I sure wish that NAL's included the field strength measurements. If I remember correctly, before the PIRATE act was passed, NOUO's included the field strength measurements. I feel fairly certain that a station is only deemed to be operating in violation of the law if the field strength exceeds the allowed Part 15 limits by a significant amount (i.e. orders of magnitude greater) but it would be good to have confirmation.
Does anyone know if and how it's possible to access the field strength measurements associated with a particular NAL?
Does anyone know if and how it's possible to access the field strength measurements associated with a particular NAL?
A freedom of information request would do it, but you might not even have to go that far, presumably you could simply request the information from the NY dept that issued the NAL.
There's a couple things that jumped out at me. Notable is how when referring to part 15 the citation singles out only FM as being limited to "certain low-power limits", as though indirectly acknowledging AM as not bound to such limits. Quote from citation:
- Section 511 defines pirate radio broadcasting as “the transmission of communications on spectrum frequencies between 535 and 1705 kilohertz, inclusive, or 87.7 and 108
megahertz, inclusive, without a license issued by the Commission, but does not include unlicensed operations in compliance with part 15 of title 47, Code of Federal Regulations.”5
Part 15, among other requirements, states that unlicensed operators in the FM band must not transmit over a certain low-power limit.6
6 47 CFR § 15.239(b) (stating that the field strength of any emissions in the 88-108 MHz band shall not exceed 250 microvolts/meter (“μV/m”) at 3 meters).
Also interesting is how they tracked the operator down:
- During the course of the investigation, Agents conducted online and social media research for 99.1 Radio Union Familiar and found information associating Vazquez directly with the
Station. Specifically, Vazquez’s Facebook page,
Also interesting is their programing was simply a rebroadcast of an AM station;
- They found it was rebroadcasting the online stream of 630 WUNO(AM) from San Juan, P.R.
But the AM band is restricted to certain low power limits @richpowers. Per FCC 15.219, it's limited to 100mW of DC input power to the final stage. It's the FM band, per 15.239 that is governed by field strength limits, rather than power limits.
Both his website and Facebook page are still up. This sort of thing really makes me wonder - did he fully realize that his broadcast operation was illegal, and does he now realize that he most likely doesn't have a leg to stand on? I would have thought that his best chance at avoiding, or at least mitigating, further legal action, would be to stop all illegal activities, take his website and social media down, and assure the FCC that it won't happen again. He's either defiant, or really doesn't give a hoot.
I'm not sure if this forum is the right venue to be discussing this type of pirate operation at length. My main purpose in replying to @mark's post was to mention the field strength issue. I feel fairly sure that the pirates getting busted are responsible for field strengths that are orders of magnitude greater than Part 15 limits and not, say, 10-50% over. That said, due to component tolerances and inaccuracies in measuring equipment, I think the most my power or field strength on AM is likely to be over, if at all, is 10% - probably less. I'm still considering the purchase of a used field strength meter for FM, and having it professionally calibrated. That's for the future though, when the inspiration really kicks in, and I feel that my budget can support it! In the meantime, the fact that my FM signal drops out as soon as I get to the other side of the street from my house (75-100 feet) must mean that I'm in the ballpark with my Decade MS-100.
1- But the AM band is restricted to certain low power limits @richpowers. Per FCC 15.219, it's limited to 100mW of DC input power to the final stage. It's the FM band, per 15.239 that is governed by field strength limits, rather than power limits.
2 - did he fully realize that his broadcast operation was illegal, ... He's either defiant, or really doesn't give a hoot.
3- I'm not sure if this forum is the right venue to be discussing this type of pirate operation at length. ..
True.. however despite its wording the citation seems to actually be referring to feild strength, not power... Part 15 FM is NOT limited by power input like AM (15.219), FM is limited by field strength. I realize the two are linked, but its wasnt the transmitters power iteself that that was non compliant, the power used is irrelevant. Consider AM carrier-current, it's not limited by power either, they all vary from 1 watt to 10watt or even more, it doesnt matter the power, it has no bearing on compliance, only its resulting feild strength is the rule - this applied even before the campus rules were enacted. And it's the same issue with part 15 FM, the power itself used doesnt matter.
2- My guess? he knew and didnt care.
3- It is, because it's quite likely he was using a Chinese transmitter marketed as part 15.
@rugster You said it yourself.
The citation says: unlicensed operators in the FM band must not transmit over a certain low-power limit.
And you point out: the FM band, per 15.239 that is governed by field strength limits, rather than power limits.
You get my point now?
I think I get the citations wording now:
"a certain low-power limit"
It's actually referring to the "low-power" limiting rules (part 15). It's not saying the FM transmitter was operating under too high a power.
Sorry to keep harping on this before you even had a chance to reply, it's just that it just occurred to me what they meant with their wording.
True.. however despite its wording the citation seems to actually be referring to feild strength, not power... Part 15 FM is NOT limited by power input like AM (15.219), FM is limited by field strength. I realize the two are linked, but its wasnt the transmitters power iteself that that was non compliant, the power used is irrelevant. Consider AM carrier-current, it's not limited by power either, they all vary from 1 watt to 10watt or even more, it doesnt matter the power, it has no bearing on compliance, only its resulting feild strength is the rule - this applied even before the campus rules were enacted. And it's the same issue with part 15 FM, the power itself used doesnt matter.
2- My guess? he knew and didnt care.
3- It is, because it's quite likely he was using a Chinese transmitter marketed as part 15.
Well, the citation does refer to field strength, as it directly quotes the ruling in the following -
6 47 CFR § 15.239(b) (stating that the field strength of any emissions in the 88-108 MHz band shall not exceed 250 microvolts/meter (“μV/m”) at 3 meters).
It's just that the earlier sentence is inconsistent, as it refers to a power limit -
Part 15, among other requirements, states that unlicensed operators in the FM band must not transmit over a certain low-power limit.
That's just plain incorrect as the Part 15 rules, unless I'm mistaken, do not mention a power limit on the 88-108MHz band at all; only a field strength limit. Honestly, I just think that whoever wrote that citation wasn't being very detail-oriented. If they had wanted to be more correct, something like the following might have been a bit better -
Part 15, among other requirements, states that unlicensed operators in the FM band must not exceed a stated field strength limit when transmitting.
Agreed with 2 and 3. As for 3, I know that this forum is focused on Part 15 operation, and doesn't want to be seen as encouraging illegal operation. I was probably being a bit too cautious when saying that the direction the discussion was going in might not be appropriate. Yes, he was probably using an eBay special. I understand that some of those transmitters are known for throwing out spurii as well as unwanted harmonics. I imagine that most of the people buying them don't even know what a spurious emission is. The thing about the FM band, is that it's too easy to put out a listenable signal there. Just buy a cheap box, plug it into a power adapter, plug an antenna in, and boom! You're on the air!
I've said this before in other forums, but I grew up listening to AM pirate ships in the UK. In reality, they weren't broadcasting illegally, as they were anchored in international waters and not subject to UK broadcasting laws. The British government did pass a law making it illegal to supply the ships, but the broadcasts themselves weren't illegal. From an engineering standpoint, I respected them. It's pretty hard putting out a good signal of 10-50kW on the AM band from a ship! Definitely not easy, They had very competent engineers - a stark contrast with the majority of the FM pirates nowadays.
That's why I like Part 15 on the AM band. It represents more of an engineering challenge than does Part 15 FM.
Well, the citation does refer to field strength, as it directly quotes the ruling in the following -
6 47 CFR § 15.239(b) (stating that the field strength of any emissions in the 88-108 MHz band shall not exceed 250 microvolts/meter (“μV/m”) at 3 meters).
It's just that the earlier sentence is inconsistent, as it refers to a power limit -
Part 15, among other requirements, states that unlicensed operators in the FM band must not transmit over a certain low-power limit.
That's just plain incorrect...
It cites the field strength to indicate the Broadcast did indeed the part 15 limits. It's unclear to me why he got an NAL instead of an NOUO.. Nor the other one on AM that got that peculiar Pirate Act titled thing.. Are there still NOUOs?.. but I digress..
As for: "unlicensed operators in the FM band must not transmit over a certain low-power limit."
I think it's just poor wording that makes it look like it says something else. Very much in the way the famous 200ft document does.. And think how citations began citing 215.19 only after the KENC thing. But whatever, it would be interesting to know just how much signal he was throwing and perhaps which transmitter as well.
@rugster The topic of "pirates" does come up from time to time and as long as it is not encouraged here or someone actually post they do it or operate in a manner outside of rules it is Ok for discussion. The point of the topic was just to post some news of recent busts by the FCC. You see this on the "other forum" also.
I also wish that they would post like they used to what field strength was measured.
In Canada, this is not so common and usually gets a write up in the news papers if it happens.
ISED doesn't publish this news like the FCC and other than a kid in Ottawa years ago we don't know how much of it actually happens here. But I do know that here is not as heavy handed as the FCC which used to give out NOUO's first to give someone a warning and cease operation or do it legally. Here, that still applies, and have not seen in the news ever about any follow suit like the FCC pirate act, which seems to forego the NOUO first.
...Or perhaps more likely, the agent who wrote it doesn't know the intricacies of part 15 at all. There's no such thing as a FCC Part 15 Task Force. They're not Part 15 police checking compliance. These are just agents hunting down pirates. I bet most FCC staff has no knowledge concerning specifics of Part 15 radio rules.
@richpowers This is why it is good practice that in the event of a visit you have the rules there to show an agent, your certified transmitter and the copy of the certification from the FCC/ISED look up page.
@richpowers This is why it is good practice that in the event of a visit you have the rules there to show an agent, your certified transmitter and the copy of the certification from the FCC/ISED look up page.
You know something? I've never seen anyone mention it, but I've never seen a physical certification sticker actually attached on any AM transmitter I ever had.
This all harkens to the recent NOTICE OF ILLEGAL PIRATE RADIO BROADCASTING: on the AM band posted under our Regulations/Law threads, and probably where this thread belongs.