Ok fellows, last week after all the posts regarding what is legal or not, I posted this hypothetical installation to the FCC Office of Engineering and Technology in Washington, D.C., same office that said the 'kits' were legal... anyway this is the response, doesn't mean everyone's installation doesn't meet the Part 15.219 (b) rule, just be aware that if you have the transmitter attached to a metal tower, metal pole, etc. of any significant length you may have a problem... I will be correcting my transmitter mount accordingly.
"----- Original Message -----
From: Generic Office of Engineering Technology
To: [email protected]
Sent: Monday, January 09, 2006 1:22 PM
Subject: Response to Inquiry to FCC (Tracking Number 670631)
Inquiry:
I have a Part15 compliant AM transmitter to the Part15.219 rule... The transmitter is 30 feet high mounted on a metal pole, the 3 meter total antenna including 3 inches of ground lead is attached to the metal pole (30 feet long) mounted to the ground (elevated ground), attached to the pole is 64 radials, each radial 25 feet long in a spiral from the pole... the input to the transmitter is 100mw... is this legal in the FCC rules? Am I violating any Part15 rule by mounting the transmitter 30 feet high? Is the pole radiating any RF outside the 3 meter antenna? Would an FCC inspector disaprove this installation? Should I have this installation inspected prior to operating if all the Part15 rules are adhered to, ie. no interference, no harmonics, no complaints from neighbors or licensed broadcasters? I have pasted the Part15.219 rule for antenna and power requirement for reference.
Thank you.
PART 15--RADIO FREQUENCY DEVICES--Table of Contents Subpart C--Intentional Radiators Sec. 15.219 Operation in the band 510-1705 kHz. (a) The total input power to the final radio frequency stage (exclusive of filament or heater power) shall not exceed 100 milliwatts. (b) The total length of the transmission line, antenna and ground lead (if used) shall not exceed 3 meters. (c) All emissions below 510 kHz or above 1705 kHz shall be attenuated at least 20 dB below the level of the unmodulated carrier. Determination of compliance with the 20 dB attenuation specification may be based on measurements at the intentional radiator''s antenna output terminal unless the intentional radiator uses a permanently attached antenna, in which case compliance shall be deomonstrated by measuring the radiated emissions.
Response:
1) No, but connecting the ground lead to a 30 feet metal pole is a violation.
2) The pole can not radiate at all.
3) Yes, this transmitter will not be approve by an FCC inspector.
4) You may not install this transmitter as describe."
I then posed this question regarding some installations as seen on various websites and discussions here on this board and others, again the FCC believes it does not meet the rule if done as described or similar and having a certified transmitter or not doesn't make a difference according to them, of course each
FCC field office will respond differently.
"----- Original Message -----
From: Generic Office of Engineering Technology
To: [email protected]
Sent: Monday, January 09, 2006 2:50 PM
Subject: Response to Inquiry to FCC (Tracking Number 670631)
---Reply from Customer on 01/09/2006---
These installations are currently being approved by field agents and the transmitter manufacturers is advising to install these AM transmitter in this fashion and have been operating for years in this manner. Please see the attached website for the manufacturer as reference and please indicate why my installation would be any different?
I believed that the 3 meter antenna/ground rule was only to the attach point of the 'true ground' and clipping the 3 inch ground lead to a pipe, ground rod, heavy gauge wire to ground rod, or metal pole was sufficient as the AM transmitter needs the ground to complete the circuit? Thank you.
Response:
This is not legal per Section 15.219(b). We can not approve this installation as
you describe. Please contact FCC Enforcement Bureau (EB) if you have any additional
questions. The website for (EB) is: http://www.fcc.gov/eb/
______________________________________________________________________
1) No, but connecting the ground lead to a 30 feet metal pole is a violation.
2) The pole can not radiate at all.
3) Yes, this transmitter will not be approve by an FCC inspector.
4) You may not install this transmitter as describe.
Do not reply to this message. Please select the Reply to an Inquiry Response link from the OET Inquiry System to add any additional information pertaining to this inquiry."
Please, let's be civil regarding this, I didn't want to post this, but thought I'd be helping my fellow part15 broadcasters avoid any issues with the FCC....
Thanks,
Radiopilot
"----- Original Message -----
From: Generic Office of Engineering Technology
To: [email protected]
Sent: Monday, January 09, 2006 1:22 PM
Subject: Response to Inquiry to FCC (Tracking Number 670631)
Inquiry:
I have a Part15 compliant AM transmitter to the Part15.219 rule... The transmitter is 30 feet high mounted on a metal pole, the 3 meter total antenna including 3 inches of ground lead is attached to the metal pole (30 feet long) mounted to the ground (elevated ground), attached to the pole is 64 radials, each radial 25 feet long in a spiral from the pole... the input to the transmitter is 100mw... is this legal in the FCC rules? Am I violating any Part15 rule by mounting the transmitter 30 feet high? Is the pole radiating any RF outside the 3 meter antenna? Would an FCC inspector disaprove this installation? Should I have this installation inspected prior to operating if all the Part15 rules are adhered to, ie. no interference, no harmonics, no complaints from neighbors or licensed broadcasters? I have pasted the Part15.219 rule for antenna and power requirement for reference.
Thank you.
PART 15--RADIO FREQUENCY DEVICES--Table of Contents Subpart C--Intentional Radiators Sec. 15.219 Operation in the band 510-1705 kHz. (a) The total input power to the final radio frequency stage (exclusive of filament or heater power) shall not exceed 100 milliwatts. (b) The total length of the transmission line, antenna and ground lead (if used) shall not exceed 3 meters. (c) All emissions below 510 kHz or above 1705 kHz shall be attenuated at least 20 dB below the level of the unmodulated carrier. Determination of compliance with the 20 dB attenuation specification may be based on measurements at the intentional radiator''s antenna output terminal unless the intentional radiator uses a permanently attached antenna, in which case compliance shall be deomonstrated by measuring the radiated emissions.
Response:
1) No, but connecting the ground lead to a 30 feet metal pole is a violation.
2) The pole can not radiate at all.
3) Yes, this transmitter will not be approve by an FCC inspector.
4) You may not install this transmitter as describe."
I then posed this question regarding some installations as seen on various websites and discussions here on this board and others, again the FCC believes it does not meet the rule if done as described or similar and having a certified transmitter or not doesn't make a difference according to them, of course each
FCC field office will respond differently.
"----- Original Message -----
From: Generic Office of Engineering Technology
To: [email protected]
Sent: Monday, January 09, 2006 2:50 PM
Subject: Response to Inquiry to FCC (Tracking Number 670631)
---Reply from Customer on 01/09/2006---
These installations are currently being approved by field agents and the transmitter manufacturers is advising to install these AM transmitter in this fashion and have been operating for years in this manner. Please see the attached website for the manufacturer as reference and please indicate why my installation would be any different?
I believed that the 3 meter antenna/ground rule was only to the attach point of the 'true ground' and clipping the 3 inch ground lead to a pipe, ground rod, heavy gauge wire to ground rod, or metal pole was sufficient as the AM transmitter needs the ground to complete the circuit? Thank you.
Response:
This is not legal per Section 15.219(b). We can not approve this installation as
you describe. Please contact FCC Enforcement Bureau (EB) if you have any additional
questions. The website for (EB) is: http://www.fcc.gov/eb/
______________________________________________________________________
1) No, but connecting the ground lead to a 30 feet metal pole is a violation.
2) The pole can not radiate at all.
3) Yes, this transmitter will not be approve by an FCC inspector.
4) You may not install this transmitter as describe.
Do not reply to this message. Please select the Reply to an Inquiry Response link from the OET Inquiry System to add any additional information pertaining to this inquiry."
Please, let's be civil regarding this, I didn't want to post this, but thought I'd be helping my fellow part15 broadcasters avoid any issues with the FCC....
Thanks,
Radiopilot