Part 15 Short Wave broadcasting?

[JasonW]

Hello All,

I've read about Part 15 Long Wave broadcasting using a 1 watt transmitter and a 15 meter antenna, which is electrically *tiny* and very, very inefficient at 160 kHz - 190 kHz. This is almost exclusively the province of LowFER beacon operators who transmit slow morse code or digitally-coded signals, although one LowFER in California does broadcast music on Long Wave in AM mode.

Has anyone ever done limited-area Short Wave broadcasting at Part 15 power levels? For frequencies from 1.705 MHz - 30 MHz, the rules (see Part 15.209 at www.arrl.org/tis/info/part15.html ) allow a field strength of 30 microvolts per meter, measured at a distance of 30 meters from the antenna. While this doesn't permit using much power to the antenna, it *does* allow using an efficient full-size, self-resonant antenna and counterpoise.

For local Short Wave broadcasting, a 1/4 wavelength or 1/2 wavelength vertical antenna over a set of 1/4 wavelength radials should work best and would be of a manageable size. For the lower Short Wave frequencies, a shorter top-loaded Marconi "Tee" antenna over radials would work well. Because the limits apply only to the field strength and not the transmitter output power, one could use a low-power Short Wave transmitter kit or even a ham transmitter (with a resistor attenuator pad to limit the power into the antenna).

While Short Wave receivers aren't as common in the US as AM/FM receivers, they aren't exactly rare either. Many of them also come with wire reel antennas, which would allow listeners to receive Part 15 Short Wave stations from farther away than Part 15 Medium Wave (AM) stations. -- JasonW

 

[radio8z]

Helo Jason,

The lowest frequency I have every transmitted on is 1320 KHz., so I have no transmitting experience to offer about VLF.

At the risk of kicking off a storm of opinions (don't discuss politics, religion, or part 15 rules), I offer the following:

Part 15.209 sets the field strength limits for intentional radiators, but does not limit antenna length or power.

Part 15.219 limits antenna length and power.

BUT

Part 15.215 (a) offers alternatives to Part 15.209, which includes 15.215 so field strength measurements are not needed.

So, I conclude that you can use either 15.209 or 15.219 to be in compliance. In fact, the old part 15 rules from years ago preambled the power and antenna limit section with "In lieu of meeting the requirements of ... field strength limits..." Apparently it was rewritten and section 15.215 (a) was revised to cover this.

It appears that you can use any power and antenna you want as long as 15.209 limits are met, including a long antenna in the AM BC band. Of course, one would have to have a good measure of the field strength, which most of us cannot do accurately.

I am not going to do this. I don't want the FCC to make the measurements for me. However, it may open the door for others to experiment.

I suspect that considering modern efficient transmitters and legal antennas that we get field strengths that exceed 15.209 limits, but 15.215 and 219 save us.

Though I have not transmitted on VLF, my receiver (Yeasu FRG-100B) will tune it. At my location the band from 160 to 190 is very noisy (man/woman made interference from electrical devices) and my dipole, cut for 3 MHz. and above, is not at all efficient for VLF reception. The big plus is that the band has almost no signals and is not crowded. Maybe someone experienced with VLF can comment on using this band as a STL for remote or multiple transmitters.

Regards,

Neil

 

[JasonW]

Neil, I shouldn't have included the first paragraph about Long Wave (I just had it there as an example of what some others have done--the noise level is indeed *very* high "down there").

I was asking about Part 15 Short Wave broadcasting. The 41 meter through 13 meter Short Wave broadcast bands seem pretty low-noise, at least here in Alaska, and the per-capita ownership of Short Wave receivers is high here (the owner of our local Radio Shack stores, who's a ham, sells them constantly).

What you wrote about the Part 15.215 and 15.209 rules sections is intriguing. It sounds like I might be able to legally operate on Short Wave at low power without measuring the field strength, as long as I used a certain antenna length and transmitter output power (as with Part 15 AM). -- JasonW

> Helo Jason,
>
> The lowest frequency I have every transmitted on is 1320
> KHz., so I have no transmitting experience to offer about
> VLF.
>
> At the risk of kicking off a storm of opinions (don't
> discuss politics, religion, or part 15 rules), I offer the
> following:
>
> Part 15.209 sets the field strength limits for intentional
> radiators, but does not limit antenna length or power.
>
> Part 15.219 limits antenna length and power.
>
> BUT
>
> Part 15.215 (a) offers alternatives to Part 15.209, which
> includes 15.215 so field strength measurements are not
> needed.
>
> So, I conclude that you can use either 15.209 or 15.219 to
> be in compliance. In fact, the old part 15 rules from years
> ago preambled the power and antenna limit section with "In
> lieu of meeting the requirements of ... field strength
> limits..." Apparently it was rewritten and section 15.215
> (a) was revised to cover this.
>
> It appears that you can use any power and antenna you want
> as long as 15.209 limits are met, including a long antenna
> in the AM BC band. Of course, one would have to have a good
> measure of the field strength, which most of us cannot do
> accurately.
>
> I am not going to do this. I don't want the FCC to make the
> measurements for me. However, it may open the door for
> others to experiment.
>
> I suspect that considering modern efficient transmitters and
> legal antennas that we get field strengths that exceed
> 15.209 limits, but 15.215 and 219 save us.
>
> Though I have not transmitted on VLF, my receiver (Yeasu
> FRG-100B) will tune it. At my location the band from 160 to
> 190 is very noisy (man/woman made interference from
> electrical devices) and my dipole, cut for 3 MHz. and above,
> is not at all efficient for VLF reception. The big plus is
> that the band has almost no signals and is not crowded.
> Maybe someone experienced with VLF can comment on using this
> band as a STL for remote or multiple transmitters.
>
> Regards,
>
> Neil
>

 

[radio8z]

Hello again,

I really don't remember what the rules say about HF operation. You certainly can check. My work with HF, 80 meters and lower wavelength, has been really fun, but we depend on skywave, not groundwave. I know first hand of instances where I was running 280 watts PEP on 80, 40, 15, and 10 meters and could not be heard by my local friends twenty miles away. Meanwhile I was working Poland, a ship in the Atlantic, and many stations in the western US.

We had a local net and we ran 10 meters after sundown when the band was closed. We could barely hear each other 10 miles separated. I lived seven miles from the Bethany Relay Station north of Cincinnati, and though at the time they were running 50 plus KW. I found their signal at my home to be very weak. Might have been antenna patterns. WLW, also seven miles away, but on 700 KHz., 50KW screwed up every measurement I tried to make with my scope.

Even CB, on a quiet night and with 5 watts input, gets out only a few miles groundwave.

This is not to discourge you or anyone from trying, but just to point out that the long distances "shortwave" achieves is not the same as trying to cover a local community. The ground losses at HF are high and this is probably why it is so ineffective for local communication.

Neil

 

[rfry]

> I suspect that considering modern efficient transmitters and
> legal antennas that we get field strengths that exceed
> 15.209 limits, but 15.215 and 219 save us.
_______________

Probably not. Below is a clip from an October 2005 FCC Notice showing that field strength in the AM broadcast band cannot exceed the quoted limit, no matter what tx and antenna are used.

QUOTE
Radio stations must be licensed by the FCC pursuant to 47 U.S.C.
§ 301. The only exception to this licensing requirement is for
certain transmitters using or operating at a power level or mode
of operation that complies with the standards established in Part
15 of the Commission's rules, 47 C.F.R. §§ 15.1 et seq. The
field strength of the signal on frequency 1620 kHz was measured
at 440,000 µV/m at 53 meters at [omitted] Street and 400,000 µV/m
at 25 meters at [omitted]Street, both of which exceeded the
maximum permitted level of 14.8 microvolts per meter (µV/m)
at 30 meters for non-licensed devices. Thus, these stations
are operating in violation of 47 U.S.C. § 301.

You are hereby warned that operation of radio transmitting
equipment without a valid radio station authorization constitutes
a violation of the Federal laws cited above and could subject the
operator to severe penalties, including, but not limited to,
substantial monetary fines, in rem arrest action against the
offending radio equipment, and criminal sanctions including
imprisonment. (see 47 U.S.C. §§ 401, 501, 503 and 510).

UNLICENSED OPERATION OF THIS RADIO STATION
MUST BE DISCONTINUED IMMEDIATELY.

//

 

[rfry]

> Has anyone ever done limited-area Short Wave broadcasting at
> Part 15 power levels? For frequencies from 1.705 MHz - 30
> MHz, the rules (see Part 15.209 at
> www.arrl.org/tis/info/part15.html ) allow a field strength
> of 30 microvolts per meter, measured at a distance of 30
> meters from the antenna. While this doesn't permit using
> much power to the antenna, it *does* allow using an
> efficient full-size, self-resonant antenna and counterpoise.
_____________

Unfortunately, the laws of physics are working against you here. Groundwave propagation losses rise quickly with frequency. So even though the 30 uV/m at 30 meter permitted field strength can be produced at shortwave freqs easily by efficient antenna systems and low tx powers, much more signal strength is lost as it propagates beyond that point than for freqs in the AM broadcast band.

Also those shortwave freqs are subject to a lot of interference (day and night) by other signals arriving by skywave propagation from txs hundreds or thousands of miles away.
//

 

[WCWalker]

***Unless the rules have suddenly changed it is my understanding that ONLY AM Carrier Current stations must comply with Field Strength limits while intentional radiators such as the Rangemaster, Infomax or Trans AM 100 must adhere to rule 15.219. This rule was changed in, I believe 1989.

Quite probably this is another rogue field office attempting to create the rules as opposed to enforcing them. A few years ago I had an incident with the Field Office in Kansas City that relates directly to this issue.

I was running a Trans AM 100 and the FCC showed up to inspect the station. They claimed I was exceeding the allowable power and range for a part 15 station on AM and requested that I turn the transmitter off. What was particularly laughable was that when I adjusted the power level of the transmitter down to ZERO, the engineer with the Field Strength gear claimed I was STILL running way too much power and must shut down.

I told them I had someplace to go (and I did) and I shut the station down. I then told them I would make a few calls and that they would be hearing from someone about this issue. I proceeded to call some friends with contacts in Washington, who in turn called the FCC in KC to set them straight. A few hours after this incident I received a call from the Supervisor at the KC Field Office claiming they were ignorant of the rules and they did not know the transmitter and this kind of broadcasting is now legal. I then resumed broadcasting and the issue was solved.

Nobody at the FCC in DC seems to believe the Field Strength rule applies to transmitters like the Rangemaster and they informed the KC Field Office of this fact. Clearly, the FCC engineer that was using the Field Strength gear did not know how to use it properly otherwise he would have found my station to be in compliance. Or...If he did know how to use it he was deliberately lying to me when he said my station was over power despite the fact the power level was set to ZERO!

I should also add that ANY Field Strength reading of a very low power AM station in the field is not likely to be even close to accurate. The FCC conceded this fact to a friend of mine and this appears to be one of the reasons why the rule was changed back in 1989. My experience proves it. Technically, the FCC is supposed to a the transmitter to an Official FCC Lab and then bench test it for Field Strength. This is especially true of anyone running a Part 15 FM station that appears to be in question.

Mr. Fry this is quite simple. What the FCC in DC says trumps what the local Field Office has to say on this subject.



> > I suspect that considering modern efficient transmitters
> and
> > legal antennas that we get field strengths that exceed
> > 15.209 limits, but 15.215 and 219 save us.
> _______________
>
> Probably not. Below is a clip from an October 2005 FCC
> Notice showing that field strength in the AM broadcast band
> cannot exceed the quoted limit, no matter what tx and
> antenna are used.
>
> QUOTE
> Radio stations must be licensed by the FCC pursuant to 47
> U.S.C.
> § 301. The only exception to this licensing requirement is
> for
> certain transmitters using or operating at a power level or
> mode
> of operation that complies with the standards established in
> Part
> 15 of the Commission's rules, 47 C.F.R. §§ 15.1 et seq.
> The
> field strength of the signal on frequency 1620 kHz was
> measured
> at 440,000 µV/m at 53 meters at [omitted] Street and 400,000
> µV/m
> at 25 meters at [omitted]Street, both of which exceeded the
>
> maximum permitted level of 14.8 microvolts per meter (µV/m)
> at 30 meters for non-licensed devices. Thus, these stations
>
> are operating in violation of 47 U.S.C. § 301.
>
> You are hereby warned that operation of radio transmitting
> equipment without a valid radio station authorization
> constitutes
> a violation of the Federal laws cited above and could
> subject the
> operator to severe penalties, including, but not limited to,
>
> substantial monetary fines, in rem arrest action against the
>
> offending radio equipment, and criminal sanctions including
>
> imprisonment. (see 47 U.S.C. §§ 401, 501, 503 and 510).
>
> UNLICENSED OPERATION OF THIS RADIO STATION
> MUST BE DISCONTINUED IMMEDIATELY.
>
> //
>

 

[KeithHamilton]

15.219 is only for the AM band, it allows for 100mw and a 3 meter radiator.

Section 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 demonstrated by
measuring the radiated emissions.

 

[rfry]

> ***Unless the rules have suddenly changed it is my
> understanding that ONLY AM Carrier Current stations must
> comply with Field Strength limits while intentional
> radiators such as the Rangemaster, Infomax or Trans AM 100
> must adhere to rule 15.219. This rule was changed in,
> I believe 1989.

Understandings and beliefs are fine if they agree with FCC Rules. But the tendency is to understand and believe those ideas that best support positions desired by their holder(s).

In this case (and others), the FCC is quoting specific texts in 47 CFR relating to the operation of unlicensed transmitters in the broadcast band. What is the basis to say they are wrong? You would have to prove them wrong by paying for your own measurements showing that you are compliant to the Rules they referenced, while using the same equipment and operating parameters as when you were cited.

> Nobody at the FCC in DC seems to believe the Field Strength
> rule applies to transmitters like the Rangemaster and they
> informed the KC Field Office of this fact.

Not according to the 47 CFR texts in the Notice clip I posted.

> I should also add that ANY Field Strength reading of a very
> low power AM station in the field is not likely to be even
> close to accurate.

This is absolute fiction. Professional field strength meters such as the Potomac Instruments FIM-41 and numerous other signal analyzers give accurate field strength readings (within a few dB) down to 5 microvolts/meter, or less. This is far below the groundwave field strength that can be produced even 500 feet away from a Part 15 AM system operating with 100 mW input power and a ground-mounted vertical that is 3 meters long (including feeder and ground connection path).

> Technically, the FCC is supposed to a the transmitter to an
> Official FCC Lab and then bench test it for Field Strength.
> This is especially true of anyone running a Part 15 FM
> station that appears to be in question.

Please explain how that can be done when the antenna is rarely supplied by the manufacturer of the Part 15 AM transmitter. Part 15 AM-ers supply their own antenna, and the radiation efficiency of the antenna system actually used can make a huge difference in the field strength produced by the station -- especially considering the understandings, beliefs, and "war stories" so common here on this subject.
//

 

[WCWalker]

> > ***Unless the rules have suddenly changed it is my
> > understanding that ONLY AM Carrier Current stations must
> > comply with Field Strength limits while intentional
> > radiators such as the Rangemaster, Infomax or Trans AM 100
>
> > must adhere to rule 15.219. This rule was changed in,
> > I believe 1989.
>
> Understandings and beliefs are fine if they agree with FCC
> Rules. But the tendency is to understand and believe those
> ideas that best support positions desired by their
> holder(s).

$$$$$ Well, my understandings are based upon my DIRECT dealings with the FCC and that of friends or people in the business. I'm not all that sure that yours are actually up to date. Times change...


>
> In this case (and others), the FCC is quoting specific texts
> in 47 CFR relating to the operation of unlicensed
> transmitters in the broadcast band. What is the basis to
> say they are wrong? You would have to prove them wrong by
> paying for your own measurements showing that you are
> compliant to the Rules they referenced, while using the same
> equipment and operating parameters as when you were cited.

$$$$$ Based upon what I read this appears to be a portion of a NAL to a station. Why don't you provide a direct link or print the entire piece and not just a portion or a clip. This indicates it came from a Field Office and quite likely they are not fully understanding the rules. In that case they should speak either to John Reed or Raymond LaForge in DC.

Also, if you can find a part in the rules that states "Part 15 AM intentional radiators must meet both Field Strength and part 15.219 rules" it would help to lend creedence to your opinion. Right now it is just that, your opinion and not supported by fact or a specific FCC rule.

>
> > Nobody at the FCC in DC seems to believe the Field
> Strength
> > rule applies to transmitters like the Rangemaster and they
>
> > informed the KC Field Office of this fact.
>
> Not according to the 47 CFR texts in the Notice clip I
> posted.

$$$$$ Well, what you posted directly CONTRADICTS what I and others have been told by the FCC in DC.


>
> > I should also add that ANY Field Strength reading of a
> very
> > low power AM station in the field is not likely to be even
>
> > close to accurate.
>
> This is absolute fiction. Professional field strength
> meters such as the Potomac Instruments FIM-41 and numerous
> other signal analyzers give accurate field strength readings
> (within a few dB) down to 5 microvolts/meter, or less. This
> is far below the groundwave field strength that can be
> produced even 500 feet away from a Part 15 AM system
> operating with 100 mW input power and a ground-mounted
> vertical that is 3 meters long (including feeder and ground
> connection path).

$$$$$ If this is absolute fiction, then why did the FCC Field Office Engineer claim my signal was OVERPOWER even when it was set to ZERO and I could not even HEAR my station on my radio inside my home?

And more importantly, why was a friend of mine (GM of a 5kw licensed AM outlet) told by an FCC Supervisor that they were not able to accurately read very low power AM signals with their equipment?

I smell a BIG FAT COMMIE RAT.


>
> > Technically, the FCC is supposed to a the transmitter to
> an
> > Official FCC Lab and then bench test it for Field
> Strength.
> > This is especially true of anyone running a Part 15 FM
> > station that appears to be in question.
>
> Please explain how that can be done when the antenna is
> rarely supplied by the manufacturer of the Part 15 AM
> transmitter. Part 15 AM-ers supply their own antenna, and
> the radiation efficiency of the antenna system actually used
> can make a huge difference in the field strength produced by
> the station -- especially considering the understandings,
> beliefs, and "war stories" so common here on this subject.

$$$$$ An intelligent guy like yourself should be able to figure this out. Technically you are supposed to use a FCC Type Accepted transmitter or home brew gear. Kits really are not truly legal despite the claims of so many on this board. In my case, once the FCC in KC learned about the Certification of my unit they suddenly realized THEY were in error and I resumed broadcasting. Naturally the FCC in DC played a vital role in my being able to return to the air, free from FCC Field Office interference.

Type Accepted Transmitters usually do come with a supplied antenna. While we usually don't ship antennas with the Rangemaster anymore, they are still available upon requiest, the last I knew.

Perhaps you are referring to the countless owners and users of "kit" type transmitters. In that case you are correct with your statement that they all use a variety of different antennas. But in reality, contrary to the belief of many on this board, kits really are not legal unless they are FCC Type Certified.

Now for a personal observation about you Mr. Fry:

You are coming off as an arrogant,know it all, NAB sympathizer. I too have had more than my share of trouble with many of the participants on this board in the last few years. Some are egomaniacs or gossip mongers and others are ill informed about the facts as they pertain to part 15 AM. Still others are pathological liars and many more are just plain ignorant of community radio in general. You've taken your fair share of crap from some of these people and it is certainly not warranted because you are simply trying to convey a message that contradicts that of their own opinions. At least you are polite and don't get snotty or hostile like some of them.

Times and rules change and so does the interpretation of the rules and that seems to be the case. A perfect analogy would be the Constution! I too am a bit of an anachronism at times when it comes to aspects of my personal life but I do stay on top of the latest news, trends and changes to the part 15 AM industry and FCC rules changes or interpretations.

The FCC is overworked and undermanned. They have their hands full at keeping the licensed stations and FM pirates in check. They don't have the time, money or manpower to deal with EVERY little part 15 AM station in existence. If someone claims to be a part 15 AM station but runs 20 watts then yes, the FCC is likely to do something about it.

My best guess is that the FCC realizes they would have an even bigger FM Pirate problem if they didn't cut part 15 broadcasters a little slack. Smart move on their part because it keeps their work load to a minimum.

You could better serve the public and community radio in general by policing the licensed stations that violate rules. Let's face it, they have more rules to comply with than we do therefore they break a lot more rules than we do.

 

[rfry]

> Also, if you can find a part in the rules that states "Part
> 15 AM intentional radiators must meet both Field Strength
> and part 15.219 rules" it would help to lend creedence to
> your opinion. Right now it is just that, your opinion and
> not supported by fact or a specific FCC rule.

Yet the FCC used excess field strength to issue the Notice clip I posted, and cited their basis in the Rules for doing that.

> > This is absolute fiction. Professional field strength
> > meters such as the Potomac Instruments FIM-41 and numerous
> > other signal analyzers give accurate field strength
> >readings (within a few dB) down to 5 microvolts/meter,
> > or less.

> $$$$$ If this is absolute fiction, then why did the FCC
> Field Office Engineer claim my signal was OVERPOWER even
> when it was set to ZERO and I could not even HEAR my station
> on my radio inside my home?
>
> And more importantly, why was a friend of mine (GM of a 5kw
> licensed AM outlet) told by an FCC Supervisor that they were
> not able to accurately read very low power AM signals with
> their equipment?
>
> I smell a BIG FAT COMMIE RAT.

Such statements are not useful to anyone receiving an FCC citation when they prove to be untrue. And in the meantime they could lead people into courses of action that expose them to the risk of FCC actions.

> Kits really are not truly legal despite the claims of so
> many on this board.

On what basis do you write that? Can't anyone build a tx, or assemble a kit and use it under Part 15 legally on the air as long as they, or the kit manufacturer certified that the installation meets Part 15? Of course, that takes a lot of test equipment and skills that the average, non-commercial Part 15 operator doesn't have.

> In my case, once the FCC in KC learned about the
> Certification of my unit they suddenly realized THEY were in
> error and I resumed broadcasting.

Using a certified transmitter doesn't mean that a Part 15 AM system meets all Part 15 Rules, unless the transmitter was certified with the antenna that is in use, and the tx and antenna system are unmodified.

> Now for a personal observation about you Mr. Fry:
> You are coming off as an arrogant,know it all, NAB sympathizer. (etc)

To you and some, I guess. But I'm content to make my posts in what I believe is a professional manner, and let the chips fall where they may.
//

 

[WCWalker]

> > Also, if you can find a part in the rules that states
> "Part
> > 15 AM intentional radiators must meet both Field Strength
> > and part 15.219 rules" it would help to lend creedence to
> > your opinion. Right now it is just that, your opinion and
>
> > not supported by fact or a specific FCC rule.
>
> Yet the FCC used excess field strength to issue the Notice
> clip I posted, and cited their basis in the Rules for doing
> that.

***If you were indeed intent on having an honest discussion about this issue you would provide the ENTIRE document for our review. Since you only provide a small clip it is obvious you are not truly interested in seeing the other side of the coin, or the facts. You don't cite a specific source or the location where the entire document may be found.

>
> > > This is absolute fiction. Professional field strength
> > > meters such as the Potomac Instruments FIM-41 and
> numerous
> > > other signal analyzers give accurate field strength
> > >readings (within a few dB) down to 5 microvolts/meter,
> > > or less.
>
> > $$$$$ If this is absolute fiction, then why did the FCC
> > Field Office Engineer claim my signal was OVERPOWER even
> > when it was set to ZERO and I could not even HEAR my
> station
> > on my radio inside my home?
> >
> > And more importantly, why was a friend of mine (GM of a
> 5kw
> > licensed AM outlet) told by an FCC Supervisor that they
> were
> > not able to accurately read very low power AM signals with
>
> > their equipment?
> >
> > I smell a BIG FAT COMMIE RAT.
>
> Such statements are not useful to anyone receiving an FCC
> citation when they prove to be untrue. And in the meantime
> they could lead people into courses of action that expose
> them to the risk of FCC actions.

***Huh? Are you calling me a liar?


>
> > Kits really are not truly legal despite the claims of so
> > many on this board.
>
> On what basis do you write that? Can't anyone build a tx,
> or assemble a kit and use it under Part 15 legally on the
> air as long as they, or the kit manufacturer certified that
> the installation meets Part 15? Of course, that takes a lot
> of test equipment and skills that the average,
> non-commercial Part 15 operator doesn't have.

***According to the rules it appears as though only FCC Type Accepted transmitters and home brew are legal. Read OET 63 from 1996 and it points this out. Also, a recent FCC document that was posted on here not that long ago seems to reinforce this rule.

>
> > In my case, once the FCC in KC learned about the
> > Certification of my unit they suddenly realized THEY were
> in
> > error and I resumed broadcasting.
>
> Using a certified transmitter doesn't mean that a Part 15 AM
> system meets all Part 15 Rules, unless the transmitter was
> certified with the antenna that is in use, and the tx and
> antenna system are unmodified.

***If it contains a CB whip then it is legal. That simple.

>
> > Now for a personal observation about you Mr. Fry:
> > You are coming off as an arrogant,know it all, NAB
> sympathizer. (etc)
>
> To you and some, I guess. But I'm content to make my posts
> in what I believe is a professional manner, and let the
> chips fall where they may.

***In this case it appears to be "let the cowchips fall where they may".

You've deliberately avoided providing us with tangible proof of your claims concerning the alleged field strength requirement for part 15 AM intentional radiators and you refuse to provide access to the entire FCC document that you only posted a small clip from.

You are not interested in honest dialog and only post here to serve some kind of outdated agenda. Worse still, you are too obstinate to even want to concede you may be wrong concerning the corrections I've made to your alleged facts. I don't profess to be an engineer and I have limited technical ability at best. But I know part 15 AM quite well, understand the rules and HOW the FCC currently enforces them and what is considered legal and what is not.


> //
>

 

[suncountry]

Entire Notice Of Unlicensed Operation

http://www.fcc.gov/eb/FieldNotices/2003/DOC-261745A1.html

FEDERAL COMMUNICATIONS COMMISSION

ENFORCEMENT BUREAU
Northeast Region

Boston Office
1 Batterymarch Park
Quincy, MA 02169


10/6/2005


Yvon Grachamps
Mattapan, MA

NOTICE OF UNLICENSED OPERATION

Case Number: EB-04-BS-079
Document Number: W20063226001

The Boston Office received information that an unlicensed
broadcast radio station on 1620 kHz was allegedly operating in
the Boston, Massachusetts area. On August 16, 2005, agents from
this office confirmed by direction finding techniques that radio
signals on frequency 1620 kHz were emanating from transmitter
sites located at 30 Abbott Street, Apt #2, Dorchester, MA and 89
Tremont Street, Everett, MA. The Commission's records show that
no license was issued for operation of a broadcast station on
1620 kHz at either of these locations.

Radio stations must be licensed by the FCC pursuant to 47 U.S.C.
§ 301. The only exception to this licensing requirement is for
certain transmitters using or operating at a power level or mode
of operation that complies with the standards established in Part
15 of the Commission's rules, 47 C.F.R. §§ 15.1 et seq. The
field strength of the signal on frequency 1620 kHz was measured
at 440,000 µV/m at 53 meters at 30 Abbott Street and 400,000 µV/m
at 25 meters at 89 Tremont Street, both of which exceeded the
maximum permitted level of 14.8 microvolts per meter (µV/m) at 30
meters for non-licensed devices. Thus, these stations are
operating in violation of 47 U.S.C. § 301.

You are hereby warned that operation of radio transmitting
equipment without a valid radio station authorization constitutes
a violation of the Federal laws cited above and could subject the
operator to severe penalties, including, but not limited to,
substantial monetary fines, in rem arrest action against the
offending radio equipment, and criminal sanctions including
imprisonment. (see 47 U.S.C. §§ 401, 501, 503 and 510).

UNLICENSED OPERATION OF THIS RADIO STATION MUST BE DISCONTINUED
IMMEDIATELY.

You have ten (10) days from the date of this notice to respond
with any evidence that you have authority to operate granted by
the FCC. Your response should be sent to the address in the
letterhead and reference the listed case and document number.
Under the Privacy Act of 1974, 5 U.S.C. § 552a(e)(3), we are
informing you that the Commission's staff will use all relevant
material information before it to determine what, if any,
enforcement action is required to ensure your compliance with FCC
Rules. This will include any information that you disclose in
your reply.

You may contact this office if you have any questions.



Dennis Loria
District Director
Boston Office





Attachments:
Excerpts from the Communications Act of 1934, As Amended
Enforcement Bureau, "Inspection Fact Sheet", July 2003<P ID="signature">______________
Deano</P>

 

[rfry]

Re: Entire Notice Of Unlicensed Operation

> http://www.fcc.gov/eb/FieldNotices/2003/DOC-261745A1.html
>
> FEDERAL COMMUNICATIONS COMMISSION
>
> ENFORCEMENT BUREAU
> Northeast Region
etc
_________

Yes, that's it. I was trying respect the privacy of the person getting the notice, but it IS in the Public Domain, I know.
//

 

[WCWalker]

Re: Entire Notice Of Unlicensed Operation

***Thanks for posting this Sun Country.

I've heard this station, I believe they were playing some kind of Caribbean music format. I also know they were not using a part 15 AM transmitter for their broadcasts. Based upon the large broadcast radius they had, I would guess they were using a 20 to 30 watt transmitter.

This case ain't relevant to part 15 broadcasters using a part 15 transmitter like the Rangemaster, Infomax or Trans AM 100. You can get a fairly accurate field strength reading of a 10 or 20 watt AM signal but not a tenth of a watt or even a half watt.



> http://www.fcc.gov/eb/FieldNotices/2003/DOC-261745A1.html
>
> FEDERAL COMMUNICATIONS COMMISSION
>
> ENFORCEMENT BUREAU
> Northeast Region
>
> Boston Office
> 1 Batterymarch Park
> Quincy, MA 02169
>
>
> 10/6/2005
>
>
> Yvon Grachamps
> Mattapan, MA
>
> NOTICE OF UNLICENSED OPERATION
>
> Case Number:
> EB-04-BS-079
> Document Number:
> W20063226001
>
> The Boston Office received information that an unlicensed
> broadcast radio station on 1620 kHz was allegedly operating
> in
> the Boston, Massachusetts area. On August 16, 2005, agents
> from
> this office confirmed by direction finding techniques that
> radio
> signals on frequency 1620 kHz were emanating from
> transmitter
> sites located at 30 Abbott Street, Apt #2, Dorchester, MA
> and 89
> Tremont Street, Everett, MA. The Commission's records show
> that
> no license was issued for operation of a broadcast station
> on
> 1620 kHz at either of these locations.
>
> Radio stations must be licensed by the FCC pursuant to 47
> U.S.C.
> § 301. The only exception to this licensing requirement is
> for
> certain transmitters using or operating at a power level or
> mode
> of operation that complies with the standards established in
> Part
> 15 of the Commission's rules, 47 C.F.R. §§ 15.1 et seq.
> The
> field strength of the signal on frequency 1620 kHz was
> measured
> at 440,000 µV/m at 53 meters at 30 Abbott Street and 400,000
> µV/m
> at 25 meters at 89 Tremont Street, both of which exceeded
> the
> maximum permitted level of 14.8 microvolts per meter (µV/m)
> at 30
> meters for non-licensed devices. Thus, these stations are
> operating in violation of 47 U.S.C. § 301.
>
> You are hereby warned that operation of radio transmitting
> equipment without a valid radio station authorization
> constitutes
> a violation of the Federal laws cited above and could
> subject the
> operator to severe penalties, including, but not limited to,
>
> substantial monetary fines, in rem arrest action against the
>
> offending radio equipment, and criminal sanctions including
>
> imprisonment. (see 47 U.S.C. §§ 401, 501, 503 and 510).
>
> UNLICENSED OPERATION OF THIS RADIO STATION MUST BE
> DISCONTINUED
> IMMEDIATELY.
>
> You have ten (10) days from the date of this notice to
> respond
> with any evidence that you have authority to operate granted
> by
> the FCC. Your response should be sent to the address in the
>
> letterhead and reference the listed case and document
> number.
> Under the Privacy Act of 1974, 5 U.S.C. § 552a(e)(3), we are
>
> informing you that the Commission's staff will use all
> relevant
> material information before it to determine what, if any,
> enforcement action is required to ensure your compliance
> with FCC
> Rules. This will include any information that you disclose
> in
> your reply.
>
> You may contact this office if you have any questions.
>
>
>
> Dennis Loria
> District Director
> Boston Office
>
>
>
>
>
> Attachments:
> Excerpts from the Communications Act of 1934, As
> Amended
> Enforcement Bureau, "Inspection Fact Sheet", July 2003
>

 

[rfry]

> ***If you were indeed intent on having an honest discussion
> about this issue you would provide the ENTIRE document for
> our review. Since you only provide a small clip it is
> obvious you are not truly interested in seeing the other
> side of the coin, or the facts. You don't cite a specific
> source or the location where the entire document may be
> found.
> You've deliberately avoided providing us with tangible proof
> of your claims concerning the alleged field strength
> requirement for part 15 AM intentional radiators and you
> refuse to provide access to the entire FCC document that you
> only posted a small clip from.
_________

The full text and a link to it was just posted on this thread. As I responded to that, I had wanted to respect the privacy of the person getting the Notice. Oh, well.

But now that the precedent is set, here is another link to a Notice based in part on excess Part 15 AM field strength:

http://www.fcc.gov/eb/FieldNotices/2003/DOC-246123A1.html

//

 

[WCWalker]

***Yes, I was aware of this right after it happened. This guy was using something like a 25 watt LPB transmitter and had a broadcast radius of 15 miles. Again, it has nothing to do with a part 15 station. Don't try to equate field strength readings from a LPB Pre Sunrise/Post Sunset transmitter with a 100 mw flamethrower.


> > ***If you were indeed intent on having an honest
> discussion
> > about this issue you would provide the ENTIRE document for
>
> > our review. Since you only provide a small clip it is
> > obvious you are not truly interested in seeing the other
> > side of the coin, or the facts. You don't cite a specific
>
> > source or the location where the entire document may be
> > found.
> > You've deliberately avoided providing us with tangible
> proof
> > of your claims concerning the alleged field strength
> > requirement for part 15 AM intentional radiators and you
> > refuse to provide access to the entire FCC document that
> you
> > only posted a small clip from.
> _________
>
> The full text and a link to it was just posted on this
> thread. As I responded to that, I had wanted to respect the
> privacy of the person getting the Notice. Oh, well.
>
> But now that the precedent is set, here is another link to a
> Notice based in part on excess Part 15 AM field strength:
>
> http://www.fcc.gov/eb/FieldNotices/2003/DOC-246123A1.html
>
> //
>

 

[radio8z]

Re: Part 15.219 is for AM band

> 15.219 is only for the AM band, it allows for 100mw and a 3
> meter radiator.
>
> Section 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 demonstrated by
> measuring the radiated emissions.
>
Keith is correct. In my other post I was referring to the AM band. Sorry if what I said was misleading. Also note that in part 15.217, you have an alternative to 15.209 also for VLF operation.

A quick read about 13MHz. seems to me to limit field strength and does not give the power/antenna alternative.

Neil

 

[JasonW]

Standard, legal-length antennas *are* either supplied with FCC-certified units such as the Talking House and TalkingSign (3 meter wire antennas) and/or standard consumer antennas are specified for use with them (2.59 meter [102"] tall CB whips are used with the RangeMaster, the Talking House & TalkingSign outdoor ATUs, and the out-of-production Trans-AM). -- JasonW

> > ***Unless the rules have suddenly changed it is my
> > understanding that ONLY AM Carrier Current stations must
> > comply with Field Strength limits while intentional
> > radiators such as the Rangemaster, Infomax or Trans AM 100
>
> > must adhere to rule 15.219. This rule was changed in,
> > I believe 1989.
>
> Understandings and beliefs are fine if they agree with FCC
> Rules. But the tendency is to understand and believe those
> ideas that best support positions desired by their
> holder(s).
>
> In this case (and others), the FCC is quoting specific texts
> in 47 CFR relating to the operation of unlicensed
> transmitters in the broadcast band. What is the basis to
> say they are wrong? You would have to prove them wrong by
> paying for your own measurements showing that you are
> compliant to the Rules they referenced, while using the same
> equipment and operating parameters as when you were cited.
>
> > Nobody at the FCC in DC seems to believe the Field
> Strength
> > rule applies to transmitters like the Rangemaster and they
>
> > informed the KC Field Office of this fact.
>
> Not according to the 47 CFR texts in the Notice clip I
> posted.
>
> > I should also add that ANY Field Strength reading of a
> very
> > low power AM station in the field is not likely to be even
>
> > close to accurate.
>
> This is absolute fiction. Professional field strength
> meters such as the Potomac Instruments FIM-41 and numerous
> other signal analyzers give accurate field strength readings
> (within a few dB) down to 5 microvolts/meter, or less. This
> is far below the groundwave field strength that can be
> produced even 500 feet away from a Part 15 AM system
> operating with 100 mW input power and a ground-mounted
> vertical that is 3 meters long (including feeder and ground
> connection path).
>
> > Technically, the FCC is supposed to a the transmitter to
> an
> > Official FCC Lab and then bench test it for Field
> Strength.
> > This is especially true of anyone running a Part 15 FM
> > station that appears to be in question.
>
> Please explain how that can be done when the antenna is
> rarely supplied by the manufacturer of the Part 15 AM
> transmitter. Part 15 AM-ers supply their own antenna, and
> the radiation efficiency of the antenna system actually used
> can make a huge difference in the field strength produced by
> the station -- especially considering the understandings,
> beliefs, and "war stories" so common here on this subject.
> //
>

 

[JasonW]

Part 15 Short Wave NVIS? (Re: Part 15.219 is for AM band)

I wonder if Near-Vertical Incidence Skywave (NVIS) using a low-mounted dipole and a ground-mounted reflector wire or grid would be effective for limited-area broadcasting on the 22 meter band? (It would work better on 41 meters and below.)

That 14 kHz slice 'o spectrum centered at 13.56 MHz is clear and low-noise where I am, and the allowed Part 15 field strength works out to about 1.8 milliwatts fed to a 1/2 wavelength dipole. That's obviously not a lot of power, but many effective Part 15 AM antennas end up radiating about that much after the losses. -- JasonW

> > 15.219 is only for the AM band, it allows for 100mw and a
> 3
> > meter radiator.
> >
> > Section 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 demonstrated by
> > measuring the radiated emissions.
> >
> Keith is correct. In my other post I was referring to the
> AM band. Sorry if what I said was misleading. Also note
> that in part 15.217, you have an alternative to 15.209 also
> for VLF operation.
>
> A quick read about 13MHz. seems to me to limit field
> strength and does not give the power/antenna alternative.
>
> Neil
>