L. P. Ryan / Low Power Radio cited by FCC for selling pre-built AMT 3000

I'm sure many of you have seen this already on the FCC site:

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-07-4570A1.pdf

Mr. Ryan claims he only builds the SS Tran for customers but the FCC noted that on his website, www.ontheair3.com, he sells the AMT 3000 completely assembled which the agency ruled is against the law. Mr. Ryan has been fined $7000.00.

A couple of other points I noted in the NAL:

"Moreover, nowhere on the website does Low Power Radio advertise an “assembly service,” indicate that
potential customers could purchase the SSTRAN AMT3000 directly from SSTRAN and that Low Power
Radio would assemble it for them, or provide a price for an assembly-only service."

This leads me to believe that if someone bought an AMT 3000 in kit form directly from the manufacturer and simply had Mr. Ryan build it for a fee than it would be legal.

Another point in the document that is curious is footnote 10:

"Although Mr. Ryan acknowledges that there is no certification for the SSTRAN AMT3000, the website falsely advertises the assembled device as “Part 15 compliant.”

I was under the impression that even if a part-15 TX is uncertified by the FCC, if the manufacturer follows the commission's part-15 specifications, the device is itself compliant.

Anyway, it's ashame Mr. Ryan has to be put through this ordeal as he is disabled and on a fixed income.

db

Mind you, in a country where people get away with heinous crimes such has rape and murder, rest assured the FCC will go beyond the call to catch and apprehend a "madman with a soldering iron". God forbid the commision will do something that would benefit the country as a whole instead of something so trivial and stupid!

Wholly agreed, Bill. Unfortunately, this sort of thing no longer surprises me, given what a cavalcade of corporate deference our political system has become. The FCC has a definite mandate (given the neoliberal economic theories of our current administration) to kiss whatever part of the corporate anatomy is waggled in front of it. Apparently, even the possibility of someone serving his own neighborhood with 1/10 watt of monaural AM is a perceived threat to mega-corporate dominance, and thus considered a proper subject of any kind of harassment these plutocrats can dream up. Jefferson's "tree of liberty" is thirsty indeed...

The FCC really is not as bad as many of you believe. He should follow the instructions on the NAL and
they will ruduce or cancel the fine. If he wishes to continue in this line of work, he should work with the commission to get type certification or leave some parts unassembled so it is still a kit.
And, I hope the FCC looks into LPAM community broadcasting soon. This may save AM.

Saving AM? Hmmmm, I dont know if that could even occur. Americans have gone so far with technology, Ipods, and such.. I think soon all radio will be past history.
Who in the heck even needs a radio anymore? Most stations are all jukebox setups .
No local programming. I watched as a local radio station on AM, One I worked for, went from Local Community Programming to a relay station for all syndicated talk programming. It was the worst, now they are slowly re adding some local flavor, and Im hoping soon they will go back to serving small time america again with a local radio format..

the only things that will save AM are

1) Require AM Stereo
2) Re Organize the Band to Allow 20Khz Audio Bandwidth
3) Require Radio Manufacturers to build AM Radios that perform to minimum spec's
4) and most inportant Fresh local oriented community programming.
5) Get rid of this daytime only and directional array crap. Run a certain power level 24/7
6) Bring back true Regional Clear Channels
7) open up the Band between 1700 and 1800 for Part 15 AM Broadcasters only. allow 100mw with what ever antenna design a person can come up with.
8) Require Radio Manufacturers receivers to tune to this new band.

in short the nail is in AM's coffin, because we know none of the above will ever happen. The nail will be in FM's coffin when mobile WiMax becomes main stream.

The FCC is definitely on the warpath against kit builders.

They just rejected Richard Mann's (d/b/a The Antique Radio Collector) contention that he just builds the AMT 3000 for customers.

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-07-4716A1.pdf

Here is the crux of the matter:

"We note that Antique Radio Collector’s LOI Response included
marketing material that stated “we [Antique Radio Collector] have your AMT 3000 shipped to us from
the manufacturer (they do not offer pre-built transmitters), build and test it for you and then ship your
AMT3000 ready for use"...we have found that the sale and shipment of an unauthorized device assembled from a kit violates Section 302(b) of the Act".

Still, we have yet to see a situation in which the customer purchases an AMT 3000 directly from the manufacturer and physically sends it to a builder for completion. In both cases, including Mr. Ryan's, the builder is handling the transaction between SS Tran and the customer which the FCC construes as selling completed transmitters.

"On November 15, 2006, the Spectrum Enforcement Division of the Enforcement Bureau
issued a Letter of Inquiry to Antique Radio Collector in response to a complaint alleging that
Antique Radio Collector was marketing in the United States fully-assembled AM transmitters,
specifically, the SSTRAN model AMT3000 AM transmitter."

I'm assuming the complaint came from a licensed broadcaster. But what broadcaster has so much time on his hands that he would chase down and file a complaint against some poor kit builder? Is his business that bad and is he that desperate?

It's really pathetic especially when you consider that the number of people actually buying and using a part-15 AM TX is very small.

db

dbdigital said:

I'm assuming the complaint came from a licensed broadcaster. But what broadcaster has so much time on his hands that he would chase down and file a complaint against some poor kit builder? Is his business that bad and is he that desperate?

Click to expand...

this was hashed out at part15us already the first time around. thru a FOIA request one of the posters there found out that the complaint was filed by a certain prominent seller of certified transmitters.

This is unfortunate. I do know that transmitter sales are very slow right now and have been for a long time. I suspect that the entire FCC Certified Part 15 AM transmitter business is dying a slow death. I do know that once word gets around that a certain someone filed a complaint against these guys that his reputation will be ruined.

A word of caution to anyone that reads this message. A few years ago I was privy to some inside information concerning a mid size radio market on the eastern seaboard. It turns out a local licensed broadcaster started to complain about a couple of things to the FCC about a competing station. Then the competing station filed a complaint against the station that filed the original complaint. The two other stations in that market got into the act and they all started to file complaints against one another. Finally, the FCC became sick of the entire situation and decided to audit EVERY single licensed station in that market. Oddly enough, the Part 15 AM station in that market was left untouched from this fray. Eventually all the stations involved were found to be non compliant in at least one or more areas and fines were levied against each one.

Moral of the story? You should think twice about filing a frivolous complaint against any station, whether it be a licensed station or Part 15 station. It could come back to haunt you. Let sleeping dogs lay is a good idea.

I would think that a Part 15 would be viewed as such a low threat it wouldn't be worth the effort to go after them. Unless they were causing harmful interference I can't imaging anyone bothering them. Then again, having hear the pirate FMs in New York I would think this sort of activity would be a red flag to both the FCC and licensed stations.

Dr_Johnnie_Fever said:

dbdigital said:

I'm assuming the complaint came from a licensed broadcaster. But what broadcaster has so much time on his hands that he would chase down and file a complaint against some poor kit builder? Is his business that bad and is he that desperate?

Click to expand...

this was hashed out at part15us already the first time around. thru a FOIA request one of the posters there found out that the complaint was filed by a certain prominent seller of certified transmitters.

Click to expand...

Do you mean someone who sells certified part-15 transmitters or someone who just sells transmitters?

If sales of part-15 AM transmitters has been dwindling, as William reports, it no doubt reflects the continuing diminishment of the AM band as a whole.

db

DB. Sales of the non Type Accepted units still seems to be strong, at least according to what I've heard and read. People just don't want to shell out a grand for a transmitter even if it has the FCC's seal of approval on it.

because the seal no longer means a garunteed pass anymore. the broadcasters, nab, pbs want us off, and if you are unfortunate to live in NJ or FL these states want you off also.

Dr_Johnnie_Fever said:

because the seal no longer means a garunteed pass anymore.

Click to expand...

Can you clarify this? I would think if you're using a certified transmitter and it's installed correctly and meets Part 15 that there would be no legal standing for being shut down. I would certainly be more learly about a kit without any sort of certification.

Regular stations may be unhappy about the presence of a Part 15 station, but I can't imagine them getting their panties in a bunch over somebody with 1/10th of a watt!

dbdigital said:

Dr_Johnnie_Fever said:

dbdigital said:

I'm assuming the complaint came from a licensed broadcaster. But what broadcaster has so much time on his hands that he would chase down and file a complaint against some poor kit builder? Is his business that bad and is he that desperate?

Click to expand...

this was hashed out at part15us already the first time around. thru a FOIA request one of the posters there found out that the complaint was filed by a certain prominent seller of certified transmitters.

Click to expand...

Do you mean someone who sells certified part-15 transmitters or someone who just sells transmitters?

If sales of part-15 AM transmitters has been dwindling, as William reports, it no doubt reflects the continuing diminishment of the AM band as a whole.

db

Click to expand...

I just read the thread at part15.us concerning the complaint filed against Antique Radio and who was behind it and I must say that I am disappointed that a transmitter manufacturer would feel so threatened by some guy selling a few pre-built AMT 3000s that he would unleash the FCC on him.

Yes, what Mr. Mann did was illegal but legality was not the motivation here. It was a case of turf protection.

As I see it, the SS Tran TX and a type-accepted TX such as the Rangemaster are targeting two different customers. With a few exceptions, the AMT 3000 customer would probably never consider a Rangemaster because of it's expense (this person is a hobbyist/experimenter) and the Rangemaster customer would want a TX that is more rugged and take more abuse than what an AMT 3000 would provide as well as being FCC certified (this customer needs a transmitter for commercial use).

I clearly see a market for both units.

db

I understand that the fines resulted by the FCC applying the letter of the law but if one backs up one step one could ask "If I have a SSTRAN transmitter, what difference does it make by any measure whether I built it from a kit or purchased it built from a kit by someone else?".

This can be dangerous ground since one interpretation of the rules which provide for self built non-certified transmitters is that this is to allow experimenters a means to experiment. The kits seem to be somewhat allowed (rules are not clear) by this exemption to certification and if the issue is pushed with the FCC the rules could easily be changed to remove this provision. I don't see it going the other way to allow sales of completed transmitters.

Neil

Bill. Yes, believe it or not some licensed broadcasters honestly have a pet peeve with legal, Part 15 stations. Some go as far as trying to label us as pirates and will file a frivolous complaint against the station with the FCC.

One example. Village Radio of Montclair, NJ, a suburb of NYC, was getting hounded by more than one station in the NYC market despite the fact they were using a FCC Type Accepted transmitter. The FCC was familiar with the transmitter and told the licensed stations to "stuff it".

Commercial Part 15 AM operations can really strike a nerve with some licensed station's management. They firmly believe they will and are losing sales to these stations. In reality that really is not the case. In most cases, the businesses that buy time on Part 15 stations cannot afford to buy time on local licensed stations. The Part 15 station is an entry level or gateway method to reaching at least some of their potential market via the broadcast medium. My personal belief is that it is the mission of a Part 15 AM to help grow these small businesses into more profitable operations so that they can then afford to buy time on a licensed station, once they outgrow the Part 15 station.

William, out of curiousity, could you also report how many Rangemasters the Monclair NJ station had, their frequencies, and their locations?

That information may help us all to decide the issue of interference by a part 15am to a licenced station.

I read that story and I have reletives in that area, so please do report it as I won't.

Remember folks, there are two parts to every story, the reports I see here are very one sided.
Gee, I just can't think of why that is.

I have friends and relatives in that area too. Therefore I cannot divulge any additional information on the issue.

So, Mr Ryan 's offense wasn't bad engineering. It's not that he did bad work or the part 15 transmitters were junk. In fact, they
were good.

He got caught up in paperwork. The transmitters didn't have a Type Certified sticker on them.

OK! He wasn't turned in to the FCC by a commercial broadcaster. He was turned in by his competition.

A high ranking FCC official once told me that most pirates are turned in by other pirates. And in this case by someone else in the low power movement.