETS field strength at 100uV @ 30 meters.
For AM, you would rather it stay like it is now as with BETS-1 AM is field strength....250uV at 30 meters and that wouldn't be as good as what you have now. Although you would eliminate the ground and antenna leads rule and you could do anything you want but be limited by field strength.
So what you want is part 15.239(FM) to harmonize with BETS-1
Now you ask, why does Canada have 2 categories(RSS-210/BETS-1) for the same thing...AM and FM?
Answer.....one is for broadcasting and the other is for nonbroadcasting and to understand this, if you don't already, you can start another topic and it can be discussed again! Artisan and I can go over it again. It's because we have two entities, ISED and the CRTC that both regulate the airwaves but different part of it.
ISED is a government ministry and spectrum management is just one little part of it where in the USA the FCC manages the airwaves and only that.
But if REC can get you an increase in part 15.239 equal to BETS-1 you would have FM more useable than it is now.
In the USA you have one set of rules.....part 15. Canada has two sets of rules for the AM and FM bands. RSS-210 and BETS-1. BETS-1 is for the AM(535-1705) and FM(88.1-107.5) only. ....one is for broadcasting and the other is for nonbroadcasting ....
That's where I get confused - the whole "broadcasting" vs "nonbroadcasting" distinction. It kind of dumbfounds me and there's nothing similar in our Part 15 rules to compare it too either. I know we discussed this at length only a few months ago but still I never totally grasped it - it seems to be something wrong with my brain. (by the way, excuse incorrect my citing of 15.221)
I'm still not sure when Canada's version of Part 15 originated. I do know Canada was first to set up government controls to combat radio interference in the mid 1930s and then the US followed their example, but I get the impression RSS210 and BETS arose much much later -- but really have no idea when.
The closest I can comprehend Canada's "broadcasting" vs "nonbroadcasting" rules in association with the US Part 15 rules is that it's similar to the difference between 15.209 and 15.219
I also realize that's a flawed perception, but..
Or in other words, one method is capable of attracting an audience and the other is generally capable for personal use. (Public performance vs personal use)
@richpowers I am going to start a new topic to continues this. If anyone has more to add about REC and the submission to the FCC about BETS you can continue here.
Have I gone off-topic? Does not the topic about what BETS actually is directly pertain to BETS potentially coming to the US?
But really I wasnt trying to reprise the previous BETS confusion discussion, I'm just saying I never quite grasped it, which in turn leaves me confused about this current topic about it being implemented somehow here in the US.
So, I dont see what the topic drift is. But I wasn't aiming to rehash the BETS confusion anyway, just expressing that I never really got it.