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Richard Fry's Comments about Part 15 radio

W

WCWalker

Guest
A question for the audience.

Fry's comments that concern Part 15 broadcasting are obviously stirring up some trouble on this board and in the world of Part 15 broadcasting in general.

If you own a Part 15 transmitter or are thinking about buying a transmitter, have you been intimidated by Fry's comments to the point that now you either have been dissuaded from buying or building a transmitter or have stopped broadcasting?
 
William C. Walker said:
...snip...

If you own a Part 15 transmitter or are thinking about buying a transmitter, have you been intimidated by Fry's comments to the point that now you either have been dissuaded from buying or building a transmitter or have stopped broadcasting?

No problem here and business as usual. I have been doing part 15 AM for a long time and have been familiar with the rules and nothing Mr. Fry has posted has surprised me nor made me change anything. His posts have helped me brush up on the technology, especially with regard to loading coils.

Neil
 
It wouldn't put me off part 15 AM broadcasting. Although it does emphasize the importance of a type-accepted unit like a Rangemaster or Procaster.

I suppose my only question would be that if an FCC field agent were to inspect my setup, would he use the 15.209 rule or the 15.219 rule to base his judgement as to whether it was legal or not? And would using multiple transmitters be tempting fate?

Perhaps one strategy would be to inform a field office that you would be setting up a part 15 AM station using a type-accepted TX following the 15.219 "3 meter" rule and see how they respond.

C5
 
I have been told by field agents they get stressed when people do this, they don’t want to be bothered. They will find you if they need to. My advice is just make it easy on them should they need to find you. Broadcast contact information regularly, and leave a copy of the certification where they can find it if they show up and you are not there.
They have a lot of important things going on, and little time to do it, & they are under a lot of time pressure.
 
Carmine5 said:
....
Perhaps one strategy would be to inform a field office that you would be setting up a part 15 AM station using a type-accepted TX following the 15.219 "3 meter" rule and see how they respond.

C5

Don't do this. Just follow the rules. I repeat my comment that nothing in my activities has been changed by Mr. Fry's posts regarding the rules. I know the rules, have followed them, and after 49 years of on and off part 15 AM activity I have had no problems. I see nothing inconsistant between my knowledge of the rules and Mr. Fry's contributions regarding them.

I also will mention that I have never used a "certified" transmitter. Certification does not absolve the user from responsibility if the transmitter is misused. Certified or not, get on the air, follow the rules, and enjoy the hobby.

Neil
 
Neil E. said:
Carmine5 said:
....
Perhaps one strategy would be to inform a field office that you would be setting up a part 15 AM station using a type-accepted TX following the 15.219 "3 meter" rule and see how they respond.

C5

Don't do this. Just follow the rules.

OK, but which one? The 15.209 rule, or the 15.219 rule? Which rule would a field agent be more inclined to follow?

C5
 
Carmine,

I cannot answer for the FCC but consider this. 15.209 is based upon field strength at a distance. 15.219 is based on physical attributes of your system. It turns out that 15.219 will in many instances provide a larger field strength than 15.209. Therefore if your field strength exceeds the limits of 15.209 would it not be reasonable to think they will inspect the station for compliance under 15.219?

Most of us are only able to assess our operations under 15.219 and if you are compliant then you are in a defensible position if ever inspected though it is still up to the inspectors.

Do what you can to follow the rules, get on the air, don't worry, and have fun.

Once again, to stay on topic, nothing Mr. Fry has posted causes me any concerns.

Neil
 
Well, for what it's worth Neil, here is my suspicion (and I really hope I'm wrong). Rule 15.209 is a clarification of rule 15.219 and that one would be used in conjunction with the other. It also appears that 15.209 is new to the latest rules governing part 15 operation.

That was my original question which, I guess, touched off this latest firestorm on the age-old topic of ground lead radiation (a favorite subject of Mr. Fry's as we know).

My question is strictly a legal one and I sincerely hope that I'm way off base in my understanding here and that you're right. I would much prefer, as I know we all would (with the possible exception of one), an either/or interpretation of the rule.

C5
 
I run a part 15 station, usually FM sometimes also on the AM.

I use an FCC certified Maxell FMT1 on FM and a SStran that I built myself. The SStran I tested using directions given for the asking by Phil B, who sells the kits. I know for a fact that there isn't more than 100 milliwatts into the rf amplifier stage and can show that with a multimeter and a calculator. I know that the combined antenna and ground wire (when I use one) are 3 meters or less. I have experimented with loading coils on the AM, but ended up restoring it to the original circuit configuration because I like the *sound* better that way and it gets a good signal to the neighbor across the street who is the only AM listener I am aware of.

I bought the FMT1 and built the SStran while engaged in regular reading and posting on boards Richard Fry frequents and sometimes debating points with him or asking questions. So, obviously I have built and bought transmitters and did not give up on part 15 BCB as a hobby. I also have conducted experiments with my gear to see how far it can get and etc. My station is not "24/7" but it is on the air regularly and has been for over 2 years now.

HOWEVER.. The original transmitter for this station was built from a very cheap Hobbytron kit. I highly doubt if it was part 15 compliant for FM when built as per the instructions. As a result of listening to Richard Fry (and others too!), and asking questions and getting answers, and going from that to doing research, I built and added to the original circuit to add things like a low pass filter, rf attenuation, a regulator so the "drift" on it's tuned tank oscillator was less affected by the battery voltage. I'm pretty sure that by the time it was done it was compliant, because it actually had a bit less range than the Maxell when I bought the Maxell for some experiments. The Maxell also sounded better, and since it is FCC certified and there is really no user/hobby level way of accurately measuring a part 15 FM for compliance, I took my much revamped kit transmitter off the air.

The decision to go to a certified transmitter *for FM* was very much influenced by talks with Rich and many others on the part 15 board. I have never regretted it. It sounds better, doesn't drift on frequency, etc. Now for AM, I enjoyed building the SStran, there *are* a set of guidelines within the part 15 rules that are realistic for a hobbyist for determining if it is compliant, and I have fun experimenting with antenna variations and tinkering with the audio controls and outboard audio gear to see just how good I can get the sound. For AM, the sound is far better than I expected. But I digress..

The point is, Rich didn't stop or discourage me from part 15 FM or AM. Neither did the many other people on the assorted part15 boards who gave advice and sometimes encouragement. I'd lived through many of Rich's rants on ground lead length and etc before I finally decided to buy and build the SStran kit. I don't have a lot of budget to work with, so the SStran was the option I felt I could afford.

I *do* feel that the work of Rich and others was helpful and their willingness to answer questions and explain technical matters and theory did more to encourage me than any of the attractive ads I saw for assorted gear. It got me thinking, calculating, building, testing and experimenting. While that's not all of the fun that part 15 has to offer as a hobby, I have been finding it very enjoyable.

Do I get frustrated or annoyed with Rich (and others) sometimes? Well sure. I am also sure that sometimes I have been quite a pain in their neck with my questions and arguments. I even would disagree on some relatively minor points where I feel the predictions based on theory do not line up precisely with results of actual physical experiments with real gear. But those differences would be measured in feet, not in miles, and as such it's not worth arguing over beyond a reasonable point.

I was not dissuaded from building *and* buying transmitters and I have not stopped putting my station on the air.

In all fairness, though.. if some people have been dissuaded or left the air, then why would they still be here reading these forums to answer the question? So it may happen, but I can say it didn't have that effect on me personally.

Daniel
 
Carmine5 said:
Well, for what it's worth Neil, here is my suspicion (and I really hope I'm wrong). Rule 15.209 is a clarification of rule 15.219 and that one would be used in conjunction with the other. It also appears that 15.209 is new to the latest rules governing part 15 operation.

15.209 specifies "general radiation emission limits." But then 15.215(a) states that "alternatives" to the general radiation limits are found in 15.217 through 15.257. Of these, 15.219 is applicable to 500-1705 kHz. It appears clear to me that if either 15.209 or 15.219 is satisfied, the system would be legal. Check out this page on my web site: www.geocities.com/victory1610am/FCCInfo.html

In answer to the question: No, but Mr. Fry's comments did encourage me to try a shielded coaxial cable for the ground wire just for kicks. No change in signal range.
 
As always here and on other boards I anticipate and appreciate your comments which come from one who practices the art and also has a realistic view of things. You have added much to the boards by describing your experiences.

You wrote:
Rattan said:
...snip...
I was not dissuaded from building *and* buying transmitters and I have not stopped putting my station on the air.

Your answer which I quoted addresses the question of the original post.

I repeat my comment: nothing Mr. Fry has posted has caused me any concerns.

Neil
 
Carmine5 said:
Well, for what it's worth Neil, here is my suspicion (and I really hope I'm wrong). Rule 15.209 is a clarification of rule 15.219 and that one would be used in conjunction with the other. It also appears that 15.209 is new to the latest rules governing part 15 operation.

That was my original question which, I guess, touched off this latest firestorm on the age-old topic of ground lead radiation (a favorite subject of Mr. Fry's as we know).

My question is strictly a legal one and I sincerely hope that I'm way off base in my understanding here and that you're right. I would much prefer, as I know we all would (with the possible exception of one), an either/or interpretation of the rule.

C5

Carmine,

Originally, there was only one part 15 rule for part 15 AM, the one we now know as 15.209 (originally written sometime around 1937). Part 15.219 was added later. It used to be prefaced with the words to the effect "in lieu of meeting the requirements of part 15.209 ....). In other words you can operate under either 15.209 or 15.219. This is and OR situation, not an AND situation. Most likely part 15 operators are using 15.219. If your transmitter has 100 mW or less input power and your antenna and ground are less than three meters then you are OK under 15.219. Go on the air and don't worry.

cgbrock said:
15.209 specifies "general radiation emission limits." But then 15.215(a) states that "alternatives" to the general radiation limits are found in 15.217 through 15.257. Of these, 15.219 is applicable to 500-1705 kHz. It appears clear to me that if either 15.209 or 15.219 is satisfied, the system would be legal.

Yes, I agree that it is an OR situation, not an AND situation.

Back to the OP question, nothing Mr. Fry has posted has caused me any concerns.

Neil
 
Neil E. said:
Carmine5 said:
Well, for what it's worth Neil, here is my suspicion (and I really hope I'm wrong). Rule 15.209 is a clarification of rule 15.219 and that one would be used in conjunction with the other. It also appears that 15.209 is new to the latest rules governing part 15 operation.

That was my original question which, I guess, touched off this latest firestorm on the age-old topic of ground lead radiation (a favorite subject of Mr. Fry's as we know).

My question is strictly a legal one and I sincerely hope that I'm way off base in my understanding here and that you're right. I would much prefer, as I know we all would (with the possible exception of one), an either/or interpretation of the rule.

C5

Carmine,

Originally, there was only one part 15 rule for part 15 AM, the one we now know as 15.209 (originally written sometime around 1937). Part 15.219 was added later. It used to be prefaced with the words to the effect "in lieu of meeting the requirements of part 15.209 ....). In other words you can operate under either 15.209 or 15.219. This is and OR situation, not an AND situation. Most likely part 15 operators are using 15.219. If your transmitter has 100 mW or less input power and your antenna and ground are less than three meters then you are OK under 15.219. Go on the air and don't worry.

cgbrock said:
15.209 specifies "general radiation emission limits." But then 15.215(a) states that "alternatives" to the general radiation limits are found in 15.217 through 15.257. Of these, 15.219 is applicable to 500-1705 kHz. It appears clear to me that if either 15.209 or 15.219 is satisfied, the system would be legal.

Yes, I agree that it is an OR situation, not an AND situation.

Back to the OP question, nothing Mr. Fry has posted has caused me any concerns.

Neil

Well, this does ease my mind. The understanding of either/or concerning 15.209 and 15.219 seems pretty clear.

Thanks all.

C5
 
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