Same Old Same Old About FCC Regs.

[radiopilot]

The effective radiated power (ERP) needed to generate 23.6 mV/m, 75 meters away is less than 40 milliwatts. That ERP could be produced by a typical Part 15 AM transmitter and whip plus its "ground conductor" when mounted on an elevated structure.

Which perfectly by your deduction Part 15.209 should not be used to measure an intentional radiator under the rules or Part 15.219 needs to be revised to lower the 100 mw transmitter allowance to something lower than 30mw to meet the radiation limits of 15.209?

Are you now indicating the FCC does not know how to test transmitter power which allowed them to come up with 100mw power allowance?

I don't know what your agenda here is Mr. Fry but it boogles the mind why you should spend so much time and energy over what someone with with a 100mw transmitter will generate in terms of what radiation limits are violated whether the transmitter is at 2 feet off the ground or 20 feet off the ground?
What daily satisfaction comes from arguing this point time and time again especially when the FCC is not excessively looking for these violations unlike what you indicate?

Thouisands of these installations are currently running just fine without any percieved threat from the FCC and those that did get any NOUO were either turned in to the FCC by either competitors, or someone with an agenda.

I believe Part 15.209 needs to be rewritten such that Part 15.219 stands alone with the hobbyist being allowed to use 100mw transmitter power and that's it since the average (might I say no one) will ever use an expensive Potomic FIM to measure the station especially when in the hands of such trained FCC agents they themselves make inaccurate readings.

Radiopilot

 

[rfry]

Which perfectly by your deduction Part 15.209 should not be used to measure an intentional radiator under the rules or Part 15.219 needs to be revised to lower the 100 mw transmitter allowance to something lower than 30mw to meet the radiation limits of 15.209? Are you now indicating the FCC does not know how to test transmitter power which allowed them to come up with 100mw power allowance?

This thread http://part15.us/node/1746 has a lot of information directly from the FCC about how Parts 15.209 and 15.219 evolved. In it you'll find that the FCC intended systems using 15.209 and/or 15.219 as they exist now to provide similar signal strengths at similar distances.

What daily satisfaction comes from arguing this point time and time again...

Because some posters to these boards continue to make inaccurate and misleading statements about how these systems operate (and can be measured), which if followed by others could lead them to problems with the FCC. This is proven by the NOUOs that have been linked in this thread.

(might I say no one) will ever use an expensive Potomic FIM to measure the station especially when in the hands of such trained FCC agents they themselves make inaccurate readings.

I haven't learned of any scientifically proven case that the FCC made grossly inaccurate readings for a Part 15 AM or FM station (Mr Walker's anecdote in Kansas City included).

Typically the FCC takes their Part 15 field intensity measurements quite close to the transmit antenna where the fields are very high, as in the last AM NOUO (Wellsville, OH) noted above in this thread. The fields they measure there are so high that they could be in error by 50% or so and still show non-compliance.

It would be interesting to learn why the FCC so often uses 15.209 rather than 15.219 when issuing an AM NOUO. It might be just simpler/quicker/cheaper for them to measure the field strength a short distance away than to conduct an on-site inspection and risk possible anger/arguments from the station operator. The operator may not even be on site at the time the FCC arrives.

If the FCC believes, as they state in the link above in this post, that 15.209 and 15.219 setups are to have about equal performance, that may explain why they refer to 15.209 in the NOUO. And 15.219 cannot be used directly in the NOUO because it is being issued based on a field strength -- which is not defined by 15.219.

There has been only one NOUO I know of that was based on 15.219, specifically as to the length of the ground conductor (link below).

http://www.fcc.gov/eb/FieldNotices/2003/DOC-269883A1.html

//

 

[WCWalker]

Fry, that first link does not tell us much of anything other than how the rules were slightly rewritten to facilitate the use of the metric system. It certainly does not outline whether or not both conditions apply simultaneously to a transmitter. They don't.

Clearly you do not understand how to interpret law otherwise it would be quite clear that the way the rules are written that both do not apply to a Part 15 AM transmitter. It just so happens I do know several attorneys, two of which have an understanding of broadcast law and more importantly, how to interpret our laws. And just because a law is passed does not make it legal or non contradictory to an existing regulation or law. There are thousands and perhaps tens of thousands of laws and regulations that are on the books that violate or contradict earlier laws and regulations or the Constitution itself.

I have an idea. Instead of lecturing people in your condescending tone about how they are non compliant with Part 15 AM transmissions, I suggest you purchase a FIM, and several FCC Type Accepted transmitters like the Rangemaster, Infomax, Trans AM 100 and Talking House unit and then see what kind of readings you get. Bet you never get the same exact readings over and over again with each unit.

Again, if HR 1388 is passed you will get the opportunity to get a nice uniform, a badge and probably a clipboard and then you can go out and hassle Americans as you please.

 

[WCWalker]

The effective radiated power (ERP) needed to generate 23.6 mV/m, 75 meters away is less than 40 milliwatts. That ERP could be produced by a typical Part 15 AM transmitter and whip plus its "ground conductor" when mounted on an elevated structure.

Which perfectly by your deduction Part 15.209 should not be used to measure an intentional radiator under the rules or Part 15.219 needs to be revised to lower the 100 mw transmitter allowance to something lower than 30mw to meet the radiation limits of 15.209?

Are you now indicating the FCC does not know how to test transmitter power which allowed them to come up with 100mw power allowance?

I don't know what your agenda here is Mr. Fry but it boogles the mind why you should spend so much time and energy over what someone with with a 100mw transmitter will generate in terms of what radiation limits are violated whether the transmitter is at 2 feet off the ground or 20 feet off the ground?
What daily satisfaction comes from arguing this point time and time again especially when the FCC is not excessively looking for these violations unlike what you indicate?

Thouisands of these installations are currently running just fine without any percieved threat from the FCC and those that did get any NOUO were either turned in to the FCC by either competitors, or someone with an agenda.

I believe Part 15.209 needs to be rewritten such that Part 15.219 stands alone with the hobbyist being allowed to use 100mw transmitter power and that's it since the average (might I say no one) will ever use an expensive Potomic FIM to measure the station especially when in the hands of such trained FCC agents they themselves make inaccurate readings.

Radiopilot

A little birdie told me that he's an over officious appointee by the NAB governing body to keep an eye on us rogue elements. In reality, more licensed stations are pirates than Part 15 station operators.

 

[rfry]

Fry, that first link does not tell us much of anything other than how the rules were slightly rewritten to facilitate the use of the metric system. It certainly does not outline whether or not both conditions apply simultaneously to a transmitter. They don't.

Quoting the FCC from the text in that link:

Paragraph 16, however, made the Commission's intentions clear that it implemented the alternative power measurements in lieu of a field strength limit to make it easier for home builders, that didn't have the means to perform field strength measurements, to demonstrate that their products complied with the standards. However, this rule was never intended to provide a greater operating range than the original field strength limit. The operating ranges were expected to be about equal, but improvements in efficiency were starting to result in increased range, and increased potential interference, for systems operating under Section 15.113.

Section 15.113 became 15.219.

I suggest you purchase a FIM, and several FCC Type Accepted transmitters like the Rangemaster, Infomax, Trans AM 100 and Talking House unit and then see what kind of readings you get. Bet you never get the same exact readings over and over again with each unit.

A field that measures a few thousand times higher than allowed by 15.209 is not going to vary between that and a legal value from one day to another, other things equal.

//

 

[WCWalker]

The way the rules are written these rules conflict with one another. The rule needs to be rewritten to state that "a part 15 AM transmitter operating at 100 mw may not exceed the field strength limits quoted in rule 15.209." Currently the way this is read, and interpreted from a legal perspective is that you have a choice to operate under either 15.209 or 15.219. Forget intent because in a court of law, intent is rarely taken into consideration by a Judge when interpreting law or in this case, a regulation.

Even if the field strength rule only applies, it would be possible to get an NOUO thrown out in a court of law of documentation proving that FIM's cannot accurately read very low power AM signals. In my case, if it had gone that route, I could have had the FCC engineer put on the stand and he would have been required to state that my transmitter was exceeding their field strength limits despite the fact the power level was set to ZERO and there was no discernible or audible signal on a radio a mere fifteen feet away from the transmitter.

 

[rfry]

The way the rules are written these rules conflict with one another. The rule needs to be rewritten to state that a Ppart 15 AM transmitter operating at 100 mw may not exceed the field strength limits quoted in rule 15.209." Currently the way this is read, and interpreted from a legal perspective is that you have a choice to operate under either 15.209 or 15.219.

As is shown by radiation physics, practical experience, and the FCC NOUO links given in this thread, the use of a Part 15 AM, FCC-certified transmitter such as the Hamilton Rangemaster (or others) does not define or limit the maximum field intensity that such a transmitter can produce at a given distance.

Why? Because radiated field intensities also are greatly dependent on the characteristics of the antenna system components attached to the transmitter.

For Part 15 AM this includes the r-f loss in the loading coil and the r-f ground in use, and the additional radiation gain from the exposed vertical height of the conducting path leading from the "ground" terminal of an elevated mount of the transmitter and 3-meter whip to that r-f ground (which typically, is something buried in the earth).

Therefore the users of all such "FCC-certified Part 15 AM Transmitters" are not automatically immune to FCC actions under Part 15.209.

If they were immune, there would be fewer "Part 15'" AM NOUOs issued by the FCC.

//

 

[radiopilot]

If they were immune, there would be fewer "Part 15'" AM NOUOs issued by the FCC.

Mr. Fry, since you are the only person here protesting the part15 setups everyone has that you believe are not in compliance based on the NOUO's by the FCC and they are great in numbers compared to the real pirates operating on the FM side... tell us in your own words after researching all the NOUO's in the FCC database just how many have gotten an NOUO on the AM side for going over the radiation limits cited per part 15.209?

Now we know you have more time on your hands to do this research than most of us since we have other things to occupy our time since we do have lives to contend to, come back post those NOUO links to the FCC and let us know how many as you indicate were cited.

Remember only to cite those NOUO's that were running a part 15 transmitter and don't try to sneak in a violation with a TIS, 100watt, 500watt, etc. transmitter.

We're waiting patiently...

Radiopilot

 

[rfry]

... since you are the only person here protesting the part15 setups everyone has that you believe are not in compliance based on the NOUO's by the FCC...

Note that the installations receiving an FCC NOUO were not in compliance with Part 15. If they were, they would not have received it.

People wanting to avoid an NOUO might want to know what causes the FCC to issue one. That's the reason for my comments, and posting links to some of them.

The NOUO links I posted in this thread were first posted by others on this and other boards. I spent no time looking for them on the FCC website, I just remembered where I saw them on these boards.

There wouldn't be much value in adding to the NOUO list, as the point already has been made.

//

 

[WCWalker]

... since you are the only person here protesting the part15 setups everyone has that you believe are not in compliance based on the NOUO's by the FCC...

Note that the installations receiving an FCC NOUO were not in compliance with Part 15. If they were, they would not have received it.

People wanting to avoid an NOUO might want to know what causes the FCC to issue one. That's the reason for my comments, and posting links to some of them.

The NOUO links I posted in this thread were first posted by others on this and other boards. I spent no time looking for them on the FCC website, I just remembered where I saw them on these boards.

There wouldn't be much value in adding to the NOUO list, as the point already has been made.

//

Note that the link to the NOUO from the Philadelphia area allegedly showed a Part 15 AM transmitter using in excess of one watt of power. FCC Type Accepted transmitters like the Rangemaster, Trans AM 100, Infomax and Talking House are not designed and don't possess the appropriate parts to handle the voltage values associated with higher power. Unfortunately Fry seems to turn a blind eye to this fact. Most likely in the case of the Philly area station, the transmitter was home brew or perhaps a CC unit that was being used as an intentional radiator.

Fry is not about to search the FCC database for NOUO's of allegedly non compliant Part 15 AM stations because it won't support h is agenda on this forum. I.E. you won't find very many either because there has only been a tiny handful of stations from around the country that were citied for allegedly violating the FCC Part 15 AM regulations.

With Heir Fry it is guilty until proven innocent...

 

[rfry]

Note that the link to the NOUO from the Philadelphia area allegedly showed a Part 15 AM transmitter using in excess of one watt of power.

Transmitters with a measured input power in excess of 1 watt, and even those that are certified under Part 15 (such as the Hamilton Rangemaster and others) can either meet or exceed Part 15.209 field intensity limits, depending on the design and adjustment of the transmitter, and the radiation efficiency of the antenna system supplied by the user.

//

 

[WCWalker]

Note that the link to the NOUO from the Philadelphia area allegedly showed a Part 15 AM transmitter using in excess of one watt of power.

Transmitters with a measured input power in excess of 1 watt, and even those that are certified under Part 15 (such as the Hamilton Rangemaster and others) can either meet or exceed Part 15.209 field intensity limits, depending on the design and adjustment of the transmitter, and the radiation efficiency of the antenna system supplied by the user.

//

Whatever. Again, there is not one single FCC Type Accepted Part 15 AM transmitter that can radiate at a power level exceeding one watt regardless of the antenna that is attached. Unless someone literally uses a full quarter wave tower in place of the CB whip, this is utter nonsense.

The following OTOH again shows how the FCC field agents are not all that sharp. Note the two different FM frequencies on this NOUO.

http://www.fcc.gov/eb/FieldNotices/2003/DOC-286300A1.html

 

[rfry]

Whatever. Again, there is not one single FCC Type Accepted Part 15 AM transmitter that can radiate at a power level exceeding one watt regardless of the antenna that is attached.

It does not take one watt or more of radiated power to produce a maximum groundwave field at 30 meters that is non-compliant with FCC Part 15.209.

Typical, FCC-certified/uncertified "100 milliwatt," assembled AM transmitters, and uncertified kit or home-made/composite AM transmitters can produce a field intensity at 30 meters that is far in excess of what is allowed by 15.209.

The groundwave field intensity 30 meters away from these installations highly depends on the efficiency of the user-supplied antenna system, including the radiation from the "ground" and other conductors leading away from an elevated installation of the transmitter with its attached, 3-meter whip.

Excess field strength from these elevated setups becomes the basis for FCC NOUOs, because per the quotes posted earlier, the FCC still considers that compliant setups operating under 15.209 and 15.219 both should produce about the same field intensity at a given distance (other things equal).

Compliance to the low field intensities permitted by Part 15.209 is very difficult to measure/prove in an outdoor environment, due to ambient r-f noise and other interference. Wm Walker is correct to this extent.

But the field strengths that the FCC measures close to the antenna of an installed, unlicensed AM station that result in an NOUO under 15.209 are much higher than can be produced by a compliant part 15.209 setup.

Such high field intensities can be measured with very good accuracy where the FCC measures them close to the transmit antenna, even though such fields were produced by a "Part 15" setup. And THAT field, if non-compliant, is used as the basis for the FCC to issue an NOUO.

Therefore it would be very difficult, technically, to argue/disprove the accuracy of such FCC measurements.

Once again, I repeat my belief that people always are free to operate as they wish.

//

 

[radiopilot]

Such high field intensities can be measured with very good accuracy where the FCC measures them close to the transmit antenna, even though such fields were produced by a "Part 15" setup. And THAT field, if non-compliant, is used as the basis for the FCC to issue an NOUO.

Once again, I repeat my belief that people always are free to operate as they wish.

Mr. Fry... this is really getting exhausting... I can see the thread for this one going in the 20 pages or so if allowed... LOL

Once again post up the countless NOUO's against those using the part 15 transmitter on the AM side with all the setups everyone is using (we're talking thousands of users) and you'll see that one was the Flagstaff violation (if a 100mw Rangemaster was used) the other was the 90' grounded issue with the church transmitter (once again who knows what they used), other than that cite from the FCC Enforcement page the average user of the 100mw transmitter that was cited an NOUO... you can't post one and you come up with excuse of the posts you remember somewhere and had to look up on these boards.

Fact is Mr. Fry you are trying to use two these violations you have burned into memory as the basis for lecturing your retired engineering skills to some end.

You are right on one very good quote 'my belief that people always are free to operate as they wish' should somehow be etched, chiseled, burned, stamped, whatever in your consciousness and maybe the boards can move on to some other topic much more worthy of the 'Community Boards' rather than 'My Rant Against Part15 User Boards'. :

Radiopilot

 

[radioman148]

>>Fact is Mr. Fry you are trying to use two these violations you have burned into memory as the basis for lecturing your retired engineering skills to some end>>

Everybody needs a hobby ;D

 

[radiopilot]

Everybody needs a hobby ;D

Or shall I say obsession? :

 

[Neil E.]

Well, this thread should win an award for topic drift, yet even at that, it has become a very interesting discussion.

My original post had to do with making unsubstantiated and trite personal comments about posters rather than sticking to the technical and legal facts. There is no harm in disagreeing with over these "facts" but the harm is when it gets personal. Fortunately, these personal comments do more harm to the credibility of those making them than to the intended targets.

My hope was that the personal comment approach would diminish because personal comments about motives, abilities, free time, having no life, and so on just weaken the arguments and frankly make the posters of such material appear less than able to present factual rebuttals. Unfortunately, as demonstrated by many posts here this continues. So be it. If that is the only way you can find to "enhance" your disagreement and support your opinions then I suppose that is what you need to do.

I tried to offer constructive advice.

Neil

 

[radioman148]

I've been reading the NYC board about radio pirates. It seems there is no shortage of them in NYC or Newark, NJ.
These are definitely not legal, not even gray area. They are running higher power on FM with at least 10 mile coverage--maybe more in some cases.
Maybe Mr. Fry should go there and let them know about the rules because those violations are not even questionable.

 

[XRQKFM]

I've been reading the NYC board about radio pirates. It seems there is no shortage of them in NYC or Newark, NJ.
These are definitely not legal, not even gray area. They are running higher power on FM with at least 10 mile coverage--maybe more in some cases.

Most are running 100 watts into Comet antennas, a tip off as to how many there are comes from antenna sales; which according to an antenna dealer averages over a hundred a month. Despite their tough laws; Florida has hundreds of high power pirates operating in and around the Miami area. The Feds are afraid to go in and do much about it; fearing for their personal safety. Why go after the sharks, when the guppies are an easier target?


Steve
www.outlawradio.us

 

[WCWalker]

Neil. Fry is deliberately antagonizing some people with his posts. They wreak of arrogance and he is coming across like he's the Shell Answer Man.

I've seen his credentials and he has absolutely NO PART 15 AM experience. None. Someone with no practical experience with these transmitters should refrain from acting like an expert on the subject. This is akin to someone that has driven a sub compact car trying to tell the drivers of 18 wheelers the ins and outs of their rigs.

Don't expect all of use to listen to Fry, especially those of us that know better. It just so happens Neil that I've dealt directly with the FCC on this issue and I know for a fact and have verified this with more than one source (inside the FCC as well as broadcast engineers) that these FIM's that are industry standard CAN NOT accurately read very LPAM signals. I don't care what Fry says on this subject and most of us are tired of his preachy tone and lack of practical hands on experience with this subject. Despite my limited technical background I have friends that are broadcast engineers and other friends that have more background in technical areas like this than Fry. Their experience in these matters plus my own personal experience seeing the FCC's inability to accurately read my Part 15 AM signal with their FSM is proof enough for me that these FSM's cannot pin point an exact reading on these signals.

I can't find more than about half a dozen NOUO's or NAL's for alleged violators of Part 15 AM regulations in the Enforcement section of the FCC website. And this dates back nearly a decade. And at least one of those is questionable in terms of the kind of transmitter being used because the FCC alleges that the power level of that transmitter was 1200 milliwatts. Again, there ain't no Type Accepted Part 15 AM transmitter that has the ability to exceed one watt of power at either stage. The voltage ratings for many of the components in these transmitters are very limited in order to prevent modification of the unit to obtain a higher power level. This means that if you can find a way to run the transmitter at a higher power, unless you change some of the components, the unit will crap out, or pardon the expression, fry.

So, Fry can keep on spewing out the same tired old mantra on this subject but most of us that have experience in this area will take what he has to say with a grain of salt.