Yes, the ground issue has been discussed at length, but I think it's worthwhile to continue the conversation. Here's my take on it.
I don't think anyone is really denying that the ground wire radiates to some extent. However, 15.219 does not limit the length of the "radiator" -- it limits the length of the "ground lead (if used)" plus the other things which are straightforward.
There is science, and then there are regulations. In my real life, I deal with regulators all the time (our state's Department of Water Resources and Department of Environmental Quality). You quickly learn that actual science is often secondary to the agency's interpretation of the language of the rules. Everything hinges on the FCC's interpretation of "ground lead," not whether the ground lead actually radiates. If someone at the FCC determined that the intent of 15.219 was in fact to limit the total length of radiator to 3m, most elevated installations would be precluded.
Chuck
Daniel,
I could go into this if you want. The input power for my SSTRAN unit as I measured it is 93 mW. There is little doubt from me that if built according to instructions, this unit will be compliant in this regard. The circuit is well designed and is not adjustable in terms of power.
On the other hand, the power input to my Ramsey AM-25 is too high to be compliant regardless of the bias adjustments.
I have posted information about this here and on another board and there was very little interest. I suppose that is because it is easier to measure the ground length than the power.
Neil
I was trying to avoid any more discussion on the ground issue myself, as I have also grown tired of the repetitiveness of it and the predictability of most folks comments.
I would like to make what I hope is a constructive suggestion. SCWIS, why don't you take the most succinct postings about the ground topic, making sure to show all relevant points of view, and compose a FAQ or sticky posting. This way, all visitors to this forum will be able to find the information and the regulars won't have to rehash this topic until doomsday.
Sealerman said that an FCC agent who came to see him gave him information about how to get a broadcast station license. It's astonishing to me that such a discussion ever took place, since it is practically impossible for people without vast resources to get such a license. First, it's necessary to apply for a station construction permit. Real estate has to be acquired, buildings have to be built, equipment has to be installed, an antenna system has to be erected...The expenses are enormous, even for a "low-power" station, which, for AM, is not less than 250 watts.
Now that Sealerman has been issued a NOUO, he may have yet another obstacle to licensing to overcome, which is section 73.4280 of the Rules, "Character Evaluation of Broadcast Applicants." This Section does not, itself, explain what "Character Evaluation" is, but gives several references to documents that explain the subject. Character evaluation by the FCC examines "misconduct that demonstrates the licensee's or applicant's proclivity to deal truthfully with the Commission and comply with its policies." From what I have seen, this rule has been applied mostly to convicted felons. However, Section 73.854 deals specifically with anyone who has ever been involved with unlicensed operations (either individually or with others) in violation of Section 301 of the Communications Act of 1934. An applicant for an LPFM station license must give a sworn statement that neither he, nor any other party to the application, has ever been involved in any unlicensed operations.
If a licensed LPAM service is ever created, a rule similar to Section 73.854 will probably also apply. Very likely, the FCC fears that low-power FM or AM attracts former pirates.
I think it's a good idea to strictly adhere to the rules to avoid any FCC enforcement actions. A clean record increases one's options.
mojoe wrote: SCWIS, why don't you take the most succinct postings about the ground topic, making sure to show all relevant points of view, and compose a FAQ or sticky posting.
Because no one reads those, they just go right to the forums and start a new thread 🙂
Seriously, however, that is a great suggestion for a whole bunch of topics that are floating around in our content. We have great content on topics like grounds, loading coils, automation, free content for broadcast and more.
We've done this in the past with the Wentzel and Vectronics transmitter schmatics and the Wild Plant DJ in our book section. THose pages are very popular. Good reminder, mojoe.
Ok, I'll get to work!
Experimental broadcasting for a better tomorrow!
This line from the NOUO, "The field strength of the signal on frequency 1620 kHz was measured at 23,600 microvolts per meter (uV/m) at 75 meters, which exceeded the maximum permitted level of 250 uV/m at 3 meters for non-licensed devices." is so funny I had to get a log on and post some sort of comment. This FCC notice begs for rebuttal, but in order to do so you actually have to have what you believe is a part 15 compliant station. In other words, if you get one of these, then answer within the 10 days, and set forth facts in affidavit form that demonstrate your operation is authorized under FCC rules. FCC inspectors can be in error, as can anyone.
Also; All the forum talk about "ground" is pretty much a waste of time. When and if you get cited on a "ground" issue, then litigate. Get help on this forum from RF techno geeks, and make your arguments in your 10 day response to the letter. When you get no response, then ask for legal help on this forum, from someone with FCC administrative law. It is clear to me nothing can comply with the most strict ground interpretation except a battery operated box with no audio input that is not sitting on an electrically conductive support. Doesn't sound like the Philco phono oscillator I had in the '50s. Lots a luck out there.
Emwave,
Welcome aboard. Yes, it does appear that the FCC inspector goofed when citing the 250 uV/m limit for an AM operation. The offender might get this dismissed on a technicality and it would certainally be wise for him to respond and pursue this.
In general, though, how wise it to approach the FCC rules with the idea that one can argue one's way out of a citation? Does this imply that it is OK to operate beyond the rules because one can then "litigate"? Maybe I misinterpret what you wrote?
We all can operate with whatever antenna, power, and ground we want if we comply with part 15.209 which seems like a simple approach. The problem is how does one without the means to do so verify the field strength? In an attempt to make the compliance verifiable by a competent hobbyist, the FCC wrote 15.219. This is now causing problems with interpretations whereby justifications are being expressed by posters here for not following what this part says. I note that no one I recall ever questioned the interpretation of the 100 mW. power limit and few have questioned the antenna length. Why just quesiton the ground lead?
It all comes down, in my opinion, to a question of range. Both part 15 parts cited here are intended to restrict range and when things are done to increase range beyond what could be considered needed for personal use it is not surprising that the FCC notices. Indeed, range is not mentioned in the rules but that is the intent as I see it.
Neil
"In general, though, how wise it to approach the FCC rules with the idea that one can argue one's way out of a citation?" It is wise to set forth the facts and proper interpretation of rules and law. Field staff may not have things right, and by writing a reasoned response you may get a determination that you are correct.
"The problem is how does one without the means to do so verify the field strength?" Field strength is not specified in 219 & 209 does not apply. Notice ->" (a) Except as provided elsewhere in this subpart, ..."
Intent can be a factor, but more frequently than not intention scoots out the window and the language of rules and statutes and precident will be applied.
I spent a lot of last night writing a petition to get an FM app. that was bounced by staff. I think staff was wrong. I hope to get my friends app. reinstated. So they give you 10 days to respond. Unless you know you are violating the rules, why not respond?
You ask why just question "ground lead"? Because "ground lead" is not defined thus the rule is vauge. If the transmitter sits on a metal table, is the table a "ground lead?" Or if the transmitter has an external power supply, is the wire to the transmitter a "ground ;ead?", if the transmitter is plugged into a wall outlet is the ground in the 120 VAC house wiring a "ground lead"?... etc. etc. Of course if one DOES question an interpretation, such as a definition of "ground lead" and gets a final decision you don't like, well... everyone is stuck with it. But at least you get an answer. By the way, "final decision" might mean going up to the Supreme Court.
Emwave,
Thanks for getting back to me about my post. We seem to differ on the point about 219 and 209. My take is that either can be used. As you quoted is says " (a) Except as provided elsewhere in this subpart, ..." rather than saying "except as required". As I read this, 219 is allowed in lieu of or as an exception to 209. Before the rules were revised, the preamble phrase to 219 read something like "In lieu of meeting the requirements of 209...." (quoting from memory, can find it exactly if you want).
Regarding the vaguaries of the ground, you presented very good information. Even the old Philco phono oscillators with the built in 78 rpm turntable had an RF ground through the power cord and thereby the building neutral. I had one and that was my into to part 15.
Someone told me that this ground issue may just be a "dusty tailight" to be used if an inspector wants to. I don't know if that is the case, but it is possible. On the other hand, it is well established that the ground conductor radiates a signal and adds to range. If the rules are revised to clairify what seems to be a matter of descretion we may not like it at all.
Also, I agree that there is no harm in responding defensively to an FCC communication. My point is that the ability to challenge a citation on technical terms is not a wise excuse to use to bend the rules.
My experience with govt. agencies has been mostly positive and I found that one gets treated the way one treats the staff. I don't always get what I want but my dealings have not been as confrontational as is commonly thought about such contacts (and that includes the State Tax Dept. and the IRS).
I hope your app. is resolved to your satisfaction.
Neil
I don't think that pointing out the FCC's error will help Brown/Sealerman much. It appears that Sealerman has already conceded that the transmitter had too much power, so Section 15.219 is not applicable. Section 15.209 actually specifies a more restrictive field strength limit in the AM broadcast band than the incorrectly-cited FM limit when it is extrapolated to 30 meters.
It seems from his posts that Sealerman's defense is, "It wasn't me." He says that some rogue individual not associated with him or his group switched transmitters on him. It appears from the information in this thread that the premises in which the offending transmitter was located were under Sealerman's control. If that is the case, the claim that somebody else is responsible sounds rather weak.
I think that about the best that Sealerman can hope for is that the FCC officials actually are nice guys, like he thinks, and they decide not to expend any more precious public resources on him, and terminate the investigation.
First: I am confident 15.209 (a) does not apply. It says, " (a) Except as provided elsewhere in this subpart..." and thus 15.219 takes over. So, the 100 MW input limit etc. applies in the MW AM broadcast band.
As for the idea someone who gets cited on the basis of "ground" and wants to get a definition of what that means, I say go for it. As I said, you may not like the results, but you might end this endless "ground" torture. And just a reminder; response to a citation can send the issue up to DC staff, and then you can keep on truck'in up to the Commission and from there to court. My hands are full enough thank you, but in my life I have sometimes appealed and got changes at the FCC. In the alternative you can petition for rulemaking to change the rules. Happens all the time.
Emwave,
Well, I guess we may need to accept that we do not agree on this.
The phrase "except as provided" to me means that 209 applies except when the provisions of 219 are met. If the provisions of 219 are met then 209 field strength limits do not apply; that is the "except as provided" which means there is another way to be compliant. It does not mean that 219 overrules or preempts 209. Either one is OK for compliance.
Consider that if 219 supersedes 209 as I think you have suggested then why wasn't 15.209 deleted?
Neil
OK Neil. I agree with you, in that if you have a 500 foot tower and 1 kW transmitter and for some wierd reason are within the field strength limits of 209 then the operation should be legal per 209. lol On the other hand, if an operation meets the requirements of 219, then the field strenth limits of 209 do not apply. The other question? 209 covers more spectrum, so it would not be deleted in any case.
One also has to remember that part15 on the AM and FM BCB governs more than just hobby transmissions. Every modern reciever has a note somewhere on it explaining that it complies with part15 of the FCC rules. This is because they transmit a weak signal as part of their operation, which you can actually pick up with another reciever nearby. Since 3 m antenna/feedline/groundwire obviously is not in use with the typical clock radio that has an FCC compliance label, and they don't need anything near 100 mw for the part of the receiver that needs that tiny transmitted/radiated signal, there have to be guidelines to cover that in part15 as well.
Daniel
Ok, sorry for the confusion.. I didnt mean to make it "sound" like someone slipped a transmitter in on me.. We were trying differant things and used one that wasnt so part15 turns out.. The FCC and staff were all very nice and this has been settled.. and we are now in compliance using only Rangemaster transmitters....the sites and transmitters will all be back up very soon.