New Part 15 Florida

[Whiplash]

www.flaglerbeachradio.com

 

[Desert Ear]

Very good web site.
Is your antenna by the water or inland?
It would be cool to show your coverage contour on your web site.

DE

 

[Whiplash]

Antenna is on the famous Flagler Beach Pier and ground rods go into the ocean under the pier.

 

[Desert Ear]

Excellent!

We're in the desert. No water or earth (just rocks) or tall buildings, but our Rangemaster easily gets out a mile in all directions.

 

[Nostalgia]

Antenna is on the famous Flagler Beach Pier and ground rods go into the ocean under the pier.

Hello, my name is Frank Charley, middle initial C. I would like to hear more about your ground rods going down to the ocean. The pier looked a little taller than 3 meters. ;D ;D ;D

Sounds good Chris, have fun with it!

 

[Whiplash]

They are that tall. And I have to say it hasn't made much of a difference. We're getting the usual mile out of the transmitter.

 

[Chad-Stevens]

Sounds great! Is the same personnel that was involved with WFBO-LP "The Blizzard" involved with Surf 1700. I loved the Blizzard and made several web-airchecks of it back in '05-'06.

 

[Ermi Roos]

I looked up some enforcement actions issued to stations in Flagler Beach, FL, and they were issued by the FCC's Tampa Office. Being under the juristiction of the Tampa Office is not a bad thing for Part 15 stations. The Tampa officials have a reputation for very light enforcement of the Part 15 rules.

 

[Whiplash]

There are some folks that were an on air part of the former WFBO. But no one involved that broke the rules.

 

[Ermi Roos]

There are some folks that were an on air part of the former WFBO. But no one involved that broke the rules.

I searched for enforcement actions on the FCC website for Flagler Beach, FL merely to find out which FCC office is responsible for the area. Flagler Beach is quite a long distance from Tampa, being on the Atlantic coast, while Tampa is on the Gulf coast, but the Tampa office is nevertheless in charge at Flagler Beach.

Yes, WFBO-LP was the object of the enforcement actions that I found, but, like any other FCC office, Tampa cites licensed stations if they violate the rules, and they also put high-powered unlicensed stations out of business.

They do seem to be tolerant of nearly-Part 15 micropowered stations that are bending the rules only somewhat, however. For example, a Tampa District Director gave an interview for a youth-operated FM station that very likely was not compliant with Section 15.239. A Tampa-based FCC agent has been quoted as not being concerned with operation on 1710 kHz, although that is above the frequency range allowed by Section 15.219. Also, a list of unlicensed FM stations within the juristiction of the Tampa office, very likely violating Section 15.239, which have been operated by police agencies and drive-in theaters, has been posted on another website.

I don't know how Tampa deals with the "ground lead" issue, but in view of their behavior so far, my guess is that they will simply ignore it.

 

[druidhillsradio]

There are some folks that were an on air part of the former WFBO. But no one involved that broke the rules.

They do seem to be tolerant of nearly-Part 15 micropowered stations that are bending the rules only somewhat, however. For example, a Tampa District Director gave an interview for a youth-operated FM station that very likely was not compliant with Section 15.239.

Ermi, if you listen to the interview Ralph Barlow clearly states that the station had it's signal measured, adjusted and was compliant.

 

[Ermi Roos]

There are some folks that were an on air part of the former WFBO. But no one involved that broke the rules.

They do seem to be tolerant of nearly-Part 15 micropowered stations that are bending the rules only somewhat, however. For example, a Tampa District Director gave an interview for a youth-operated FM station that very likely was not compliant with Section 15.239.

Ermi, if you listen to the interview Ralph Barlow clearly states that the station had it's signal measured, adjusted and was compliant.

John,

You know much more about the technical details of the station in question than I do. Nevertheless, if it was actually compliant with 15.239, that was only because Mr. Barlow used (or perhaps abused) his authority to DEEM it to be so. The field strength limit of 15.239 restricts range so much that meaningful broadcasting is not likely. If compliant (which I don't believe), Mr. Barlow gave his interview to zero audience.

 

[RadioMan203]

John,

You know much more about the technical details of the station in question than I do. Nevertheless, if it was actually compliant with 15.239, that was only because Mr. Barlow used (or perhaps abused) his authority to DEEM it to be so. The field strength limit of 15.239 restricts range so much that meaningful broadcasting is not likely. If compliant (which I don't believe), Mr. Barlow gave his interview to zero audience.

Correction: that would be zero radio audience. I believe they have an online stream where it would have been heard.

 

[Ermi Roos]

Correction: that would be zero radio audience. I believe they have an online stream where it would have been heard.

Reply by Ermi Roos:


While the station's website claims a wordwide audience via streaming, they also claim a 25 mW transmitter operating on 96.7 MHz in Clearwater, FL, 30-foot antenna height, and a 1-mile coverage radius. 25 milliwatts may not sound like much, but even one MICROWATT of radiated power is enough to greatly exceed the field stength limit of 15.239. A one-mile range is something that legal users of Part 15 FM can only dream about. A couple of hundred feet, or so, is more like the outer limit of a compliant Part 15 FM station.

I can appreciate Mr. Barlow supporting a good a cause, which, in this case, is getting young people to appreciate a wholesome activity like radio broadcasting. I've been a church youth group and scouting leader myself, and have taught ham radio license preparation classes to boys. So, I appreciate such sentiments. If, as I believe, however, a government offical has been giving a group he supports a leg up over others, I consider that to be highly unethical.

 

[druidhillsradio]

Correction: that would be zero radio audience. I believe they have an online stream where it would have been heard.

Reply by Ermi Roos:


While the station's website claims a wordwide audience via streaming, they also claim a 25 mW transmitter operating on 96.7 MHz in Clearwater, FL, 30-foot antenna height, and a 1-mile coverage radius. 25 milliwatts may not sound like much, but even one MICROWATT of radiated power is enough to greatly exceed the field stength limit of 15.239. A one-mile range is something that legal users of Part 15 FM can only dream about. A couple of hundred feet, or so, is more like the outer limit of a compliant Part 15 FM station.

I can appreciate Mr. Barlow supporting a good a cause, which, in this case, is getting young people to appreciate a wholesome activity like radio broadcasting. I've been a church youth group and scouting leader myself, and have taught ham radio license preparation classes to boys. So, I appreciate such sentiments. If, as I believe, however, a government offical has been giving a group he supports a leg up over others, I consider that to be highly unethical.

@Ermi, to me having Ralph give good advise on making a FM Part 15 legal is no different than a FCC Field agent diplomatically point out whay one could do to make his Part 15 AM compliant. Just say'in.

 

[Ermi Roos]

In addition to what it says on the station website, a web search indicates that WKID used a Ramsey FM30 transmitter, and a Comet antenna of unspecified model. A driver in Clearwater checking the range of the station with his car radio reported that the range observed was just 20% shy of the 1-mile claimed on the website. These observations were posted some time after the interview with Ralph, and they do not describe a compliant Part 15 FM station.

As a rough guess using the data available, the field strenth would have been more in the vicinity of 5000 uV/m at 3 m rather than the 250 uV/m at 3 m limit of 15.239. NOUOs have been issued for that much field strength, and less.

 

[Ermi Roos]

The lowest field strength I have seen recorded in an FM NOUO is 1381 uV/m at 3 meters on 107.7 MHz, issued to Morris Hanson of Milbank, SD on August 25, 2010. This very low field strength might have passed in Canada, where 1000 uV/m at 3 meters is allowed in their equivalent to 15.239. 1381 uV/m might have been seen as being too close to the limit in Canada to be certain that a violation had actually taken place. The corresponding radiated power is a lot less than a microwatt! Just how little RF power is allowed by 15.239 boggles the mind.

The point is that while one station was given a pass because it happened to be run by children, but other operators have unfairly received NOUOs for similar, or even lesser, offenses. I think that the rules should be the same for everybody. That is only fair.

I think that the present rules are too restrictive, and they should be loosened to allow more range for everybody; but there should not be preferential treatment for some. That simply is not just.

 

[druidhillsradio]

@Ermi: I cannot prove, but I have "heard" if you know what I mean, because of the normalized rules between Industry Canada and the FCC, the actual break point is 1000uV at 3 meters.

 

[Ermi Roos]

There are even some small differences between US and Canadian rules in the case of what is called Part 15 AM (15.219) here. For FM, the stated field strength limit in Canada is four times higher than in the US. There are certainly similarities of the unlicensed broadcasting rules in the two countries, but I am not sure what "normalization" of the rules means.

It would not surprise me if US agents are directed not to cite for field strengths lower than 1000 uV/m at 3 m. Such an allowance would account for imperfect measurements caused by reflections and other terrain effects. I have referred to an NOUO for a field strength of only 1381 uV at 3 meters in this thread. Canadian agents should allow a higher field strength than that in order to be sure that the measured field strength actually shows a violation of their rules.

Since you are an EMC engineer, John, you would be very familiar with standardized tests, test specs, and test ranges.

 

[rfry]

... It would not surprise me if US agents are directed not to cite for field strengths lower than 1000 uV/m at 3 m. Such an allowance would account for imperfect measurements caused by reflections and other terrain effects.

Field strengths produced by a "Part 15 FM" transmit system based on measurements made considerably further than 3 m away from the transmit antenna cannot be extrapolated to the true value of the peak field existing 3 m away from such a transmit system -- accurate as those distant measurements may be for the fields existing at those locations beyond 3 m.

In such cases and depending on path geometries, reflections/obstructions/terrain effects for those distances can produce a REDUCTION in received fields, rather than their improvement over the theoretical fields for free-space, unobstructed paths.

A single, in-phase reflection arriving at the receive antenna from a surface having a reflection coefficient of 100% improves the free-space field there by about 6 dB.

Such a reflection received 180 degrees out of phase from the free-space field (due to path geometries) completely cancels that free space field.