The recent server crash had cut off about three months of posts on this thread. Here is the the latest from Ken Cartwright on his website, www.kencradio.com .
Ken has turned off two of his three transmitters because they have been issued two NOUOs by the FCC. The one transmitter that has not been cited is still in operation. The Hamilton ground lead filter has not yet been approved by the OET, and so it cannot be used to make the two transmitters that have been shut down compliant with the rules. In the meantime, Ken is looking into using Community Internet Television for providing information for his community.
Thank you Ermi for the update on Ken Cartwright's situation.
I'm taking this opportunity to make a point that has been welling up for awhile, and one which I expect to make again.
The NOTICE OF UNLICENSED OPERATION carries with it the implication that the operator should have obtained a license, but didn't bother to do so. But what about the fact that the FCC would not have granted a license?
The logic is missing a dimension, or something. I hope someone picks up on that theme.
On April 8, 2010, Ken Cartwright was issued his second NOUO for KENC because of a transmitter mounted on a water tower in Sublimity, Oregon. This second NOUO was discussed on this thread, but the posts were lost because of the part15.us server crash in the middle of April.
I just discovered that a nearly identical NOUO was also issued on April 8 to the City of Sublimity, the owner of the water tower. This certainly must have put a lot of pressure on Ken. He not only has trouble with the FCC, but also with a mayor and a city council. He may not get permission to locate a transmitter on city property again.
Ken described his fight with the FCC as a "civics lesson" for others. The lesson I get out of this situation is, "don't give the inspector a hard time."
It's routine for the EB to issue separate NOUO's to both the owner of the property where the transmitter is located and the operator of the unlicensed station, unless the two are at the same location.
NOUO's continue at a brisk pace this year, but there have been no new ones for AM lately (thank goodness).
There actually has been another recent AM NOUO:
http://www.fcc.gov/eb/FieldNotices/2003/DOC-297432A1.html
This particular NOUO was not discussed on this website because of the server crash in mid-April, but it was extensively discussed on other Part 15 discussion boards. The NOUO was issued for the ground lead, but the field strength that was recorded (73,800 uV/m at 30 m) is also not possible for any existing Part 15 AM transmiter, regardless of the elevation of the antenna. Perhaps the field strength reported in the NOUO is an error. I have repeatedly said that field strength measurement is not an exact science (I get e-mails disagreeing with me--which I don't read anymore). There could have also been a transcription error.
Quoting from the FCC NOUO which Ermi cited above:
This shows that the ground wire was radiating and exceeds the 3 meter combined maximum length of all radiating elements permitted under Section 15.219(a).
This is not what part 15.219 a) states. It states the combined length of the antenna, transmission line, and ground lead (if used) combined must not exceed 3 meters. This quote appears to reflect a different interpretation which can be both good news and bad news for part 15 AM operators.
It is good news because if an installation is constructed such that only the antenna and ground lead (less than 3 meters total length) are radiating but the transmission line is not then the transmitter can be sited remote from the antenna system such as inside a building with an external antenna. It would, however, be difficult to determine tx. line radiation by a field test as cited since disconnecting the tx. line would render the station inoperable.
The bad news is that an installation which complies with the literal 15.219 a) requirements regarding combined length of the antenna, transmission line, and ground lead may not be in compliance if the audio and/or power feed lines are radiating.
With this post I am not arguing with the FCC's interpretation or application of this rule, rather am pointing out a possible pitfall regarding a "by the book" installation.
Neil
Fair Warning: I am about to vent.
Ermi Roos is exactly correct. This amount of field strength is simply not practicable with 100 milliwatts of input power regardless of the elevation of the transmitter/antenna. Liberty 1640's web site may give some insight into the false field strength readings. Field strength meters DO NOT differentiate between main radiated signal and signal from other additive sources. Anyone who has ever used a field strength measuring device that has been calibrated to a lab standard can tell you, reflected and additive signals are thrown into the cumulative readings. The more sensitive the equipment the greater the error. Even if the signal were viewed on a spectrum analyzer, the additive and reflected signals cannot be separated out in all instances.
http://liberty1640.com/station_location.htm
To clarify, multiple transmitters on the same frequency WILL cause additive signal strength in the over lapping areas, including other transmitter sites. This can be evidenced by the field strength when the ground wire is removed. Personally, this isn't an NOUO I would lay down and let the internet convict me of because of a public notice.
The FCC inspector here is reacting to a COMPLAINT of unlicensed operation. ANY GUESSES where the complaint came from? The smart money is on a licensed station operator or employee. These folks simply don't like the competition.
FM, social media and digital media are beginning to take away their, heretofore, exclusive listener "picking grounds". Part 15 stations are just taking advantage of what other media are doing on a grand scale. Licensed broadcasters need to pull their heads of their rear portal and see the bright new future for broadcasting just ahead. It does not include the 24/7 repeater radio pablum they have been feeding us ever since consolidation of ownership in the 80's.
And finally, here is another case of death by many paper cuts. The FCC inspector uses one of the sites of the multiple transmitter network to pick on. When this one clears the process, onto the next one, and so on. This is when you request a summary judgment before an administrative law judge at the commission.
Now is time to quit complaining about the injustice of the application of the FCC rules and begin to help the FCC define what the public wants out of the limited spectrum available. Just because folks think they have a license to broadcast doesn't give them sway with any court. All of those licenses BELONG to the government, period. No individual, company or organization owns a license. For reference, see the various communications acts used by the FCC to authorize their work.
I am frankly put off by the grousing and complaining done by some folks concerning the application of the rules by the government agency responsible for policing the radio spectrum which is in a public trust. Change it or get over it. Simply put, if you want to use radio spectrum, whether for business or hobby, you must use the same processes everyone else uses to use the same resource. It is because of the misuse of some people that the new LPFM rules forbids anyone who has been involved in unlicensed broadcasting from even applying for an LPFM construction permit or application for transfer to own an LPFM license. When will we begin to protect our own Part 15 micro power broadcasting interests?
Arguing with an inspector is like mud wrestling with a pig...It's fun 'til you figure out the PIG LIKES IT!
I feel better now.
Ken Cartwright just doesn't get a break! He just announced on his website, www.kencradio.com , that the FCC has assigned KENC to a licensed station, and he has to change his call letters. This time, he is not going to select a call sign starting with "W" or "K."
Added note: KENC, 90.7 FM, is at Estes Park, Colorado.
Ken Cartwright's new call letters are CCRN. This could be a station in Chile, but I suppose it doesn't matter. The access to his Internet site will also change to reflect the new call sign. Ken says that he is still waiting for a decision from the OET about the ground lead filter.
I suspect the OET decision on the ground lead filter will come just before HE-double hockey sticks (Stanley Cup language, yeah Black Hawks) freezes over...or the President figures out how to be President.
And a side note: Ken's website says the new call sign is CKENC. I am not debating, just saying. He must have changed his mind and sent you an email. I happen to like CCRN better anyway.
That's right. Ken deleted all references to his his previous choice of CCRN (standing for Canyon Community Radio Network). I would think that he doesn't have to change his website address to reflect the new call letters, but he says that he will, anyway. Maybe he will change his mind again. I think that a slogan, like "Canyon Community Radio," would be better than call letters.
I just noticed that WLOY, a well-known college Part 15 AM station on 1620 kHz in Baltimore, using multiple synchronized transmiters, has also been the call sign of a licensed station on 660 kHz in Virginia since 2007. Unlicensed WLOY in Baltimore has been broadcasting since 2003. They brobably checked to see if anybody else was using the call letters back in in 2003, but now a licensed AM station is using the call sign. WLOY in Baltimore is still using their unauthorized call sign. This may be because they have not received as much attention from the FCC as KENC.
Even if no station is using a particular "K" or "W" call sign right now, The FCC may be assign it in the future.
20-plus years ago the use of call letters for stations on the broadcast band were an important branding and packaging label. However, with the advent of internet streaming, social media and the use of image branding by radio stations, call letters have become almost passe'.
Stations use monikers like "The River", "Jack FM", "The Q" and others. The call letters are rarely mentioned except for the top of the hour FCC required station identification. The advent of the Arbitron PPM audience measurement system, call letter use has become just a government institutional inconvenience of the past. PPM measures most all program delivery platforms. Just imagine audience measurement with today's HD FM signals (HD-1, HD-2, HD-3...). They all have the same call letters. Confusing eh?
Using a phrase or name of 2 or 3 words helps listeners identify with who you are and what you broadcast; becoming more memorable than call letters. Now, put on your creativity chapeau and get busy. I'm just sayin'...
Call letters are a sentimental remembrance of the way radio used to be. Today, few stations make a big deal out of their calls; most downplay them. It's unclear to me how much of a factor the use of call letters by a Part 15 station is in terms of triggering an FCC inspection. On the other hand, I don't know why it should be such a big deal if a Part 15 station wants to use the call letters of a station in a different market, but that's the way the rules read. So if you do use calls, you have to constantly check to see if they are in use. One possible work-around is to use call letters that are relatively unlikely to be assigned, such as three-letter calls.
Given the fact that "real" radio stations hardly promote their call signs anymore, I have decided to stop using them on my Part 15 stations, at least on the air. My home station is now "The River" and my cottage station is "The Lake". Perfectly legit and unlikely to ruffle any feathers. And I'm sure those "calls" would be perfectly acceptable to any licensed station as well.
I do have one other thought for you hams out there: what do you think of the use of your OWN ham radio call sign on your Part 15 station? Legit? Not legit? Good or bad idea? If anyone is doing this, I'd love to hear your thoughts. I have a pretty nice ham call. 🙂