Why I took the website off. Asked by Rich Powers.

Posted by: @mark

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.   .. It doesn't make sense that the potential coverage for a RSS-210 AM transmitter is many times more than a BETS one. It should be reversed.

Shouldn't the broadcast transmitter have the better coverage? How come the range for a transmitter for personal use only is measured in kilometers but a transmitter that is broadcasting equipment measured in feet? ....

You know, I have to act as I am doing something wrong even though I'm not. The Procaster is legal no license needed yet because of this intent and broadcasting nonsense I have to act like I am doing something wrong and "hide it". Crazy.

I understand your frustration. I still don't get it .. but as you point out - it doesn't make sense at all... And it is that very senselessness that tells me something along the way had been drastically misinterpreted, accepted and further convoluted over time to the point that now you are essentially submitting to, and/or hiding your activity to an imaginary imposed restriction.

That's what I think. That's what makes sense.

But that's just my gut, belief, opinion, deduction, presumption, - I've never dug my heels in to find out, which can be a very tedious and drawn out venture to accomplish. Most answers can be found in exploring the history and evolution of the rules, what prompted them to begin with, and why two unlicenced methods for the same band - the AM Broadcast Band, mind you, a frequency range that's primary existence and purposes is for public consumption.

No Mark, none of it makes sense, not what I've heard through Artisan and you on the matter anyway. So yeah, I think - for what it's worth - that some big misinterpretation is the problem.

I'll probably at some point set out to explore the Canadian version of Part 15 and find clarifications. I've taken a couple very brief stabs at it before, but couldn't find much of a toehold or anything to grab hold of yet to get started. It's much easier to do that here in the US, but open documentations and/or case studies of such operations seem to be a bit more reclusive for Canada research.

I feel your frustration, but I really don't think your doing anything wrong, but by all means do what you think is right. I notice Artisan doesn't seem to be particularly nervous about his station operation. 

I don't know man.

@richpowers That's because I was using a BETS-1 certified Decade when I had my website up.  I was using the Talking Sign, RSS-210 certified only, to feed my SDR, and nothing else.  I couldn't even be heard reliably, anyway, with that transmitter on the street below my apartment due to living in a Faraday cage (a concrete and steel apartment building).  And I didn't try very hard either.

Basically, the Canadian rules all boil down to intent.  If you intend on other members of the public listening to your signal, then you have to use BETS-1.  If the signal is for your own use only, then you can use either BETS-1 or RSS-210.

My personal feeling, and it is my opinion only, is that ISED here will not bother you if you use an RSS-210 transmitter and do not attempt to compete with other licensed broadcasting stations (i.e., do paid for commercials, expand your listening area like the guy in Winnipeg tried to do by using multiple transmitters, etc.).  But if they visit, and determine that you are operating a broadcast venture using RSS-210, they can, and obviously sometimes do, shut you down.

There's really no misinterpretation of the rules.  The ultimate solution is to get an AM transmitter certified for BETS use here in Canada, as Mark points out.  Unfortunately, the BETS-1 rules for AM dictate a maximum field strength of 250uv/m @ 30 meters.  That will severely limit range, maybe a couple of hundred meters.

All this stems from the fact that we have an additional government body here in Canada, the CRTC, which regulates the contents of broadcasts.  There is a specific CRTC exemption order that allows BETS-1 transmitters to broadcast without obtaining a CRTC license.  ISED is supposedly only concerned with the technical aspects of radio transmission, and spectrum use.

@richpowers Everything you say is right. It is total nonsense. The worst that would happen is I would have to go to FM with the BETS approval. 
You made a good point and I have been arguing this for years. You are allowed on a broadcast band which the AM band is but you can't broadcast. And whether you are broadcasting is based on intent. For the public or yourself. The signs in the area and a website would be considered intent to broadcast if inspection saw that.
You are 100% correct. It is an "imaginary imposed restriction" but the restriction is there.
And a senseless one. I'm going to keep doing it but just not advertising it openly. The Procaster is certified as legal to operate according to the technical rules in Canada. Legal to operate on a broadcast band which is intended for the public. Same as FCC part 15. Good enough for me.
But I have to suggest a BETS certification for the Procaster. The guy in Winnipeg would have continued had the agents seen a BETS transmitter.
I like that term, imaginary imposed restriction. Hadn't thought of it that way.

Posted by: @artisan-radio

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.. .. Basically, the Canadian rules all boil down to intent.  If you intend on other members of the public listening to your signal, then you have to use BETS-1.  If the signal is for your own use only, then you can use either BETS-1 or RSS-210. ... .

There's really no misinterpretation of the rules.  The ultimate solution is to get an AM transmitter certified for BETS use here in Canada, as Mark points out.  Unfortunately, the BETS-1 rules for AM dictate a maximum field strength of 250uv/m @ 30 meters.  That will severely limit range, maybe a couple of hundred meters. ...

Yet RSS210 allows more range ... Somethings missing. The interpretation of the rules are plenty clear enough in regard to the technicalities of the transmitters. The "intent" that is what's so murky. Why would you be allowed more range on AM if your "not broadcasting" (RSS-210) than you're permitted if you are "broadcasting" (BETS-1). What the hell?

Yeah, someday I'd like to figure out what's going on with low power AM there in Canada, but as for the moment I'm just glad I'm not the one who has to worry about figuring a way to conform to the confusing rule.

@Mark It's a wise move to be prudent in your activities when dealing with convoluted legalities such as this apparently elusive definition of what "broadcasting" with a RS-210 certified device designed for the purpose of "not broadcasting" in the AM band.

OMG it's kind of hilarious, but I feel for ya 

One of the reasons for the BETS-1/RSS210 disparity is that some technical genius either at ISED or the CRTC figured that 100uv/m at 30 meters (BETS-1 FM) would only have a range of 30 meters, or about 100 feet.  It's even written into the BETS-1 document, although not in the rules specifically (it's in the introduction).

Wait a sec... @Mark Didn't you say earlier in this thread or an associated thread here that RSS-210 actually allows a greater range than BET-1?  - or did I misunderstand you?

Rich Powers asks:"Yet RSS210 allows more range ... Somethings missing. The interpretation of the rules are plenty clear enough in regard to the technicalities of the transmitters. The "intent" that is what's so murky. Why would you be allowed more range on AM if your "not broadcasting" (RSS-210) than you're permitted if you are "broadcasting" (BETS-1). What the hell?

You are trying to make sense of something the doesn't make sense. I wish the rule makers tried to make sense of their own rules. Then they'd make sense.

But Is it an accurate statement that RSS-210 is capable of greater AM range than BETS-1 ???

Yes that is accurate. RSS-210 is the same as FCC part 15. The range you can get with part 15 AM is the same with RSS-210.

But BETS-1 is field strength 2500 uV@ 3 meters(250 uV@ 30 meters). Not power or antenna length. Range is limited to field strength. Doesn't matter what your set up is.

The part that you are trying to make sense of is the better of the two range wise has the "imaginary restriction" of not intending it for everyone to listen to.
You can't make sense of it because it makes no sense.

@Mark I guess Artisan answered it:

Posted by: @artisan-radio

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some technical genius either at ISED or the CRTC figured that 100uv/m at 30 meters (BETS-1 FM) would only have a range of 30 meters, or about 100 feet.  It's even written into the BETS-1 document, although not in the rules specifically (it's in the introduction).

- -- Detail RSS-210 vs BETS-1

Key Distinction

The crucial difference lies in the application and regulatory scope:

• Devices certified under RSS-210 are explicitly for non-broadcasting use and are entirely licence-exempt.
• Devices certified under BETS-1 are specifically for broadcasting purposes, albeit low-power and licence-exempt within their defined parameters.

The distinction between a "radiocommunication device" (RSS) and "broadcasting equipment" (BETS) is fundamental to Canadian spectrum management.

---What is non-broadcasting?

In the context of Innovation, Science and Economic Development Canada (ISED) regulations, "non-broadcasting" refers to any radiocommunication that is NOT intended for direct reception by the general public.

The key distinctions are:

Broadcasting: This involves transmissions intended for a wide, general public audience, such as commercial radio or television stations. These are regulated under the Broadcasting Act and associated Technical Standards (BETS) and often require a broadcasting licence, unless a specific exemption (like for low power announce transmitters under BETS-1) applies.

Non-Broadcasting: This includes any other form of wireless communication that is more private, point-to-point, or intended for a limited, specific group of users. These devices are generally regulated under the Radiocommunication Act and must meet Radio Standards Specifications (RSS), such as RSS-210.

Essentially, if the signal is not meant for general public consumption via a standard radio or TV receiver, it falls under the "non-broadcasting" category.

--- So you can not broadcast to your private station to neighborhood under RSS-210?

No, you cannot broadcast to your neighborhood using equipment certified solely under RSS-210. The key reason is that ISED regulations define broadcasting as transmission intended for direct reception by the general public, and RSS-210 explicitly governs equipment used for non-broadcasting applications. ... ..

Neighborhood Transmission is Broadcasting: Transmitting a signal intended for reception by multiple homes in a neighborhood is considered broadcasting, even if the power is low or the audience is limited to a specific area.

Appropriate Standard: Low-power announce transmitters that operate in the AM/FM broadcast bands and are intended for short-distance public information (e.g., real estate "talking signs") are regulated under a different standard: BETS-1. If you wish to set up a transmission for your neighborhood, even at low power, you would need to comply with the rules for broadcasting equipment, which means meeting the requirements of BETS-1. Using RSS-210 certified equipment for this purpose would violate ISED regulations.

--- Well Canada's RSS-210 is equivalent to the FCC Part 15.219 but there is no such broadcasting vs non-broadcasting stipulations in connection with FCC Part 15.219

While the text of FCC Part 15.219 does not explicitly use the terms "broadcasting vs non-broadcasting," the distinction is fundamental to the regulatory framework of the FCC and dictates how the rule is interpreted and applied. 

So, while the rule itself does not explicitly mention the word "non-broadcasting," the entire framework of Part 15 is designed for devices that do not fall under the definition of licensed, public broadcasting services.

-- That's incorrect, there is no question whatsoever that part 15 AM can, and has always been consistently utilized for over 80 years as a means of legally broadcasting to the general public on the AM Band. Part 15 AM has been used for travelers information since 1940, as well as college stations, Billy Gram Crusades, A.F. Blue Angels demonstrations, real estate sales, hobby stations. I could go on and on, what's more, it is also quite clear that there are absolutely no restrictions on what content is broadcast. So you err greatly in your last response.

You are correct that FCC Part 15 rules have been used for decades for what is commonly referred to as "hobby broadcasting" or "Part 15 radio stations" which are receivable by the general public. My previous responses incorrectly implied that any transmission to the general public was automatically prohibited under Part 15 and required a different license.

Here are the corrected points regarding FCC Part 15 operation:

Public Reception is Allowed: The FCC allows operation under Part 15 rules within the AM and FM bands for the purpose of communicating to the general public, effectively functioning as an unlicensed, low-power radio station. This application has been consistent for many years.

Content Restrictions: There are no content restrictions specific to Part 15 that limit the type of programming, unlike licensed broadcasters who are subject to rules regarding indecency and obscenity during certain hours.

Licensing: These operations do not require an individual FCC license, provided they strictly adhere to the technical specifications defined in the relevant sections (e.g., FCC Part 15.219 for AM, 15.239 for FM).

So, within the United States, operating a low-power AM station within the FCC Part 15 rules is a legal way to broadcast content without a license, as long as the technical limits are met.

In the original context of the question (RSS-210 vs BETS-1), the Canadian framework has a similar but subtly different approach where BETS-1 is the specific standard for public "announce transmitters", distinguishing it from the general "radiocommunication devices" covered by RSS-210.

---- Earlier you said you can not broadcast an AM signal to your neighborhood under RSS-210, yet previously you said that under RSS-210 you can broadcast if it is "intended for a limited, specific group of users"... That sounds like a contradiction.

The apparent contradiction stems from the difference between operating a licence-exempt low-power device and engaging in actual broadcasting.

Industry Canada's RSS-210 specifies technical requirements for a wide variety of low-power, licence-exempt radiocommunication devices .... .. These devices are designed for short-range communication and must adhere to strict power and field strength limits specified in RSS-210 and the general requirements in RSS-Gen.

The phrase "intended for a limited, specific group of users" refers to applications like auditory assistance systems or specific control links, where the signal is only intended for the paired receiver(s), not for general reception by the public.

Therefore:

You cannot broadcast an AM signal to your entire neighborhood using equipment certified under RSS-210 because the power and range of such devices are highly restricted and not intended for general public reception.

You can use a low-power, licence-exempt device under RSS-210 if the signal is for a limited, specific group of users in a very constrained area (e.g., within a single building or a small area for a specific purpose like a short-range information system), provided it meets all the technical specifications and power limits of the standard.

The "limited, specific group of users" clause does not mean you can create a de facto neighbourhood AM radio station; it means the device's design and power output intrinsically limit its reception to a small, non-general audience within a limited range.

--- Who's to say a neighborhood is not a "small, non-general audience within a limited range"?

The distinction lies not just in the physical size of the area, but in the regulatory definition of "broadcasting" and the power limits imposed on licence-exempt devices. 

Why a Neighborhood is the "General Public"

A "neighborhood" is considered the "general public" in a regulatory sense because the signal can be received by anyone with a standard, unmodified radio receiver, without any restriction or specific authorization. The "limited, specific group of users" clause refers to highly constrained, private communication links, ..

Attempting to cover an entire neighborhood, which might involve dozens or hundreds of homes, clearly falls under the definition of broadcasting to the "general public," which is a regulated activity requiring specific licences and certifications that go far beyond the scope and technical specifications of RSS-210. 

Does RSS-210 have any restrictions on what content is broadcast?

No, RSS-210 does not have restrictions on the content being transmitted. The standard is purely concerned with technical specifications ... .. technical standards like RSS-210, Licence-Exempt Radio Apparatus: Category I Equipment, focuses on technical compliance, .. ..

The regulation of the content of radio transmissions (e.g., rules about what can or cannot be said or played) falls under the jurisdiction of the Canadian Radio-television and Telecommunications Commission (CRTC), but only for operations defined as broadcasting (transmissions intended for reception by the general public).

Since devices under RSS-210 are specifically for licence-exempt, non-broadcasting applications and operate at very low power, their content is not subject to CRTC regulation. However, using these low-power devices to create a de facto broadcast to the general public (like an entire neighborhood) is still a violation of the purpose and technical limits of the standard, not the content rules.

---- So explain why if Part 15.219 is equivalent to RSS-210, and also the definitions of "broadcasting" in both regulatory bodies is essentially the same, then why in the U.S. is it that 15.219 has always been permitted to operate as "minature radio stations", but in Canada it is not?

The key difference lies in the specific interpretation and explicit application of these rules by their respective regulatory bodies (FCC in the US and ISED in Canada).

FCC (United States) - Explicit Allowance
The FCC's Part 15 rules, specifically Section 15.219, were established with an interpretation that permits the use of extremely low-power AM transmitters for communication to the general public within a very limited range, often referred to as "miniature radio stations" or "microradio".

The FCC explicitly states that for devices operating under specific rule sections (including § 15.219), "Unless otherwise stated, there are no restrictions as to the types of operation permitted under these sections." This regulatory stance allows for audio programming (essentially, broadcasting) to be transmitted, provided the strict technical limits are met:

ISED Canada - Explicit Prohibition of Broadcasting
In Canada, ISED's regulatory framework, particularly RSS-Gen, General Requirements for Compliance of Radio Apparatus, explicitly defines "broadcasting" as transmissions intended for direct reception by the general public. It then explicitly states that licence-exempt radio apparatus standards, like RSS-210, Licence-Exempt Radio Apparatus: Category I Equipment, cover equipment for "radiocommunication other than broadcasting".

This means that while the technical limits in RSS-210 for certain frequencies might be comparable in power to Part 15.219, ISED's regulatory definition and scope of the standard preclude their use for anything that meets the definition of general public broadcasting.

Canadian regulations require a specific broadcasting licence and certification under different standards for any content intended for general public reception, regardless of how small the coverage area is.

 
--- You keep mentioning 15.219 has an approximate 200ft limit of range (as you did again in the chart), that contracts physics and is thus incorrect.

You are correct that citing a fixed distance of exactly 200 feet as an absolute, physical limit of range can be misleading and is an oversimplification. The actual range depends on environmental factors, receiver sensitivity, antenna efficiency, and ground conductivity.

The figure of approximately 200 feet (61 meters) is frequently referenced by the FCC in its guidance and interpretations of Section 15.219 because it represents a typical, estimated maximum service contour under ideal conditions when complying strictly with all technical specifications, particularly the 3-meter antenna/ground lead length restriction.

----Nevertheless, the 200ft estimate is not an accurate estimation, even in poor conditions a compliant 15.219 outdoor installation commonly achieves, in most cases, at least about a half mile range.

While actual user results might vary, the claim that a compliant Part 15.219 installation commonly achieves a half-mile range is generally considered an exaggeration or is likely due to the operator using a non-compliant setup .. ... Achieving a signal a half-mile away would require exceptionally good conditions (e.g., highly conductive ground, line-of-site, a very sensitive receiver, absence of ambient noise) and likely involves only a very weak, fringe-level signal that is not reliably consistent.  .... The 200-foot estimate is a practical guideline for the reliable service area of a legal setup. 

--- No, it is not an exaggeration at all, it's physics, even engineers of the FCC Technical Rules Branch can and have confirmed that 15.219 in average ground conductivity conditions a usable signal up to a mile and a half, and potentially more.

While achieving a range of a mile or more might be technically possible under highly specific, optimized circumstances in a physics-based calculation, official FCC documentation and expert analysis consistently describe the typical, reliable service area of a compliant Part 15.219 device as being significantly less, in the order of hundreds of feet.

The disparity between theoretical maximum propagation and the practical regulatory understanding lies in what constitutes a "usable signal" and the definition of a "compliant installation" under the rules:

Usable Signal Definition: The FCC defines a "usable signal" within the context of minimizing interference. The goal of Part 15 is to keep the signal extremely localized. The regulations rely on the fact that an operator following the 3-meter antenna rule will inherently restrict their signal to a small area.

While an engineer might confirm the theoretical maximum propagation distance in optimal conditions, the regulatory framework treats these devices as highly constrained systems whose practical application is intended to be limited to a small, private area. The common interpretation and enforcement focus on keeping the reliable service area small.

That's an interesting conversation.  I don't know how accurate it is, but it's interesting nonetheless.

I think it just made up the statement "You can use a low-power, licence-exempt device under RSS-210 if the signal is for a limited, specific group of users in a very constrained area".  Nowhere in the rules does it state that, at least for RSS-210.

Now, it is contained in the rules for RSS-123.  That is a licensed low power service (up to 1 watt) that is not considered broadcasting by the CRTC, and it is essentially that statement - a device that transmits a signal for a limited and specific group of users in a constrained (ISED uses the term 'bounded') area.

It may have confused the two services (RSS-210 & RSS-123), or it may have inferred that the same conditions apply for RSS-210 as they do for RSS-123.

And it may even be true.  If RSS-123 is not considered broadcasting, then why would RSS-210 in a bounded area not be the same?  The only difference is that one is licensed because of the greater power used; the other is not.

The difficulty then comes in determining precisely what a bounded area means.

@artisan-radio Yeah, I noticed it also interloped US with Canada rules a few times. "It" being Google AI which I forgot to point out. The ai responses were also edited down a lot (not changed) because it repeated itself a lot. Most of it's responses were a lot longer that the portions  quoted above Sometimes I completely forget I'm not talking to a person. Suddenly asking myself what the hell am I doing? I am completely aware how unreliable it can be. I never have any faith in it's responses but it can be quite useful as a broad starting point. I notice even it's own citations (in the form of website links) often do not confirm what it just said. No question that ai makes things up all the time (often described as "hallucinating").

Nevertheless, after the conversation I do now comprehend the "broadcasting vs non-broadcasting" thing a lot better. However, the fact that in both countries the definitions of "broadcasting" is identical, and that RSS-210 and 15.219 are identical, it's therefore reasonable to assume that operation of the devices would be also be identical.

The primary distinction is Canada's two licence-free transmitter certifications. The US has always been clear with it's permission that you can use part 15 transmitters for whatever you want, whenever you want, and to broadcast whatever you want. That, curiously, is a freedom that Canada does not allow, which for some reason surprises me.

I wonder if.. actually I strongly suspect, the Canada decision of specific limited range "broadcast" certifications of licence-free transmitters was directly related to the major clash between the NAB and the FCC in the early/mid 1970s over Part 15 AM use (15.219) by the HWY Departments, the NAB didn't really kicked in gear with their objections until the HWY Dept. Part 15 transmitters began to also carry traffic reports  - to the NAB that was the straw that broke the camels back - because at the time regular traffic reports was a major draw for people on the road to tune in. Great expense was put into buying or renting helicopters by radio station to regularly gather and relay that info in their broadcast for real-time updates. The NAB was enraged when the little part 15 roadside transmitters began broadcasting similar info.

The FCC remedy was to eliminate 15.219 and create the more controllable licenced TIS  (which the NAB was wasn't very enthusiastic about either). It was really a fluke that the elimination of 15.219 was not passed, fortunately for us.

Canada after witnessing the whole fiasco here in the US, apparently avoided the entire situation by creating two forms of licence-free AM.

Or so I deduce.

Posted by: @artisan-radio

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... It may have confused the two services (RSS-210 & RSS-123), or it may have inferred that the same conditions apply for RSS-210 as they do for RSS-123.

And it may even be true.  If RSS-123 is not considered broadcasting, then why would RSS-210 in a bounded area not be the same?  The only difference is that one is licensed because of the greater power used; the other is not.

The difficulty then comes in determining precisely what a bounded area means.

Ok you lost me there .. I don't feel like looking up RSS-123, but yeah, what is a bounded area?. To me that could mean a school, a park, a parking lot, or a neighborhood... or any number of other examples