Same Old Same Old About FCC Regs.

[radiopilot]

Last night I spent an two hours going through the FCC NAL/NOUO database to see who got NOUO's and NAL's... I know what a waste of good time I could have spent with my wife and son playing monopoly or Rockband or something... but what I found was 99 percent of the NOUO's were for FM violations whether they were over the part 15 rules for FM using a part15 transmitter or any number of 5,10, 100watt units, or any number of CB band violations, or the occasional EPIRB use in violation of the rules... the entirety of the rest of the NAL's, citations, etc. were for the licensed FM/AM entities whether for an unpainted antenna structure or no fence around such structure, EAS violations, EEO file violations, etc.

Yeah... Mr. Fry and Neil and all the other cheerleaders in favor of supporting the rhetoric of Mr. Fry, there where no violations for users of Part15 100mw and any allegations by them indicating such is simply not warranted and misleading at best.

Now you may not believe anything I post here but I hope you too will venture into the FCC database and reach your own conclusion as I have and feel it's useless to debate this any further with Mr. Fry... he's got nothing better to do at this time in his life but I've got a part15 station to run.

May I suggest Mr. Fry you obtain a part15 transmitter and come to the conclusion the FCC is not going to raid your home for any violations of the rules?

Radiopilot

 

[radioman148]

Thanks Radiopilot.

 

[rfry]

... there where no violations for users of Part15 100mw and any allegations by them indicating such is simply not warranted and misleading at best.

None of the NOUOs issued for non-compliance with FCC Part 15.209 state the transmitter power used. So there is no rational justification for the validity of the conclusion quoted above.

As shown in the plots at http://i62.photobucket.com/albums/h85/rfry-100/Part15AMSystemComparison.gif, a ground-mounted AM transmitter with only 30 milliwatts of output power in the unmodulated carrier can generate a field intensity far above the limit of 15.209 -- and one which can be measured with good accuracy by a suitable meter. I have measured fields of this value myself, as have hundreds/thousands of broadcast station engineers over many decades..

Part 15 setups on elevated mounts, using long, conducting paths to r-f ground generate even higher fields.

This is physical reality, whether or not people choose to accept it.

//

 

[Tom Wells]

Three facts:

1. I run a pt 15 AM station on AM 1620
2. I once received a NAL from the FCC and paid a $1000 dollar fine for operating at 100 watts on 7.415 mhz in 1991.
3. I have a degree from a radio engineering school and 28 years of experience with RF as an "obsession", not a hobby.

If you don't know what it feel like to recieve an "unfavorable" letter from the FCC, I'll tell you.
It's like when you're 16 years old, have wrecked the family car for doing something stupid, your stomach is tied in knots,
and you wish you could make it all go away, but you can't...it's too big, and you're going to pay somehow.
It's a very bad feeling, a bad situation, and this is what Mr Fry is hoping you will avoid by being properly informed.

There is room for the disagreement seen here due to each installation's unique situation, local ground conductivity, local absorbtion
of signal, etc.

Regarding the small car owner vs big rig driver, I would suggest the big rig driver, with professional experience and a special license permitting them to operate commercial vehicles, would be far better qualified than the econo-car driver to speak on matters of
driving, traffic, safety, vehicle safety, maintenance, and operating procedure.

I have no field intensity meter, but many years of trying to get the most out my part 15 AM has convinced me of what MY best
expectations ought to be in terms of coverage. I can't tell anyone else what their result will be, but I can agree
with Mr Fry that the essential matters are those of power, efficiency, and radiating conductors of the RF.

I want everyone to be able to have a great big signal, but the rules are specifically written to ensure that pt 15 AM signals are wimpy.
Sorry about that, because it limits MY signal as much as anyone else's.

There is some truth that it may be a bit difficult to measure low power AM signals in the close field, and perhaps the
rules need a clarification and/or definition of what such signals ought to measure at a distance like 1 km, as in AM broadcast service.
Even this would find us in disagreement, as local ground conductivity would result in some signals being in compliance, and some exceeding the stated limits.

Please have respect for someone with more experience than yourself.
Regardless of power level, RF only behaves one way, and the laws of physics are unyielding.
It is to Mr Fry's credit that he's sharing his knowledge and experience.

I will agree we could use his help in getting AM iboc abolished as it is willful, repeated, intentional, malicious interference.
How 'bout it, Rich?
My 1620 suffers on the upper sideband from someone on 1640 spewing hash somewhere.
And on the lower sideband by WONX 1590 with unbelievable amounts of overmod splatter.

We could also use your help in figuring out how to get the FCC to police the "unintended radiator" devices, which are
harming every single AM operator in the US.
If only I could get a job as a FCC agent citing these garbage-spewing devices.......
How is it that the FCC regulations in this area seem to have had NO effect whatever?
I can go out and buy devices anywhere that destroy reception for hundreds of feet, and these manufacturers continue to make
ever more and ever worse offending crud.

 

[radiopilot]

Tom, I respect you and you are a very articulate in the areas you are an expert in and I enjoy your anti-HD posts, I too am an engineer BSEE, MSME by the way... one thing my part 15 does:

I run a part15 on 1550AM with the SSTRAN 100mw.
My total antenna height 3 meters to the tip is 30 feet (or 20' of pipe ground along the house)
The ground system consists of many, many radials on a salt water marsh.
I don't run 100's of watts or any amplifiers.
I had Atlanta FCC AGENT confirmation at my site.
I have NEVER been given an NOUO or NAL ever.
I currently am in the FCC database for a LPFM should the window open in our area.

Now other than that what else can I say?
The real violators are the NAB, licensed broadcasters, and real pirates.

Radiopilot

 

[Neil E.]

Mr. Walker and Radiopilot,

I appreciate your comments posted after mine of yesterday. I have refrained, at least in this thread, from commenting on the technical and legal matters at hand. I accept that for many the "same old tired worn out" discussion may be boring, but look what happened in this thread. Some great and previously unknown (to me at least) information was presented.

Since experience seems to be an issue let me present some of mine. I have been using part 15 AM on and off since 1959. In addition to a graduate degree in electrical engineering, I hold an Extra class amateur radio license. Along with low band operations, I have built from scratch and operated a 2 meter repeater and managed the acquisition of an installation of a 220 MHz repeater for public service use. During my college days as an engineering student I volunteered engineering help for the College AM campus carrier current station where I built and maintained transmitters, and even did some "jocking" back then. I currently, and for the past 20 years, have part 15 AM and FM transmitters operating here. I know what they will and will not do and I have had no problems with the FCC, my neighbors, nor anyone else regarding my activities. Perhaps that is because, with my background, I understand the rules and the technology and how to apply both.

I had the advantage of being able to study and understand the technology and rules, an advantage many hobbyists don't enjoy and boards such as this provide them with this opportunity. Your posts and those of Mr. Fry together offer a great source of information for the hobbyists.

I have no disagreement with anything Mr. Fry has posted and I don't find his demeanor "arrogant". Let's learn from each other.

Neil

 

[WCWalker]

Speaking for myself, I have a difficult time learning anything from someone that has no prior experience with the subject at hand. And I personally know more than one Broadcast Engineer plus have other friends with a considerable amount of technical experience in various radio fields including Part 15 AM. I learn from them and they, believe it or not, have learned a few things about this subject from me. Therefore, I really cannot learn anything new from Mr. Fry.

You missed my point about the vehicles. The point is this. Someone that has only driven a car and not a truck is out of place telling someone that drives a truck how it should handle. And vice versa. Someone that has only driven a small car and not a truck is talking out of turn when trying to give advice to the driver of an 18 wheeler about how it should handle. That is the situation that we have here with Mr. Fry. No practical experience with Part 15 AM yet he thinks he's an expert.

 

[Goat Rodeo Cowboy]

You missed my point about the vehicles. The point is this. Someone that has only driven a car and not a truck is out of place telling someone that drives a truck how it should handle. And vice versa. Someone that has only driven a small car and not a truck is talking out of turn when trying to give advice to the driver of an 18 wheeler about how it should handle.

Whether this thread teaches us anything about radio or not, we do have an opportunity to learn a lot about the ability of humans to communicate, and the ability of humans to REFUSE to communicate.

If I pull into the Rest Area along the Interstate and I am in strange territory and I am looking for some advice on how to maneuver the upcoming road through mountains or maybe through the desert, Whose advice am I going to pay the most attention to: Someone driving a Ford Pinto 12,000 miles a year, or the truck driver who gets all over the country driving a bit over 100,000 miles per year. And that holds true even if I, too, have my antique Pinto on this trip.

 

[WCWalker]

My point exactly. You want someone that has experience driving that specific vehicle through that terrain. A large truck handles very differently than a small Otnip and the person driving the truck, if he does not have experience with the Otnip, will not be able to furnish precise information or sound advice on how to handle that part of the road. He may be able to point out flaws with the road etc. but he won't know how the smaller vehicle handles these conditions.

I'd liken the current situation here with that in DC. We've got a guy with NO prior experience in business, let alone the automotive companies, issuing ultimatums and dictating policy simply because he thinks he can get away with it.

 

[Tom Wells]

I'm not sure how to respond. I would always carefully consider the voice of someone with professional experience, and give priority to their opinion. The truck driver DOES have experience driving a car ninety-nine percent of the time, and the smaller vehicle would always have
easier time negotiating a difficult road. How many car drivers do a full safety check of their vehicles EVERY day?
Not to demean any particular car or driver, but most average auto owners use them like appliances and throw them away with
over half the value unused. The truck driver's advice wins, every time. He may already know that the road is closed up ahead with an accident via CB radio, and might decide to stay at the rest stop, or get off at the next exit and use an alternate route, while the both car drivers end up stuck in a jam for 3 hours. We'll all learn a lot more when we are receptive to information, whether or not we
are ready to fully utilize it. All the behavior of RF, regardless of power level, is THE SAME. Everything just happens on a smaller scale.

I am ready to suggest that perhaps rulemaking or clarification of the best distance for measuring a part 15 AM is needed to ensure
that the measurements are not occuring in the very "close field" where large variations may give inaccurate results.
My experience is that within 100 meters these variations which could cause incorrect readings.
I would suggest that at .5 km, the field is "normalized" and should still be close enough to make a good measurement.
There is no current standards established for what permissable field strength should be at .5 km, but it would certainly
eliminate a lot of confusion and questions if there were.

 

[WCWalker]

Perhaps a more precise analogy would be the following: Would you go to a Podiatrist if you have a heart problem? Or if you have a foot problem would you want to take the advice of a heart specialist? Probably not in either case because neither has experience in the other's field.

We have the same case here. Fry is dispensing advice about Part 15 AM when he does not have the experience in this field.

 

[rfry]

Fry is dispensing advice about Part 15 AM when he does not have the experience in this field.

Note that the comments I post on these boards are based on the proven principles of physics, which principles apply to Part 15 AM / FM setups equally as well as to every other r-f transmission system of every other configuration.

Several members of this board can refer non-believers of my statement above to antenna engineering textbooks, other literature, and computer software proving this -- IF such non-believers are willing to study / use them with an open mind, have the math skills, and (hopefully) the practical experience needed to understand and accept such sources.

RF

 

[radiopilot]

Several members of this board can refer non-believers of my statement above to antenna engineering textbooks, other literature, and computer software proving this -- IF such non-believers are willing to study / use them with an open mind, have the math skills, and (hopefully) the practical experience needed to understand and accept such sources.

RF

No need for any of this, the FCC in the Part15 rules have spelled it out fairly well and they even indicate in straight forward layman terms, get a 100mw transmitter, 3 meter antenna, reasonable ground and transmission line and you're broadcasting. As long as the transmitter is not modified or an amplifier to increase the power there really is no need for textbooks, fourier transforms, laplace transforms, Monte carlo analysis, antenna books, smith charts, etc. it's all nonsense... this is why they have spelled it out clearly in the rules for Part 15. It's not filled with the same rhetoric legal/engineering terms that part 73 requires where one must hire RF engineers, broadcast lawyers, etc. just to get on the air.

This is why toys such as Mr. Microphone, FM transmitters for Ipods, baby monitors, etc. were created under Part 15 and NOT Part 73.

That is why when the two or three instances where the FCC issued an NOUO for those violations the field strength if deduced is more than the power of the 100 mw max for Part 15 AM... in other words Mr. Fry they were using either more power than 100mw or using something other than a Part 15 transmitter! I doubt the agents were concerned about the transmitter being 10', 20' or 30' feet high... the only obvious case was the transmitter with a 90' ground... tell me another instance where the ground was an issue or that the Part 15 100mw transmitter user was cited an NOUO... you can't fine one single instance so you fall back on the field strength measurement... LOL

Radiopilot

 

[rfry]

...That is why when the two or three instances where the FCC issued an NOUO for those violations the field strength if deduced is more than the power of the 100 mw max for Part 15 AM. etc

Neither the input power or the output power of the transmitter was measured, or stated in the NOUOs issued for these Part 15.209 citations.

So if such field strengths and transmitter power were only deduced, then by whom? Certainly not by the FCC.

The reality that the field intensities allowed by 15.209 can't accurately be measured in an open environment means nothing. All the FCC needs to show is that the "Part 15" field greatly exceeds that value. Such excess values can accurately be measured.

The FCC measures the field intensity resulting in the NOUOs they issue for non-compliance with Part 15.209 -- and with accuracy sufficient to support the NOUOs they issue.

Of course every "Part 15" AM operator cited under 15.209 who thinks otherwise is free to argue and prove to the FCC (if possible) that the FCC measurement was wrong, and/or did apply to them.

But win or lose, it won't be an easy or inexpensive process.

//

 

[radiopilot]

...That is why when the two or three instances where the FCC issued an NOUO for those violations the field strength if deduced is more than the power of the 100 mw max for Part 15 AM. etc

Neither the input power or the output power of the transmitter was measured, or stated in the NOUOs issued for these Part 15.209 citations.

So if such field strengths and transmitter power were only deduced, then by whom? Certainly not by the FCC.

The reality that the field intensities allowed by 15.209 can't accurately be measured in an open environment means nothing. All the FCC needs to show is that the "Part 15" field greatly exceeds that value. Such excess values can accurately be measured.

The FCC measures the field intensity resulting in the NOUOs they issue for non-compliance with Part 15.209 -- and with accuracy sufficient to support the NOUOs they issue.

Of course every "Part 15" AM operator cited under 15.209 who thinks otherwise is free to argue and prove to the FCC (if possible) that the FCC measurement was wrong, and/or did apply to them.

But win or lose, it won't be an easy or inexpensive process.

//

You have got to be kidding me Mr. Fry... are you indicating a person using a 1000 watt AM tranmitter will be cited for violation of Part 15.209 emission and claim this person violated the Part 15 rules with a transmitter (not even knowing the wattage) and then claim 'here is a case of a Part 15 AM operator was cited under Part 15.09'?

This is absolute nonsense Mr. Fry... since the only indication is radiation limits over Part 15.209, this could be anywhere from 101mw to 5000 watts either way it's over the Part 15.219 rule and since the FCC allows 100mw on AM it's useless to debate this with you... you believe any any violation over the 15.209 is someone with a 100mw transmitter... guess what Mr. Fry venture into the EBAY site for any number of 10, 20 100 watt AM transmitters... could it be these are the ones getting the NOUO's you are reading in the FCC database?

Radiopilot

 

[radioman148]

>>guess what Mr. Fry venture into the EBAY site for any number of 10, 20 100 watt AM transmitters... could it be these are the ones getting the NOUO's you are reading in the FCC database?>>

Speaking of ebay right now there's an 18 watt FM transmitter available

http://cgi.ebay.com/18W-FM-RADIO-ST...4|66:2|65:12|39:1|240:1318|301:1|293:1|294:50

 

[Neil E.]

<snip>
You have got to be kidding me Mr. Fry... are you indicating a person using a 1000 watt AM tranmitter will be cited for violation of Part 15.209 emission and claim this person violated the Part 15 rules with a transmitter (not even knowing the wattage) and then claim 'here is a case of a Part 15 AM operator was cited under Part 15.09'?

This is absolute nonsense Mr. Fry... since the only indication is radiation limits over Part 15.209, this could be anywhere from 101mw to 5000 watts either way it's over the Part 15.219 rule and since the FCC allows 100mw on AM it's useless to debate this with you... you believe any any violation over the 15.209 is someone with a 100mw transmitter... guess what Mr. Fry venture into the EBAY site for any number of 10, 20 100 watt AM transmitters... could it be these are the ones getting the NOUO's you are reading in the FCC database?

Radiopilot

The only provision allowing for operation of an intentional RF radiator which is not licensed is Part 15. Therefore, even a 1000 watt unlicensed transmitter is technically operating subject to, and will be in violation of, part 15 rules unless the field strength produced is within the limits of 15.209 (perhaps by using sufficient shielding, dummy load, etc.). If this were the case then it would be legal under 15.209 but not under 15.219, but as you will see in the next paragraph it would be legal. If I understand your comment to Mr. Fry correctly you are questioning citations based only on 15.209. Is your objection that the FCC didn't also check to verify compliance with 15.219? I think that is a valid concern. Also, it wouldn't matter whether the system complied with 15.219 if the field strength was below the 15.209 limits.

Which prevails? I obtained a copy of the part 15 rules from the Superintendent of Documents when I got into this in 1959. At that time the section numbers were different than now so I will use the present numbers to make a point. The text for part 15.219 began with something like this: "In lieu of meeting the requirements of part 15.209.....". It was clear that 15.219 was set up to be an alternative to the field strength limits. The "in lieu of" verbiage was dropped in later revisions but part 15.209 presently begins with "except as provided elsewhere in this Subpart..." which is 15.219. You can operate under either field strength limits OR 100 mW, 3 m, etc., but you are not required to meet the limits of both sections...just one or the other.

If, however, the FCC cites an operator for field strength under 15.209 could not that operator reply to the NOUO claiming and substantiating they were legal under 15.219? This may get a bit complicated but it would be worth doing. This is one advantage of using a certified transmitter providing the installation met the transmission line/ground lead limits, since use of a certified transmitter may not require further proof that it meets the power limit. To me, it seems that a certified transmitter mounted at ground level with a less than 3 meter antenna would be a good presentation.

Neil

 

[rfry]

... you believe any any violation over the 15.209 is someone with a 100mw transmitter... guess what Mr. Fry venture into the EBAY site for any number of 10, 20 100 watt AM transmitters... could it be these are the ones getting the NOUO's you are reading in the FCC database?

Yes, people receiving those NOUOs could have been using transmitters of those power levels.

BUT they also could have been using an FCC-certified Part 15 AM transmitter with an input power of 100 milliwatts, and even less. Here is undeniable proof of that.

The link below leads to a paste-up of data submitted for FCC certification of the ProcasterTM AMTX100 Part 15 AM transmitter. It also includes a picture and description from the website of the certification lab about the indoor test range where it measured the field strength from the Procaster.

In the middle of the page there is a table showing the measured field strength. The lower of the two values measured at a distance of 10 meters is 63.4 dBµV/m, which is 1,479 µV/m. Converting that to the value for a path length of 30 meters (per 15.209) is done by dividing 1,479 by 3, which equals 493 µV/m.

Part 15.209 permits a field strength at 30 meters ranging from about 14.1 µV/m to about 44.5 µV/m, depending on the operating frequency.

Therefore an FCC inspector measuring the same field as produced by the Procaster during its certification would have to conclude that the installation was non-compliant with 15.209, and could issue an NOUO.

Of course the Procaster wasn't certified under 15.209, it was certified under 15.219. So the operator of the Part 15 AM setup receiving an NOUO for these circumstances would have to work with the FCC (after the fact) to get their acceptance of this.

The rest of this paragraph is speculation. It may be possible that an FCC inspector can see during the inspection that a long, radiating ground conductor is present. But rather than trying to measure it so as to cite under 15.219, s/he just uses 15.209 -- as the FCC's position is that systems operating under both forms of the Rules should produce about the same field strengths at any given distance.

http://i62.photobucket.com/albums/h85/rfry-100/ProcasterData.jpg

//

 

[WCWalker]

<snip>
You have got to be kidding me Mr. Fry... are you indicating a person using a 1000 watt AM tranmitter will be cited for violation of Part 15.209 emission and claim this person violated the Part 15 rules with a transmitter (not even knowing the wattage) and then claim 'here is a case of a Part 15 AM operator was cited under Part 15.09'?

This is absolute nonsense Mr. Fry... since the only indication is radiation limits over Part 15.209, this could be anywhere from 101mw to 5000 watts either way it's over the Part 15.219 rule and since the FCC allows 100mw on AM it's useless to debate this with you... you believe any any violation over the 15.209 is someone with a 100mw transmitter... guess what Mr. Fry venture into the EBAY site for any number of 10, 20 100 watt AM transmitters... could it be these are the ones getting the NOUO's you are reading in the FCC database?

Radiopilot

The only provision allowing for operation of an intentional RF radiator which is not licensed is Part 15. Therefore, even a 1000 watt unlicensed transmitter is technically operating subject to, and will be in violation of, part 15 rules unless the field strength produced is within the limits of 15.209 (perhaps by using sufficient shielding, dummy load, etc.). If this were the case then it would be legal under 15.209 but not under 15.219, but as you will see in the next paragraph it would be legal. If I understand your comment to Mr. Fry correctly you are questioning citations based only on 15.209. Is your objection that the FCC didn't also check to verify compliance with 15.219? I think that is a valid concern. Also, it wouldn't matter whether the system complied with 15.219 if the field strength was below the 15.209 limits.

Which prevails? I obtained a copy of the part 15 rules from the Superintendent of Documents when I got into this in 1959. At that time the section numbers were different than now so I will use the present numbers to make a point. The text for part 15.219 began with something like this: "In lieu of meeting the requirements of part 15.209.....". It was clear that 15.219 was set up to be an alternative to the field strength limits. The "in lieu of" verbiage was dropped in later revisions but part 15.209 presently begins with "except as provided elsewhere in this Subpart..." which is 15.219. You can operate under either field strength limits OR 100 mW, 3 m, etc., but you are not required to meet the limits of both sections...just one or the other.

If, however, the FCC cites an operator for field strength under 15.209 could not that operator reply to the NOUO claiming and substantiating they were legal under 15.219? This may get a bit complicated but it would be worth doing. This is one advantage of using a certified transmitter providing the installation met the transmission line/ground lead limits, since use of a certified transmitter may not require further proof that it meets the power limit. To me, it seems that a certified transmitter mounted at ground level with a less than 3 meter antenna would be a good presentation.

Neil

This is absolutely correct Neil. In the early 1990's Chris DiPaola of Westerly, Rhode Island essentially started this new concept of using a Part 15 AM transmitter as a commercial operation. He contacted the FCC in Washington to find out what options were available for unlicensed broadcasting when he found out he was not able to get a licensed station at that time. DC told him about the Trans AM 100 transmitter by Ultra Sensors Inc. and that he could use the unit under rule 15.219. They said that Field Strength DID NOT APPLY and that a transmitter such as this could operate solely under rule 15.219. After my visit by the FCC in KC in 2000 I confirmed this as well as the people in DC told the people in KC that my transmitter could operate under 15.219 and did not need to meet Field Strength requirements. And again, even if Fry does not want to believe it, the very reason rule 15.219 was created was because it is virtually impossible to get an accurate reading of field strength from a Part 15 AM transmitter and because it simplified the process for allowing people to operate legally under the rules.

 

[WCWalker]

... you believe any any violation over the 15.209 is someone with a 100mw transmitter... guess what Mr. Fry venture into the EBAY site for any number of 10, 20 100 watt AM transmitters... could it be these are the ones getting the NOUO's you are reading in the FCC database?

Yes, people receiving those NOUOs could have been using transmitters of those power levels.

BUT they also could have been using an FCC-certified Part 15 AM transmitter with an input power of 100 milliwatts, and even less. Here is undeniable proof of that.

The link below leads to a paste-up of data submitted for FCC certification of the ProcasterTM AMTX100 Part 15 AM transmitter. It also includes a picture and description from the website of the certification lab about the indoor test range where it measured the field strength from the Procaster.

In the middle of the page there is a table showing the measured field strength. The lower of the two values measured at a distance of 10 meters is 63.4 dBµV/m, which is 1,479 µV/m. Converting that to the value for a path length of 30 meters (per 15.209) is done by dividing 1,479 by 3, which equals 493 µV/m.

Part 15.209 permits a field strength at 30 meters ranging from about 14.1 µV/m to about 44.5 µV/m, depending on the operating frequency.

Therefore an FCC inspector measuring the same field as produced by the Procaster during its certification would have to conclude that the installation was non-compliant with 15.209, and could issue an NOUO.

Of course the Procaster wasn't certified under 15.209, it was certified under 15.219. So the operator of the Part 15 AM setup receiving an NOUO for these circumstances would have to work with the FCC (after the fact) to get their acceptance of this.

The rest of this paragraph is speculation. It may be possible that an FCC inspector can see during the inspection that a long, radiating ground conductor is present. But rather than trying to measure it so as to cite under 15.219, s/he just uses 15.209 -- as the FCC's position is that systems operating under both forms of the Rules should produce about the same field strengths at any given distance.

http://i62.photobucket.com/albums/h85/rfry-100/ProcasterData.jpg

//

Fry this is where you again show your ignorance of the rules and law. IF THE TRANSMITTER IS CERTIFIED UNDER RULE 15.219 THEN IT DOES NOT HAVE TO MEET FIELD STRENGTH LIMITS OUTLINED IN RULE 15.209. This is not an EITHER OR proposition and if you understood how our laws and regulations are written and interpreted then you'd comprehend this fact.