Assisted Listening device interferring on Amateur Radio band

Discussions around meetinghouse sound systems, microphones, assisted listening devices, and translation equipment
russellhltn
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Re: Assisted Listening device interferring on Amateur Radio

Postby russellhltn » Wed Apr 09, 2014 2:42 pm

StevePoulsen wrote:These are indeed old. If they remain functional, I see no reason to replace them, but they will die and need to be replaced eventually.

Agreed. They were found in a library clean-out after the retirement of the long-time librarian. But since they work on our system, I'll let the new librarians know how they work. As it happens, there's one librarian that complains of difficulty in hearing during sacrament meetings due to the echos in the chapel.
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Re: Assisted Listening device interferring on Amateur Radio

Postby aclawson » Sun May 04, 2014 10:57 am

Until the problem is resolved it is critical that you stop using the devices immediately: it is a significant violation of federal regulations and I believe the fines start at $29,000 for each violation. Since you have been notified of the problem it is your (the church's) responsibility to stop the violations ASAP. The amateur radio operators have first right to those frequencies and have every right to file a formal complaint with the FCC which will take action.

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Re: Assisted Listening device interferring on Amateur Radio

Postby russellhltn » Sun May 04, 2014 11:17 am

aclawson wrote:Until the problem is resolved it is critical that you stop using the devices immediately:

Not that simple. The transmitter is wired into the chapel sound system and comes on automatically. The cabnet is typically locked and local leaders do not have a key.


aclawson wrote:it is a significant violation of federal regulations and I believe the fines start at $29,000 for each violation.

I'm not entirely sure that's true. Keep in mind that unlike many sources of interference that are unintentional transmitters, this is an intentional transmitter. So far we have no evidence that it's not meeting it's specifications.

That's not to say there is no responsibility to resolve it, but it strikes me as unlikely that the FCC will issue any fines unless they feel that the church not addressing this with appropriate speed.
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Re: Assisted Listening device interferring on Amateur Radio

Postby aclawson » Sun May 04, 2014 11:33 am

That's taking a gamble - there is no "we'll get around to it" exemption. Those frequencies belong to the amateur radio operators and are commonly used during emergency situations.

The situation is address by §15.5 of Title 47. Once somebody reports the problem to the FCC then you must stop using the device immediately and may not use it again until the problem is resolved.

§15.5 General conditions of operation.
(a) Persons operating intentional or unintentional radiators shall not be deemed to have any vested or recognizable right to continued use of any given frequency by virtue of prior registration or certification of equipment, or, for power line carrier systems, on the basis of prior notification of use pursuant to §90.35(g) of this chapter.

(b) Operation of an intentional, unintentional, or incidental radiator is subject to the conditions that no harmful interference is caused and that interference must be accepted that may be caused by the operation of an authorized radio station, by another intentional or unintentional radiator, by industrial, scientific and medical (ISM) equipment, or by an incidental radiator.

(c) The operator of a radio frequency device shall be required to cease operating the device upon notification by a Commission representative that the device is causing harmful interference. Operation shall not resume until the condition causing the harmful interference has been corrected.

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Re: Assisted Listening device interferring on Amateur Radio

Postby russellhltn » Sun May 04, 2014 12:46 pm

COMTEK runs under Part 90, not Part 15.

Emergency communications do not normally use that frequqncy. It's usually in the voice section.
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Re: Assisted Listening device interferring on Amateur Radio

Postby Mikerowaved » Sun May 04, 2014 3:19 pm

If changing the channel is not a viable solution, then it would be a simple matter (for someone with access) to install a low-pass filter on the transmitter. Something like the $35 Mini-Circuits BLP-90+ would reduce 144MHz emissions by ~40dB, while only adding a negligible 0.5dB insertion loss at 72MHz.
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aclawson
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Re: Assisted Listening device interferring on Amateur Radio

Postby aclawson » Sun May 04, 2014 6:23 pm

russellhltn wrote:COMTEK runs under Part 90, not Part 15.

Emergency communications do not normally use that frequqncy. It's usually in the voice section.


Emergency communications use whatever happens to work at the time.

Knowingly causing interference to the amateur bands is highly illegal and can bring a lot of trouble upon the church - I checked with an RF engineer I know who spends every day dealing with FCC violations and he relates that the FCC has a well established history of walking into church during services and shutting things down over this kind of thing. Further, Part 90 subpart N explicitly states that the operator must take reasonable steps to eliminate harmful interference.

Beyond that, blocking amateur radio frequencies is being a bad neighbor. Skip the very real risk of fines and bad PR, eliminating the harmful interference is simply the right thing to do.

Don't have the key to the cabinet? Get FM out there immediately - if they are too busy then this is definitely an instance where the SP should get involved. This is serious business and really can't wait. The FCC will not accept "well, the guy with the key to the cabinet was too busy to get around to this" and if you have a crotchety amateur willing to send a constant stream of complaints to the FCC then bad times are in store.

OP is almost two months old and even though there does not seem to be any sense of urgency in the thread it really is a big deal.

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Re: Assisted Listening device interferring on Amateur Radio

Postby aebrown » Sun May 04, 2014 9:13 pm

aclawson wrote:OP is almost two months old and even though there does not seem to be any sense of urgency in the thread it really is a big deal.

There's been some really helpful information posted in this discussion. It's clear that certain kinds of interference can create significant legal liability for the Church.

But I would note that just about everything posted after the original post about what may or may not have been done is speculation. The only real piece of information about the actual situation mentioned in the OP is this post from a Church employee. There's no reason to assume that the FM group he contacted did not take prompt action and deal with it. The original poster has never responded to let us know about the resolution (or non-resolution) of the situation.

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Re: Assisted Listening device interferring on Amateur Radio

Postby russellhltn » Sun May 04, 2014 9:42 pm

aclawson wrote:I checked with an RF engineer I know who spends every day dealing with FCC violations and he relates that the FCC has a well established history of walking into church during services and shutting things down over this kind of thing.

I'd be interested in reports of such actions. I'm guessing it's done for far more egregious violations such as unlicensed equipment.


aclawson wrote:Further, Part 90 subpart N explicitly states that the operator must take reasonable steps to eliminate harmful interference.

Subpart N doesn't look like a good fit for this service. It appears to be more for two-way communication.

Subpart B looks to be the correct section. The frequency in question places a burden to assure no interference to TV channels 4 or 5.


aclawson wrote:Beyond that, blocking amateur radio frequencies is being a bad neighbor. Skip the very real risk of fines and bad PR, eliminating the harmful interference is simply the right thing to do.

I've not suggested otherwise. But I think your statements are a little over the top and do not reflect the most likely sequence of events. It's not something to be ignored, but I wouldn't go into a massive panic over it.


aclawson wrote:OP is almost two months old and even though there does not seem to be any sense of urgency in the thread it really is a big deal.

We never heard back from the OP what the resolution was, but if you look at Post #6, you'll see that people where involved. It probably got resolved shortly after.
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Re: Assisted Listening device interferring on Amateur Radio

Postby aclawson » Mon May 05, 2014 11:57 am

No, bringing awareness of the potential of breaking federal law and international treaty is not "over the top". The prevailing attitude is "sure, dude, whatever, we'll do whatever we want and nobody will care".

it strikes me as unlikely that the FCC will issue any fines unless they feel that the church not addressing this with appropriate speed.


is just such an example.

I am a licensed amateur radio operator. Operating rules and regulations matter to me a great deal, especially in a world where people have no respect or consideration for such "unimportant" laws. It was in clerk discussions years ago about running networks over power lines within a meetinghouse where it was pointed out that (especially at the time with such new solutions) such things could completely block amateur communications. Nobody cared.

I hear of various wards/stakes investing in two way radios for use during various events. Point out that it is illegal to use the GMRS frequencies without a license and you are either ignored or get a comment along the lines of "if they were illegal you couldn't buy them" or "nobody cares about that law". Doubly so if you are in one of the areas subject to the international exclusion of GMRS use on 462.650, 467.6500, 462.7000 or 467.7000 MHz. Again, try to point this out to almost anybody and the response is "eh, nobody cares. Don't be over the top."

The point is that this kind of thing isn't something that should be messed with or taken lightly. That guy in Florida received notice of $16,000 fines *per incident* because he didn't think that it was important to put a filter on his well pump. I'm not in the loop on the fines and enforcement actions, the RF engineer is. That's his job. He says he just heard of somebody fined $7,500 for refusing to replace a faulty dimmer switch.

Do not ignore these things. Read the manuals. Keep up with regulation changes. There is no call to dismiss cautionary notices out of hand as is being done here. That is all.


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