Well Neil, at least at some point the operator seems to have considered themselves a part15 AM.
Now, whether they intentionally crossed a line at some point where they knowingly went from part15 to basically small-scale pirate, or if they thought they were doing improvements to be able to cover the town but basically thought they were still part15.. That we do not know for certain. For that matter they may well have believed they were running strictly legal part15.
I believe the initial installation was 30 ft high, so we're pretty much definitely seeing at least some "long ground wire effect", though they were NOUOed for the field strength measurement. Initial range was reported by the operator at 3-4 miles in a hilly area with good signal and the station could be heard at least somewhat at 8 miles occassionally.
At least initially by their own account the operator had no prior experience with operating radio gear. So, while a range like that might get most of the regulars here checking their equipment and setup over very carefully, the operator may have felt they were simply getting good range.
Rather questionable as to whether that field strength could be produced by a legal part15 transmitter even with LGWE (Long Ground Wire Effect), so I'd wonder if some amplification of a definitely non-part15 nature was involved..
So far as the lack of first-hand info, well, read this bit from the NOUO carefully..
"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."
Any information they disclosed in public (like on the internet?) would also be used. So if they have any legal sense or have consulted a lawyer, most people in this situation will not be saying much, if anything. If they went on a forum and told how they "thought they could get by with ______", if that statement was found and brought into court as evidence, it would imply "willfull" and that they actually knew better (to give one example), which could result in the action being more severe. So any lawyer they spoke with (or even just common sense) would indicate that it would be best not to give out details.
Daniel
Glad to hear you aren't giving up the project. It looked like a really good effort with the community supporting/encouraging because the folks *want* local media. Obviously I read through the news article that I posted the link to, and I have to say that I was sorry to hear you had that bit of trouble since it sounded like things were going great.
Reading the bit about the folks coming up and knocking on the glass when they have a request reminded me of my own station. Smaller than yours (I'm on FM with the antenna indoors, so the range is about a house, maybe 2 if they've got a good receiver/antenna), but a few of the neighbors have kept me going with it as a hobby because.. well, they sort of count on it. But my very first regular listener was the next door neighbor who'd tune in when he saw the little red LED on the transmitter go on when it was sitting in the window. And if he was having a cookout in the backyard with friends, he'd stand under the kitchen window and yell requests.
Anyway, glad to hear you folks aren't giving up, that you took care of the problem and you're going to keep it going.
Daniel
by MRAM 1500 kHz
Sealerman, if you'd care to elaborate, there are a lot of folks here that would be very interested to hear of how you link several RangeMasters together into a net. That idea has been discussed at length; STL's from baby monitors, WIFI links, phone lines, etc. Is yours a true synchronized simulcast or do the others simply carry the same audio?
In your post it would appear that one bad apple spoiled the bunch. It would seem the FCC should be after the one errant transmitter, not the network unless you operate all under one umbrella small corp. Otherwise it would be as though someone relayed my station webcast on a pirate station and I'd be at fault? I wouldn't think so.
Is your webpage coming back? The link in the news article is dead.
Do you have control over transmitters other than your own that participate in your net?
I'm not paranoid but that doesn't mean there isn't someone out there trying to get me...
I just wonder if their mistake in using the wrong field strength reference would get tossed out if it went to court? Probably not,but nice to see they are humans and make mistakes too,LOL
Good luck with your system.
Regards,Lee
http://www.freewebs.com/wilcomlabs/index.htm
Great post Neil about the gross lack of real information in all the enforcement posts. In this case sealerman contributed no information relevant to the early content of this thread. ".. and someone else connected one( the one in question) and I wont get into that part." That part is exactly the information we would like to know. Did he connect the Rangemaster to a 10 watt linear? Did he use a half-wave dipole or 1/4 wave vertical? How highe was t he antenna? How long was the grond wire? ... and on and on. I assume sealerman doesn't want to get into it because the installation was not part 15 legal in some way. Without solid information, these actions just lead to a lot of speculation and paranoid hype.
I don't agree with your strict interpretation of the part 15.219 rule. The rule is too vague to interpret strictly. The rule doesn't define "ground" and it doesn't define a "ground lead" and the "if used" part is a real puzzler. We all know an antenna won't work without a ground, but the "if used" statement leaves open the possibility of using power or audio leads as an alternate ground path without having a strictly interpreted "ground lead". I suppose there might be a few strictly legal installations, but I think the vast majority would not be "strictly" legal. Every single indoor 100 mW transmitter would be illegal by a strict interpretation of the ground rule, and yet indoor transmitter have poor range and would never be in violation of the intent of either the FS rule or the 3 meter rule.
Those posts we have seen in the past saying things like "... I called the FCC to inspect my 100 mW transmitter mounted on top of a 50' mast and they came and gave their blessing" just add to the confusion.
I do firmly believe that we should reasonably comply with the rules and, most importantly, if we get an NOUO, we should shut off the transmitter and respond immediately to the notice. The ones that defy the FCC deserve what they get and cause problems for the rest of us by raising the specter of widespread pirate operation in the rank of important things for the FCC to address.
CB radio was, and is, a problem for the FCC. The FCC wanted to open a service for everyone to communicate by radio without license restrictions. They didn't envision the enforcement nightmare that resulted. If we want the FCC to continue to allow part 15 broadcasting, it is our responsibility to reasonably, but not necesarily strictly, comply with the rules.
PhilB
Rangemaster has the misfortune of yet another of its transmitters being the subject of an FCC enforcement action discussed in this Forum. The information in this thread, however, suggests that Rangemaster is not in any way to blame. It appears that one of their transmitters was somehow illegally modified to produce more power.
I wonder how much input power can be applied to the final stage of a normal AM1000 without any modifications. The transmitter has an internal adjustment for the user to set the input power to exactly 100 mW. In order for an exact adjustment to be possible, the available power should be somewhat greater than 100 mW. Does anybody know what the maximum available power is?
Phil and all,
Yes, the 219 rules are interpreted differently by different readers. I, too, have a problem when I consider that even a phono oscillator has unintended RF grounding through power and signal leads which may or may not have to be accounted according to the rules.
It may be too much to expect that accurate and complete accounts of FCC actions will be available from which we could get guidance as to what is acceptable. Lacking this, the only thing we have is our individual interpretation of the rules. Perhaps I am looking for a definitive answer which doesn't exist and that is part of the frustration that I expressed in my earlier post.
Thanks for considering my thinking on this.
Neil
"We all know an antenna won't work without a ground"
Transmitting antennas on cars work without connections to the dirt ground. Some hams even do 160 meters with mobile rigs. Some of the antennas they use for that look quite a lot like the short antenna with the big loading coil we talk a lot about here. Transmitters on aircraft do as well, not to mention satellites.
Sure, *now* aircraft use fairly high frequencies compared to AM BCB. But they didn't always, and I think they still use a band somewhere between 3 Mhz and 7 Mhz for "beyond the horizon" communications in some cases? Since the lower frequencies allow groundwave propagation which can go beyond line of sight horizon without actually relying on ionospheric "skips"?
So it's obviously possible. Whether it'd give as good a result or be practical is another matter. But possible? Sure. That's why I've always figured the "if used" clause is in there. Transmitter/antenna systems that have no direct connection to "dirt ground" have been around since at least the early "Golden age of radio".
Now, as to it being practical for part15 AM BCB? That's another question, but there's plenty of indications it would work at least somewhat. One of my first electronics projects ever back when I was a kid was a "wireless AM mic", one of Radio Shack's now-extinct "project boxes". It didn't work great, but it worked without a ground. Somebody else here once mentioned making an AM mic type project as a kid that they could pick up loud and clear from something like 30 ft away on a car radio while their father stood holding it and talking into the mic? No connection to dirt there either and the antenna was a bit of dangling wire.
So I would disagree so far as "We all know an antenna won't work without a ground".
Now, on another topic.. A couple Hamilton Rangemasters have shown up in FCC actions lately, but that isn't a reflection on their quality or legality as a unit. Just bad luck, it could as easilly have been homebrew or kit gear with the nature of the violations.
As far as the Wellsville station issue.. Knowing now that they had multiple transmitters running, might not overlap of the signals from multiple systems on the same frequency have been part of the field strength? So while obviously there was a problem with one of their transmitter (which has been corrected), it may not have been as *much* over power as the calculations here based on field strength suggested when we were assuming a single transmitter/antenna system.
Daniel
PhilB wrote: I don't agree with your strict interpretation of the part 15.219 rule. The rule is too vague to interpret strictly. The rule doesn't define "ground" and it doesn't define a "ground lead" ...
Part 15.219 doesn't define what is meant by, or required of an antenna ground, but physics does. A perfect r-f ground is one with an infinite current source capability for all r-f frequencies, always at a potential of zero volts. The physical earth is as close as we have to a perfect r-f ground fitting this definition.
Here's part of what Wikipedia says about this: "An electrical connection to earth as a reference potential for radio frequency antenna signals. ... An ideal signal ground maintains zero voltage regardless of how much electrical current flows into ground or out of ground. The resistance at the signal frequency of the electrode-to-earth connection determines its quality,.."
A true r-f ground (the earth) does not radiate. Unshielded conductors leading from the earth, and carrying r-f current do radiate. That is why the FCC includes the length of such conductors in the wording in 15.219, whether those conductors are called ground leads, ground wires, "lightning grounds," or anything else, and are used alone or connected together. Even the outside surface of the shield of a coaxial or shielded cable can radiate unless means are provided to prevent r-f current from flowing there.
When a short ground lead is connected from a Part 15 AM tx chassis to a long, "massive" ground wire/flapole/mast/billboard steel or whatever, then that whole assembly radiates -- often far more than the 3-m whip attached to the tx r-f output connector. These are facts of physics that need to be known and considered by Part 15 operators when they decide on their system configuration (and possible FCC risks).
We all know an antenna won't work without a ground, ...
There are many antenna configurations that need/use no reference to an earth (r-f) ground for efficient radiation, as Daniel mentioned. Unfortunately they are not practical for medium wave frequencies.
A Part 15 AM system will operate without any wires connected to the tx but the 3-m antenna (assuming it has an on-board power and program source). It won't have the coverage range that most "community broadcasters" want, but it may serve the goal of a user to pick up the signal on a nearby radio, which probably is closer to the purpose of allowing "Part 15" uses in the first place.
If we want the FCC to continue to allow part 15 broadcasting, it is our responsibility to reasonably, but not necesarily strictly, comply with the rules.
Of course this leaves the decision as to what may be reasonable up to each person to decide. People need to understand the rules before they can make a decision about whether or not they will "reasonably" follow those rules. Understanding them takes some technical background.
//
Hi, again I only posted here to let people know what we are about.. As the FCC Agent said we obviously werent trying to hide anything.. We have a storefront right in the middle of town with a big sign hanging out front.. We have been in the paper several dozen times about this station and all that it provides the community.. Not jsut the radiopart but the live video feeds that go along with it. We have done local parades, games, council meeting....ALL LIVE ove the Internet.. People love it because they dont have to leave their house. We dont make any money but as long as the donations keep coming in, then we arent out of pocket either.. and we have a great time doing it.. these guys do the games and jsut have a lot of fun.. we upload the videos after the games to google and people can watch the archives as many times as they like. So yes, we did step out of bounds on a transmitter that WASNT a rangemaster.... one was from somewhere else and apparently was not part15 compliant.. The fcc agent again was very nice and inspected everything and all was asked of me was to come into compliance..As far as having multiple rangemasters.. I have one in each town... small towns.. but close together.. I have a ROKU internet radio conenected to our internet stream and that actually feeds the transmitters. so its a pretty simple setup.. and works..
Multiple Transmitters can be used on the same frequency as long as they are crystal controlled and not to close together. The trick is to get the audio synchronized, if there is just 100 or 200 ms audio difference it’s not to noticeable as someone drives between coverage cells but more then that then you can hear echoes. The phases of the RF carriers will free run against (which means you will get a short zone of flutter in-between the two transmitters) each other but as long as the transmitters aren’t to close together then it usually isn’t a problem.
Rich,
Thank you for your thoughtful and incisive determination of the definition of a ground system. Personally, I get it. I have just returned from the NAB Convention in Las Vegas. And another definitive description of an external ground, where helpful for the untried folks to Part 15, is straying away from the overall issue of FCC compliance with some of us. This violation was for using a "non-compliant transmitter". The inspector was respectful and helpful. He, no doubt, added to the learning experience and growth of the learning curve for the local community Part 15 station.
Dissecting Part 15.219 one more time for the troops is, in my view, unproductive. However, I do enjoy reading many of your offerings on this board. Let's expand our thinking by other subjects that are on the plate of a failing radio broadcast industry. And oddly enough, I didn't hear one person discussing ground systems at the NAB. The number one issue was alternative media. You know, internet radio, satellite, pod-casting, even local community trouble makers; read low power unlicensed Part 15 radio stations. Most of the broadcasters I talked to consider Part 15 community radio efforts as competition even if they don't make a buck. They take away potential listeners.
As humans we learn from our mistakes. And the recent involvement by the Senator from Nevada to make sure the "pirate" radio station in Parumph, NV. has an STA has shaken the FCC and the broadcasting industry to the core. I didn't speak to one broadcaster who didn't, at least, know of the story.
Once again, thank you for your contribution. Let us all move on to the seminal issues that move Part 15 and other broadcasting forward.
Marshall Johnson, Sr.
Senior Pastor, President
Rhema Christian Fellowship, Inc.
Rhema Radio - The Word In Worship
AM 1660 - FM 93.5
http://www.rhemaradio.org
Marshall Johnson, Sr. wrote: Dissecting Part 15.219 one more time for the troops is, in my view, unproductive.
Sorry, Marshall, but my belief is the opposite. That is based on the continuing comments on these boards, and from the websites of Part 15 AM tx manufacturers that deny/minimize the demonstrable, physical reality that long "ground" conductors always radiate (and usually more than the 3-m whip), and extend the radiating length of the antenna beyond 15.219.
Wouldn't a reasonable person wanting to be legally covered by Part 15 want to know this before deciding what to install?
My comments about these issues may cause public stress to some "Part 15 AM" operators with such installations (not you, I'm quite sure), who therefore might want to suppress this reality. That we can all understand.
And oddly enough, I didn't hear one person discussing ground systems at the NAB.
That isn't at all odd to me, and I've attended more than 35 NAB Conventions while employed for 39 years total by RCA and Harris Broadcast Divisions (and another NAB after I retired).
Licensed AM broadcast stations install/use extremely effective r-f grounds as part of a very efficient antenna system. The FCC mandates this, so it is of no concern to licensed broadcasters or the NAB once the station has been installed and granted FCC program authority. AND those r-f grounds aren't necessarily comprised of 120 buried radials of 1/4-wavelength or more, each.
Rich
//
While Marshall raises a good point about feeling a bit like "been there, done that," we do get three or four new members each week and who-knows-how-many unregistered visitors every day.
Some of those folks are learning about part 15 for the first time. Rich's posts are often the first time new users and newbie visitors read about '219 except in an FAQ. Having this info being part of a current thread gets peoples' attention, too.
Pahrump is a great example of how "out of control" the broadcast industry must feel right now. At one time the NAB mambers had a virtual monopoly on certain categories of entertainment. Most consumers didn't realize 'portable personal audio' WAS a category - we thought it was "radio."
Then, from 8-tracks and cassettes to cell phones and digital players, the NAB membership slowly lost automobile audiences. My generation was lambasted for walking around with a "transistor radio" stuck to one ear, but from the Walkman to the iPod to my scanner, the NAB members have lost my ear to all the new sources of information and entertainment.
Then the NAB members cut costs, cut quality, increased advertising minutes and started copying each other until it was all the same "Sunny" and "Jack." Like the RIAA members who didn't understand downloads and simultaneously raised prices and lowered quality, the NAB membership is (in my opinion) in deep trouble.
I think the ultimate irony is, as Marshall says, that the NAB membership has sunk to the point of desperation that they consider a Part 15 experimenter to be a threat. I have heard that this is the case, too. Poor NAB members, that's got to be a hard way to live...
We're sort of off topic for "another Part 15 AM'er get's nailed" but it turned out not to be a part 15 operation anyway, so we've got that going for us 🙂
Experimental broadcasting for a better tomorrow!
The ground wire issue apparently is an important one. The one church got cited for it and all. Apparently in this case it wasn't the problem, but a transmitter that was out of compliance was.
I'll agree, it does get to being a tiresome discussion to have over and over, but if someone trying to be legit part15 got cited for it recently, then I'd say it counts as pertinent and current. I admit though, some days it seems like you could ask opinions of whether a grey, black or plain metal case for your transmitter would look cooler, and *somehow* several posts about the groundwire would sneak in there. LOL
It's not like 15.219(b) is all there is to compliance, either. Like I don't recall seeing many mentions of how anyone measures the input to the final RF amplifier to make sure they're legit on the 100 mw limit, or different ways to check modulation to avoid overmodulation causing "spattering", and etc.
I have to agree though that it seems kind of ludicrous when commercial licensees are worried about losing listeners to oprations as small as part15 stations.
Daniel