Hello guys. As you know, I am launching a new Part 15 very soon. Ordering a Rangemaster in the next week or so (As soon as my credit lines re-avail themselves to us; banks, boy.., you can have them!) Anyway, my engineer came across this NOUO issued in August out of L.A. to an operator. Don't know if this is old news in here. Thought I'd post it for your perusal.
FEDERAL COMMUNICATIONS COMMISSION
ENFORCEMENT BUREAU
WESTERN REGION
Los Angeles Office
18000 Studebaker Road, Suite 660
Cerritos, CA 90703
August 19, 2011
Willie Walton
Santa Clarita, California, 91350
NOTICE OF UNLICENSED OPERATION
Case Number: EB-11-LA-0092
Document Number: W201132900010
The Los Angeles Office received information that an unlicensed broadcast
radio station on 1610 kHz was allegedly operating in Santa Clarita, CA. On
August 11, 2011, agents from this office confirmed by direction finding
techniques that radio signals on frequency 1610 kHz were emanating from
your residence in Santa Clarita, CA. The Commission's records show that no
license was issued for operation of a broadcast station at this location
on 1610 kHz in Santa Clarita, CA.
Radio stations must be licensed by the FCC pursuant to 47 U.S.C. S: 301.
The only exception to this licensing requirement is for certain
transmitters using or operating at a power level that complies with the
standards established in Part 15 of the Commission's Rules, 47 C.F.R. S:S:
15.1 et seq. The field strength of the signal on frequency 1610 kHz was
measured at 2,730 microvolts per meter (uV/m) at 145 meters, which
exceeded the maximum permitted level of 14.9 uV/m (24,000/1610) at 30
meters established in Section 15.209(a) of the Rules (see 47 C.F.R. S:
15.209(a)).
Another exception for some transmitters operating in the 510 kHz to 1705
kHz band is found in 47 C.F.R. S: 15.219. Specifically, Section 15.219(b)
of the Rules states "the total length of the transmission line, antenna
and ground lead (if used) shall not exceed 3 meters" (see 47 C.F.R. S:
15.219(b)). The investigation by this office determined that the ground
lead was connected to a cable that ran down the length of the antenna
tower, thereby, increasing the total length of the antenna, transmission
line, and ground lead well beyond 3 meters. This installation violated
Section 15.219(b) of the Rules.
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 of this illegal
operation to severe penalties, including, but not limited to, substantial
monetary forfeitures, in rem arrest action against the offending radio
equipment, and criminal sanctions including imprisonment. (See 47 U.S.C.
S:S: 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 to this
notice, and to supplement your response to the on-scene notice issued to
you on August 11, 2011, 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. S: 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.
Nader Haghighat
District Director
Los Angeles Office
Western Region
Enforcement Bureau
Attachments:
Excerpts from the Communications Act of 1934, As Amended
Enforcement Bureau, "Inspection Fact Sheet," March 2005
Well its unfortunate that the NOUO's do not specify what kind of equipment was being used.
But from the numbers, that seems pretty close to the field strengths one would get with an extended ground lead via a cable down a pole coming from a low power TX.
They should have connected a very very short ground lead to the mounting mast. That might have passed. But then again...there is the KENC situation where their TX was up on a pole and it had a short lead connecting to the mast for ground. The problem was that the mast itself radiated RF energy. Even after the installation of the "ground choke" filter, which should have resolved the problem...KENC still got tagged because the inspecting agent determined the mast was part of the ground lead thus exceeding 3 meters.
And KENC's ordeal was most likely started by some nearby licensed station uptight about a little bit of non-threatening competition from an independent station.
Its possible this particular case was the result of the same thing...the "go away or else" tactic from some other station.
Pathetic...isn't it.
My advice when you get that Rangemaster TX is to set that thing up EXACTLY like they set it up to test for compliance. Make sure that power setting runs that thing AT 100mW, +/- a couple single digits. Remember just because that thing can have the power adjusted and it has a certification number slapped on it..does not mean the rules exempt you or it from operating above 100mW just to compensate for losses in the 3 meter antenna which anyone with (no pun intended) well grounded common sense would recognize the rules do not allow for such adjustment to compensate for losses in an antenna system already known to have losses by design and by length limitations such as that in a mere 3 meter system for the MW band.
Good luck with the new station! Keep us updated!!
RFB
I will do just that, Sir. Operate within the parameters of legal transmission is the only way to go for me; especially since I fully intend to operate as a commercial LPAM would in a sense. Don't want to offend the natives. My format will be super clean and is targeted for an under served local audience within a 5 mile radius of my office. Shouldn't be a big deal, but you know how things can go for Part 15's.
"And KENC's ordeal was most likely started by some nearby licensed station uptight about a little bit of non-threatening competition from an independent station."
IIRC according to the agent's ( Binh Nguyen NW Regional Manager, BTW) own testimony. He claimed he was doing his usual thing, monitoring in his car, and heard KENC, which he hadn't heard before. IOW, he probably is aware of licensed AM stations in the area, and it caught his attention, so he tracked it down. He actually lives in and based out of Vancouver, Washington.
However, it still tends to look like Ken Cartwright believes a commercial station bent his ear.
Perhaps a combination of both monitoring and a complaint from a licensed station, or from a listener of a licensed station.
Sad how all that turned out. Is why I stress to the owners of that particular unit to not go assuming that because there is a power adjustment pot and an FCC certification number that it gives the green light to adjust that thing beyond the legal limits in an attempt to compensate for a 3 meter stick's inherent losses. Improve the efficiency of the antenna itself is good or improving efficiency of the transfer of that 100mW signal onto the antenna system..but to just crank up the power....well that is certainly asking for trouble.
More so since the FCC is well aware of that power adjustment pot and the fiasco with KENC. Then the most recent NOUO with those combined units crammed together on a rooftop..which is puzzling in of itself...but the same resulted...more signal in the far field than what should have been. No one knows if the units used had their power cranked up or not. Seems highly possible though.
What puzzles me about that unit is that it does not use any external loading coil or antenna system. It has its own internal torroid core and uses a common connection scheme for a CB whip. Now why would there be a need for a power adjustment pot to an antenna system integral to the entire design just to provide a way to compensate for that integral antenna system losses? Makes no sense. Seems more like a lure than anything because there is no way to improve upon a design that is integral to the whole and was certified using that integral antenna system.
Well I hope our new member has success with their new station! Its always good to see a new Part 15 operation come to life!
RFB
Good day, (RFB). I was reading your thread. Did you say there was a NOUO recently issued to an operator using multiple tx's on a rooftop? I saw a guy on Youtube recently who used multiple tx's on a rooftop linking them via cabling. Each unit increased the overall range of the other (Rangemasters) exponentially, by 6 blocks per unit, according to his engineer's calculations. He had (4) of them linked together. His overall broadcast range increased to 6 and 1/4 miles. Amazingly, his signal could be heard as far as 10 miles away during nighttime hours. It was faint that far out, but still impressive. He drove around town demonstrating the range of his tx's signal on Youtube. It was clear and loud. Oh well, that's all I have for now. Maybe I misunderstood your post. Please elaborate. Thanks.
Love this forum!
No sorry for the confusion. I was referring to another thread about the same NOUO and another member's post regarding the measurements and mention about having a number of the units tied together but clustered in very close proximity to one another, which would most likely cancel out most of the signal emitting from all of them, and that such an installation would most likely not give any improvement over a single unit on the rooftop.
Daisy-chaining the units is a great idea to expand the coverage if they are placed correctly. The units are designed to allow multiple units synchronized together to operate on the same frequency without the annoying beat frequency issue with two or more transmitters operating on the same frequency..but with their own oscillators running in "free" or un-locked mode.
Thanks for clear up. Read your posts often. Always seem to be on point and technically astute.
Thanks...
To RFB:
"Now why would there be a need for a power adjustment pot to an antenna system integral to the entire design just to provide a way to compensate for that integral antenna system losses?"
The power adjustment pot controls the DC voltage to the RF output transistor. This input power adjustment feature is provided to enable setting the input power to 100 mW for a range of load resistances. The load resistance is the sum of the coil loss resistance plus the ground resistance. The coil resistance varies by a small amount vs. frequency, but the main contributor is the ground resistance, which is unpredictable for individual ground systems. The input power will vary to some extent according to Ohms law, P=E^2/R. R varies with ground resistance.
The primary reason for the power adjustment feature is to allow adjustment to 100 mW input power for varying ground resistances. This has the side effect of enabling higher than legal power, but if you eliminate the feature, the "input power" can be crippled when the ground resistance is higher than some assumed design value.
Since the load resistance is the sum of the coil resistance and the ground resistance, the sensitivity of the input power depends on the ratio of the coil resistance to the ground resistance.
I gathered as much. Knowing the variances involved with different locations and system configurations, having the ability to compensate is in my point of view a good thing.
However adjusting power to a higher level is not the correct way to overcome ground system deficiencies...at least that is how I view it.
A 3 meter system, even with an elaborate ground radial system installed, will still have inherent losses no matter what.
There is no provision in the rules stating that increased power level can be utilized to compensate for those inherent losses and deficiencies. Those units are coupling to the CB whip with an internal torroid transformer equipped with tap points to maximize resonance of the limited length of the radiator. Naturally the ground system will play an important role.
To me it seems that instead of putting focus on the antenna ground system and improving it for greater efficiency, the fix would be to simply crank up the juice, which again anything beyond a reasonable level from 100mW is violating the rules. How can you justify going above the 100mW final input power stage law to overcome ground deficiency issues? It is still going above the legal limit no matter what the reason for doing so is. Hence in my book...the setup would be in violation if that TX was set above that legal limit. Granted maybe a couple single digits or so above probably would not be an issue..but that would depend on the inspecting agent.
Even with cranking up the juice, that does not resolve the problem, it just brute forces the signal through the system, but the antenna will still have the original problem of ground system faults. So what is accomplished with an increase in power level into a bad antenna system?
Perhaps the only thing accomplished here is the increased chance of being greeted by a field agent. At that point..it is all in the hands of faith and the agent that your system will pass.
Let me ask you PhilB...what would you do, or have already done in your units? Naturally you know the issues involved with a 3 meter antenna system and the many circumstances ran into with these systems. Does any of your units have power output adjustment capability...or do they have methods internal to maximize RF transfer efficiency which would co-work with an antenna system to further maximize that efficiency without a power level adjustment?
Again the rules do not say we can compensate for these inherent and intentional losses and deficiencies by way of increasing RF power level. Although I do see your point and I am very well aware of what is encountered with a 3m setup. Me personally I see no big deal with having a power adjustment..within reason of course.
But we cannot have our cake and eat it too and go around saying we adhere to the rules and then turn around in an instant and say exceeding the power limitation is ok to compensate for system losses because that adjustment ability is there, while still saying we are abiding by the established rule of law...100mW final input power.
Contradiction in my book. Plain and simple.
I just wish there was a provision in the rules for that purpose. It sure would make things a lot easier. But at that point...where does that provision put the upper limit point? When do you say "Ok we must set this upper limit at some point to prevent further levels above this point when we are already above the established level" and what would that new upper level limit be?
In other words, what if someone has an antenna system and ground system that is so junky that it would take levels of power considerably higher than a reasonable point, perhaps even much more than what the transmitter can provide already even with its power set to maximum?
RFB
As has been indicated, there are 2 provisions in Part 15 (and up north here in Canada). One, a field strength that is permitted, and aside from the difficulties in measuring that field strength, some sort of power output adjustment could be applicable to achieve that.
And then there is the 100mw input to the final stage rule, combined with limitations on the antenna/ground, where no such power adjustment (at least, above 100mw) would be allowable.
In the later Rangemasters, at least according to the documentation, I do not believe that you can adjust the power - they come standard with an auto tuning feature. I have one of the earlier ones, but tried to make sure that I stayed within the 100mw rule (both by that green light in the then-optional tuning module, which is not all that accurate, and meter readings at the specified measurement points within the unit, which are as accurate as you can possibly be).
To me, while I'm not a hardware and/or electronics technician (my major focus is on computer software/radio programming), this does not appear to be rocket science. Including if you're going to use the 3 meter/100mw portion of Part 15. You can't use a long ground wire which will radiate or a ground wire to a long mast, again, which will radiate - that's just attempting to get around the rules using safety as an excuse (I'm not justifying the rules, just acknowledging that they exist). The only legal installation that will work effectively appears to be something (with that 100mw input) mounted at ground level, with a short ground wire to a buried ground rod, supplemented by radials. And some audio processing which gives your signal a bit of extra punch (I use a Symetrix 421 and an Inovonics 222).
Anything else is entering into the realm of Inspector discretion. Now, if this is just a hobby, then that's fine; you can probably live with being told to cease and desist, while attempting to justify what you're doing to the bitter end. But if you're doing as some appear to be doing, and creating an actual, listened to station, known in the community, and even carrying advertising (which is a large commitment to that community) then you want to be as careful as possible to adhere to the rules that do exist today.
If a field agent has been to your neighborhood, triangulated and measured your AM or FM signal, and found it perfectly compliant, you would never know.
Very true..unless one was to be constantly looking for US Government license plates beginning with the letters FCC followed by a number.
They know exactly what kind of field strength should be measured at a given distance from the signal source. They do account for variables, but blatant signal strength is not an attempt to compensate for a bad ground or inherent deficiencies in a 3 meter stick.
As I pointed out before...I believe there should be some kind of provision for adjustment, say maximum 10 percent.
But that opens up a whole new can of worms doesn't it. What will the upper adjustment limit be? And what is to prevent from going even further up in power under the notion of compensating for losses even more? Where does it stop?
It wont. Thus we have the established limit put in place for decades now.
Better to abide by the rules than to take risks for the sake of compensating losses in an already inefficient radiating system that will not increase efficiency by merely turning up the juice.
RFB
I believe in having a power adjustment on the final of a Part 15 transmitter for several reasons.
1.) Part 15ers like to "tweak" things, and having a tweak knob makes the experience comparable to full power radio where adjustments ARE made and MUST be made to keep transmitters at the proper power;
2.) There are times when operating UNDER power might be desirable. For example, I just dedicated a less efficient transmitter to use during programs with "questionable language." It would be convenient to be able to reduce power on the main transmitter;
3.) Many full power stations have equipment capable of far more than licensed power, yet they are trusted to use it properly. I was at a station with a 25kW transmitter deliberately half-powered for the station's licensed power, 12.5kW.
4.) Religious doctrine holds that humans are given "free will" so that they are "in charge" of making the right choice in life. Therefore, transmitter design should "respect" this free will.
Great close to your argument. Basically, I need to and will stay within the rules with my new station. Will keep you all posted on our affairs, successes, failures. Appreciate your sentiments on the matter.