Attention Part 15 Station Owners and potential Licensed LPFM Applicants...

[WCWalker]

Take it easy, William.

Maybe you should have a calm talk with a lawyer (Schellhardt, perhaps) to find out if you actually have a libel case. To me, it doesn't sound like anything a judge would take seriously, but I'm a layman.

Best of luck!

Ermi. Have you read some of his past allegations concerning the manufacturers of these transmitters? He has actually contacted i.e. harassed more than one of them with some claims that I would rather not go into right now. You can find them in his past posting history if you dig around. And then claiming that most of these stations are illegal? Preposterous especially when you consider most of these stations have actually received and passed FCC inspections. I know, because I hear from a lot of these people because they own Rangemaster transmitters or something similar and many have contacted me to have their station website listed on my LPAM Network website station database.

He really needs to find a more constructive way to spend his time. Harping on this issue year after year has me believing he has some personal issues....

 

[Ermi Roos]

Yes. I am aware of the controversy about the "ground lead." Some of the earliest topics on this discussion board have extensive, sometimes heated, debates about it. This has been going on for several years. There certainly is disagreement about this subject, but disagreement does not equate to libel.

As for R. Fry making different ("better") use of his time, it's obviously up to him, since he is free to do anything he wants; but I have what I hope may be a constructive suggestion: Since the ground lead is of great interest of him, why not try to find a technical work-around to mitigate the limitations of Section 15.219(b)? (Class E AM modulation, more efficient loading coil, lower ground plane conductivity, etc.)?

 

[rfry]

...I have what I hope may be a constructive suggestion: Since the ground lead is of great interest of him, why not try to find a technical work-around to mitigate the limitations of Section 15.219(b)? (Class E AM modulation, more efficient loading coil, lower ground plane conductivity, etc.)?

Higher r-f output power from the transmitter without exceeding the 100 mW input power permitted by 15.219(a), and reducing losses in the antenna system that occur in a loading coil and r-f ground plane clearly will improve the coverage capability of any transmit system. But just by intuition, those concepts probably are understood and accepted already by most unlicensed users of the AM broadcast band.

Intuition is not as useful in understanding the r-f characteristics of a long, conducting path leading from an elevated transmitter+whip to a functional r-f ground (something buried in the earth, typically), or in understanding the fact that an r-f ground cannot and does not exist at the top of that long conducting path to a buried r-f ground. A technically valid understanding of these issues requires an engineering-based approach.

This ground lead issue directly affects the ability of the installed system to functionally meet 15.219(b), so anyone who wishes to operate under Part 15 should be served well by posts with information and documentation helping to understand it. Those whose installations for whatever reason(s) do not comply with Part 15 need not be concerned about such posts, but then neither should they identify themselves as Part 15 operators, or expect to be exempt from FCC action if Part 15 applies to them.

And to W. Walker: Note that my posts discuss hardware and operating configurations that functionally meet Part 15, and compare them to some that do not. It is up to readers to decide in which category they belong, as only they know what they have installed. I have never alleged that most Part 15 AM stations are operating illegally -- and couldn't, as I have no way of knowing that. This must be the judgment of others.

As reported by some on these boards, the FCC has inspected and not cited some unlicensed AM stations using elevated mounts with long, radiating ground conductors. However the FCC has issued citations in some of these cases, as shown in the public list at http://www.fcc.gov/eb/FieldNotices/ .

Ultimately it is the choice of each person as to how s/he wishes to operate an unlicensed AM/FM station, and at what risk.

 

[WCWalker]

...I have what I hope may be a constructive suggestion: Since the ground lead is of great interest of him, why not try to find a technical work-around to mitigate the limitations of Section 15.219(b)? (Class E AM modulation, more efficient loading coil, lower ground plane conductivity, etc.)?

Higher r-f output power from the transmitter without exceeding the 100 mW input power permitted by 15.219(a), and reducing losses in the antenna system that occur in a loading coil and r-f ground plane clearly will improve the coverage capability of any transmit system. But just by intuition, those concepts probably are understood and accepted already by most unlicensed users of the AM broadcast band.

Intuition is not as useful in understanding the r-f characteristics of a long, conducting path leading from an elevated transmitter+whip to a functional r-f ground (something buried in the earth, typically), or in understanding the fact that an r-f ground cannot and does not exist at the top of that long conducting path to a buried r-f ground. A technically valid understanding of these issues requires an engineering-based approach.

This ground lead issue directly affects the ability of the installed system to functionally meet 15.219(b), so anyone who wishes to operate under Part 15 should be served well by posts with information and documentation helping to understand it. Those whose installations for whatever reason(s) do not comply with Part 15 need not be concerned about such posts, but then neither should they identify themselves as Part 15 operators, or expect to be exempt from FCC action if Part 15 applies to them.

And to W. Walker: Note that my posts discuss hardware and operating configurations that functionally meet Part 15, and compare them to some that do not. It is up to readers to decide in which category they belong, as only they know what they have installed. I have never alleged that most Part 15 AM stations are operating illegally -- and couldn't, as I have no way of knowing that. This must be the judgment of others.

As reported by some on these boards, the FCC has inspected and not cited some unlicensed AM stations using elevated mounts with long, radiating ground conductors. However the FCC has issued citations in some of these cases, as shown in the public list at http://www.fcc.gov/eb/FieldNotices/ .

Ultimately it is the choice of each person as to how s/he wishes to operate an unlicensed AM/FM station, and at what risk.

You made the following statement in the second post in this string.

"An interesting aspect of this is that the larger the community served by an unlicensed Part 15 operation, the more likely it is not to meet Part 15. Might that disqualify the operator from being granted an LPFM license?"

Clearly the implication is that any station that has a broadcast radius larger than you deem acceptable it must be operating outside the rules. Since there are thousands, yes literally thousands of Type Accepted Part 15 AM transmitters now in use around the country and since they offer superior range to that of a kit or home brew station, you automatically assume that they are not compliant. Well, technology changes with time and new designs and components have been used to expand the range of Part 15 AM broadcast transmitters.

Over the years you've shown an unhealthy preoccupation with the allegations that you've made concerning the manufacturers and users of Type Accepted Part 15 AM devices. In contrast, you seem to ignore the fact that licensed broadcasters break far more rules than non licensed broadcasters at least on the AM broadcast band. I'd have more respect for your opinions if you at least would also come down on licensed broadcasters that break the rules with equal fervor. Unfortunately you drone on and on with the same boring statements as found in this post above in a cut and paste manner. How many dozens of times have we seen you write the following statement and others ad nauseum?

"Ultimately it is the choice of each person as to how s/he wishes to operate an unlicensed AM/FM station, and at what risk."

Just because a few FCC notices indicate non compliance with the ground rule hardly means that ANY Part 15 AM station with an extended range is non compliant. Years ago I mentioned that this issue has less to do with your engineering theories and more with the interpretation of the rules and defining what the parts of the transmitter are and the chain that follows.

 

[WCWalker]

How often do we see or hear of something like this happening with a licensed station? And how often does the FCC even bother to follow up on this problem? This proves my point. Mr. Fry conveniently ignores the fact that more licensed stations violate the rules on a daily basis than Part 15 broadcasters using a Type Accepted transmitter.

http://boards.radio-info.com/smf/index.php?topic=185993.0

 

[rfry]

Since there are thousands, yes literally thousands of Type Accepted Part 15 AM transmitters now in use around the country and since they offer superior range to that of a kit or home brew station, you automatically assume that they are not compliant. ... Just because a few FCC notices indicate non compliance with the ground rule hardly means that ANY Part 15 AM station with an extended range is non compliant.

However an unlicensed AM transmitter that is FCC certified for Part 15 (Type Acceptance does not apply) can be installed in such a way that it does not meet 15.219(b). A fairly well-known example of this resulted in an NOUO issued to the operator of a Part 15 certified transmitter in Oregon.

Although an FCC NOUO never identifies the transmitter involved, in this case the website of its operator does so (see the entry for Feb 4, '10 at http://www.kencradio.com/press.php?page=6 ).

 

[WCWalker]

Since there are thousands, yes literally thousands of Type Accepted Part 15 AM transmitters now in use around the country and since they offer superior range to that of a kit or home brew station, you automatically assume that they are not compliant. ... Just because a few FCC notices indicate non compliance with the ground rule hardly means that ANY Part 15 AM station with an extended range is non compliant.

However an unlicensed AM transmitter that is FCC certified for Part 15 (Type Acceptance does not apply) can be installed in such a way that it does not meet 15.219(b). A fairly well-known example of this resulted in an NOUO issued to the operator of a Part 15 certified transmitter in Oregon.

Although an FCC NOUO never identifies the transmitter involved, in this case the website of its operator does so (see the entry for Feb 4, '10 at http://www.kencradio.com/press.php?page=6 ).

We know, we know. I am familiar with the case having heard from the owner and also Keith Hamilton. Everything is not as it appears to be on the surface.

I have an idea. Why not ask Col. Klink to loan you Sgt. Schultz and a few other of his prison guards to use while you are out hunting down these 100 mw menaces to society. While you position the guards around the perimeter of each property to form an impregnable ring of steel where nothing can get in our out, you then may personally inspect each Part 15 AM transmitter installation to see if it is full compliance with the rules.

BTW. How many Part 15 AM stations utilizing Type Accepted transmitters have you visited personally? I can honestly say I've seen quite a few over the years and have installed a few for past customers. BTW. To date, not one of the transmitters I sold or installed every so much as received an NOUO, let alone got shut down.

 

[rfry]

We know, we know. I am familiar with the case having heard from the owner and also Keith Hamilton. Everything is not as it appears to be on the surface. ...

Very good. And if the basis for your quote clip shown above is valid, could you please post the information that doesn't appear "on the surface" -- which, if you can prove such to be true, might help other unlicensed users of transmitters FCC-certified for Part 15 AM to avoid such FCC problems?

 

[Ermi Roos]

I can appreciate that there are instances where some information can't be made public, and I understand why Mr. Walker, or anybody else, would not want to post such information. But then why allude to the existence of such information at all? By making mysterious, unsupported, statements, Mr. Walker is trying give credibility to his comments without supplying any proof. If there's something you don't want to talk about, then don't.

 

[WCWalker]

I can appreciate that there are instances where some information can't be made public, and I understand why Mr. Walker, or anybody else, would not want to post such information. But then why allude to the existence of such information at all? By making mysterious, unsupported, statements, Mr. Walker is trying give credibility to his comments without supplying any proof. If there's something you don't want to talk about, then don't.

Kind of like Fry eh? He can't substantiate his claim where he alleges Part 15 AM stations are running afoul of the rules when he believes they broadcast further than they should. And his assertions against certain manufacturers of Part 15 transmitters could also be considered frivolous.

Let's just say for the sake of argument that discretion is the better part of valor. I am not about to divulge any important information to people that would use it against those that are trying to further the development of Part 15 broadcasting.

 

[rfry]

Kind of like Fry eh? He can't substantiate his claim where he alleges Part 15 AM stations are running afoul of the rules when he believes they broadcast further than they should.

The link below leads to an engineering analysis that will substantiate to objective readers exactly why and how elevated and whip & mast systems with long, radiating conductors to r-f ground are "running afoul of the rules" applying to Part 15 AM.

http://i62.photobucket.com/albums/h85/rfry-100/AM_System_Comparison.gif

 

[WCWalker]

Yawn. ZZZZZZZZZZZZZZZZZZZZZZZZZZZZZZZZZZZZZZZZZ.

This subject has NOTHING to do with the original post. Yet again you've hijacked another thread.

 

[Ermi Roos]

Instead of an engineering analysis (which apparently puts some people to sleep), what I would do to substantiate the assertion that that the use of long ground leads is against the rules is to supply links to NOUOs on the FCC website that were issued to operators for using long ground leads. The operators include KENC, Liberty 1640, Iglesia de Dios Ebenezer et al.

In posts about these NOUOs on discussion boards, the operators receiving the NOUOs were sometimes accused of doing something unspecified wrong other than just using long ground leads. I think that it is bad form for manufacturers or their agents to make ambiguous accusations like this against their paying customers.

 

[WCWalker]

The link to the article on my website DOES NOT address issues of a technical nature as they pertain to either LPFM or Part 15 AM broadcasting. This article was published in an effort to help existing users of Part 15 AM transmitters that are interested in obtaining a LPFM station a means to come together and be heard at the FCC.

I've got a couple of friends that are Broadcast Engineers. I have other friends with many years of radio engineering or related experience. I have acquaintances on the internet that are Broadcast Engineers that I can also converse with if I need any enlightening on various technical subjects.

What I don't need is a couple of TROLLS like you and Fry taking over a thread and article that is in NO WAY, SHAPE OR FORM about the technical side of radio or designated as a discussion of the technical side of either LPFM or Part 15 AM.

Do I make myself clear?

 

[rfry]

Mr. Walker: My response with the link to an engineering analysis showing the performance of two AM transmit systems was a direct reply to your post about me in this thread of March 7, 09:02:22 PM CST stating, "He can't substantiate his claim where he alleges Part 15 AM stations are running afoul of the rules when he believes they broadcast further than they should." So my post followed in logical sequence to, and at the prompting of yours.

My post and link did substantiate the fact that installations "running afoul" of Part 15.219(b) can produce much greater coverage areas than those which do not.

Some may not like this reality. But it is a reality that should not be denied, evaded, or suppressed.

 

[WCWalker]

Mr. Walker: My response with the link to an engineering analysis showing the performance of two AM transmit systems was a direct reply to your post about me in this thread of March 7, 09:02:22 PM CST stating, "He can't substantiate his claim where he alleges Part 15 AM stations are running afoul of the rules when he believes they broadcast further than they should." So my post followed in logical sequence to, and at the prompting of yours.

My post and link did substantiate the fact that installations "running afoul" of Part 15.219(b) can produce much greater coverage areas than those which do not.

Some may not like this reality. But it is a reality that should not be denied, evaded, or suppressed.

Good God man. You've taken arrogance to another level. Why not start another string to discuss the technical side of Part 15 AM? This is not the appropriate thread for this discussion.

 

[WCWalker]

Mr. Walker: My response with the link to an engineering analysis showing the performance of two AM transmit systems was a direct reply to your post about me in this thread of March 7, 09:02:22 PM CST stating, "He can't substantiate his claim where he alleges Part 15 AM stations are running afoul of the rules when he believes they broadcast further than they should." So my post followed in logical sequence to, and at the prompting of yours.

My post and link did substantiate the fact that installations "running afoul" of Part 15.219(b) can produce much greater coverage areas than those which do not.

Some may not like this reality. But it is a reality that should not be denied, evaded, or suppressed.

The center of the USA's population according to the Census Bureau has just moved from Phelps County, Missouri to Texas County, Missouri.

 

[druidhillsradio]

I am curious as to why "Licensed" stations get to bend rules, like excessive power, no tower lights, non-functioning directional arrays, no reduced power at night, etc.. The FCC is aware and looks the other way. Same situation in the Amateur Radio Service. K1MAN has been running for years without a valid license, and it's only just recently, the case goes to an administrative court? Where is the enforcement? Where are the storm troopers? But have a long radiating ground, and the FCC will be at your door. Go figure.

 

[Ermi Roos]

It is true that FCC enforcement is not consistent, both for licensed and unlicensed stations. Long ground leads are sometimes allowed and sometimes not. It's the same with FM field strength exceedind the Section 15.239 limit. How about 87.9 MHz? Some get NOUOs for using this channel, and others operate unlicensed for years without incident (yes, I know that there are a few licenses for this frequency--FM channel 200, which is not permitted under 15.239).

For licensed stations, I see a lot of NALs for tower violations (painting, lights, identification, and such), and some are for unauthorized power at night, incomplete station paperwork, non-functioning EAS, etc.

There is a lot of enforcement, but it is not uniform or universal.

 

[druidhillsradio]

How about 87.9 MHz? Some get NOUOs for using this channel, and others operate unlicensed for years without incident (yes, I know that there are a few licenses for this frequency--FM channel 200, which is not permitted under 15.239

It will interesting to see how much continued enforcment on this frequency will be had since TV CH 6 is vacated.