Here is where we're at currently.. This was the press release that we sent out today.. I think it speaks for itself. This is a good forum and thank you for speaking for me and letting me speak... Kenc
KENC Comes to an end: November 19, 2009
Ken Cartwright- KENC Community Radio
KENC, AM 1620 KENC Community Radio will cease broadcasting on it's 3 transmitters effective November 21 at 5:00 PM PST. We will stay on line at www.kencradio.com but local programming will be reduced.
Recently a FCC inspector, Binh Guygen, out of Vancouver Washington paid Ken Cartwright owner of KENC Community Radio a visit. Based on his field strength meter readings, he found the primary Low Power transmitter at 429 N. 3rd. Ave. Stayton, OR out of compliance with the FCC code part 15.219 regulating low power transmissions... The transmitter is a Hamilton Rangemaster 1000, and is one of three installed and in operation in the Stayton area for community radio. At issue was the grounding system used for the primary transmitter. In order to comply the ground feed was cut and the transmitter was retuned to be in compliance. The original complaint was based on a local complaint that KENC had too much range for the station. We have filed a freedom of information act notice with the FCC in Washington DC to determine who filed the complaint. We have also been in touch with a FCC attorney in Washington for help.
Now that the transmitter has been changed with no ground, we have no range, but that's not enough for the FCC. They now insist that the transmitter emit no more than 14.2 Micro volts at 30 meters.. Good for less than one block. When I asked the FCC inspector if someone had complained, he said no. When asked if our signal was interfering with any other broadcast signals in or out of this area, he said no. I then asked what he would like me to do as I followed all the rules in installing, tuning and operating the equipment and the radio station. He said the ground rule is specific in that it only allows 3 feet of ground, meaning if the transmitter is on a 40' tower, which it is, the ground lead can only be 3' feet long. He cited a chapter in the FCC guide that we were not aware of.. We have satisfied that issue by removing the ground lead and we are tuned to exactly 100 milliwatts (1/10th of a watt).. Now the other issue of 14.2 microvolts at 30 meters we can't comply with.. A field strength meter capable of reading that small measurement costs $6,000 to $8,000. I called Michael Brown Radio services in Portland about contracting for his services to come down and give us a reading with his equipment. He quoted us $400 to do that, but said that it would be useless to us if we have to comply with that voltage reading, suggesting that you couldn't hear us across the street as that is such a low reading. So by not being able to comply, we are forced to shut the transmitters down or face a $10,000 fine and forfeiture of all our equipment. And if we do comply, we won't be heard.. Until we get this issue resolved we will cease transmission on November 21, 2009 @ 5:00 PM.. This brings Community Radio to an end in Stayton for now..
Ken Cartwright
11-19-09 503-769-2778
this says it all.....
Now that the transmitter has been changed with no ground, we have no range, but that's not enough for the FCC. They now insist that the transmitter emit no more than 14.2 Micro volts at 30 meters.. Good for less than one block. When I asked the FCC inspector if someone had complained, he said no. When asked if our signal was interfering with any other broadcast signals in or out of this area, he said no. I then asked what he would like me to do as I followed all the rules in installing, tuning and operating the equipment and the radio station. He said the ground rule is specific in that it only allows 3 feet of ground, meaning if the transmitter is on a 40' tower, which it is, the ground lead can only be 3' feet long. He cited a chapter in the FCC guide that we were not aware of..
[end quote]
something stinks here. get a lawyer. i don't believe for one second that someone didn't complain i do believe that you were not causing interference.
we need details on the two sites that he passed and details on the site that he failed.
and if he passed two of the sites why not run those sites.
when i DO setup my part 15 am i am going to keep a digital recorder with a lapel mic on me during the whole visit.
and i recommend this be the procedure for anyone. and get them to state their names and FCC badge number or employee number.
then take the whole deal to a transcriber who is a notary public and have it transcribed and notarized.
this way if they say anything stupid you have then by the gonads and they can't worm their way out of it.
More conversation can be found over on the Portland Radio Forums on this topic:
http://feedback.pdxradio.com/topic/kenc-1620-stayton-nal
it's worse then i thought. not only are they holding you to the part 15.219(b) limits it looks as if they are also holding you to Part 15.209 as well.
so if i mount my Rangemaster 2 Ft above ground level (legal with a 102 inch whip) and pound a ground rod 8ft in the ground and attach a ground lead as well as tune the final to 100mW input i would still be in violation.
i would still be in violation because i have a high water table here and a small stream outback which allows a field strength that is above those in part 15.209.
that is what i am taking from this bust and the wcbo bust.
looks as if it's over folks.
i would say if you ran carrier current on the neutrals and happen to get good range while still radiating within the limits of part 15.209 then they would find a way to violate you.
we have the best FCC that NAB lobbyists and Clear channel could buy.
they are certainly getting their bribery dollars worth.
I hope this Isn't the beginning of the end for part 15 radio.
kinda makes me glad I'm on part 15 FM, only 1 set of strict rules for FM.
But i also run an AM operation. I would hate to lose it.
Very sorry to see your station go down. The best suggestion I can give you at this point is to form an NPO of some type and fill out the application forms for LPFM license. The U.S. Senate looks like it's in the final stage of passing the new Community Radio Act, which will allow many more LPFM stations to come aboard.
If I were in your shoes, I'd get everything ready to submit as soon as the next filing window opens. That means the location and engineering specs have to get done ASAP. Then if your paperwork is in order, hopefully they will issue a Construction Permit and you can build the new antenna and get a decent FM transmitter. LPFM Community Radio allows up to 100 watts, which, if directional engineering suffices to keep the signal from interference with existing stations, ought to give more than enough coverage for your area.
Since you already may have enough programming, you could just move it over.
Canvas your listening community for support ... I'll bet they will help.
It might take a year to get back on the air, but you'll have a license, ethereally supported by many in Congress who have gotten behind the new well-written bill.
Another thing ... I don't know your community, but there is also the possibility of building a member-owned community Wi-Fi center. Means anyone in your community could have wireless internet for maybe $10 -15/month. With the new crop of netbooks and web phones, it means your broadcast could be very viable just on the internet ... just another thing to investigate.
Wishing you the very best ...
I don't think this agent understands the rules. Part 15.209 spells out the General Radiated Emission Limits. However, Part 15.215 states:
"Sec. 15.215 Additional provisions to the general radiated emission limitations.
(a) The regulations in Secs. 15.217 through 15.255 provide
alternatives to the general radiated emission limits for intentional
radiators operating in specified frequency bands..."
The key wording here is "alternatives". Part 15.219 is an alternative to 15.209, meaning that if you meet 15.219, you do NOT have to meet 15.209. I'm sure this is how the Rangemaster was certified...I doubt it would have met 15.209, so how did the FCC issue its certification? They certified it under 15.219.
Unfortunatley, a group has to be an NPO for at least two years prior to applying for an LPFM license. The window will probably open well before then.
Another issue is that KENC received an NOUO, which at present, disqualifies the applicant from becoming a licensee.
Not trying to rain on anyone's parade, but these are the facts. Sad but true...
For Part 15 AM, it is necessary to comply with either Section 15.209 or Section 15.219 rules, but not both. Section 15.219 has no field-strength limit. In practice, A 15.219 installation at ground level can easily have a field strength of 2000 uV/m at 30 m. With an installation elevated 3 feet, the field strength might exceed 3000 uV/m at 30 m. The inspector told Ken C. that an elevation of 3 feet is permitted (I would like to know what FCC document the inspector referred to that allows three feet of elevation). A 15,219 installation, even at ground level, has much more field strength than is allowed by 15.209 (which is 14.2 uV/m at 30 m).
The KENC installation, which was elevated 40 feet, had a measured field strength of 4000 UV/m at 137 m, which corresponds to over 18,000 uV/m at 30 m. This is what gave Ken C. a range of between 1 and 2 miles. A field strength of 2000 uV/m at 30 m will give a range of only about a quarter mile.
Even with the ground lead disconnected, the FCC inspector was apparently still not convinced that the elevated transmitter was compliant with Section 15.219. Maybe he considered the audio and power cables to be "ground leads." This is probably why he specified the 15,209 field strength limit of 14.2 uV/m at 30 m (which gives a range of only about 15-20 feet!).
To respond to Ken Norris, why not build a community wireless Intranet (with an optional connection to the Internet, if desired). You're allowed multiple access points and up to 1 watt of power in the 2.4 GHz band with an omnidirectional antenna (more, I believe, with a directional antenna) according to Part 15 rules. I've often thought of doing something like this on the little island that I'm located on (just to the north of Ken - Bowen Island). One big advantage is that you're not paying for broadband services; another is that you could support a whole heck of a lot more users than with broadband (where the limitation, at least in Canada, is upload speed to distribute the radio station content).
To respond to Ken Norris, why not build a community wireless Intranet (with an optional connection to the Internet, if desired). You're allowed multiple access points and up to 1 watt of power in the 2.4 GHz band with an omnidirectional antenna (more, I believe, with a directional antenna) according to Part 15 rules. I've often thought of doing something like this on the little island that I'm located on (just to the north of Ken - Bowen Island). One big advantage is that you're not paying for broadband services; another is that you could support a whole heck of a lot more users than with broadband (where the limitation, at least in Canada, is upload speed to distribute the radio station content).
been suggesting this for years. you are allowed 4 watt erp, 1 Watt into 6db antenna point to multi point mode.
ptp mode you are allowed 200 watt erp. believe you need to drop your power 1db for every 2db of antenna system gain.
this applies to 900 MHz, 2.4 G Hz and 5.8 G Hz.
Considering the work and expense it would take to establish a multi-point wireless net, I'm not sure there would be an advantage unless you can have broadband with it as well.
How, for example, would you access a wireless intranet from a webphone?
Considering the work and expense it would take to establish a multi-point wireless net, I'm not sure there would be an advantage unless you can have broadband with it as well.
How, for example, would you access a wireless intranet from a webphone?
I'm curious about FM range under Part 15. I know of no one who can get more than 200 ft. at the outside. After that it goes away right quick.
more and more phones and devices are including wifi clients in them.