Leagality of Kits Issue from the FCC OET...
:DOk here goes... WE do alot of work here at Boeing with the FCC Office of Engineering anf Technology... therefore I've got contacts here which gave me the Chief of Engineering and Technology; Kassem Walid, at the FCC.... now the letter below decribes what I wrote to Walid Kassem:
Hello, I am inquiring about a kit used for AM broadcasting and the kit's spec are 100mw to the final stage with the included antenna of 3 meters and the ground....
Now Part15 Rules 15.3 indicates "(p) Kit. Any number of electronic parts, usually provided with a schematic diagram or printed circuit board, which, when assembled in accordance with instructions, results in a device subject to the regulations in this part, even if additional parts of any type are required to complete assembly."
and Part 15.219 indicates:
Sec. 15.219 Operation in the band 510-1705 kHz. (a) The total input power to the final radio frequency stage (exclusive of filament or heater power) shall not exceed 100 milliwatts. (b) The total length of the transmission line, antenna and ground lead (if used) shall not exceed 3 meters. (c) All emissions below 510 kHz or above 1705 kHz shall be attenuated at least 20 dB below the level of the unmodulated carrier. Determination of compliance with the 20 dB attenuation specification may be based on measurements at the intentional radiator's antenna output terminal unless the intentional radiator uses a permanently attached antenna, in which case compliance shall be deomonstrated by measuring the radiated emissions.
Now does this mean as long as I buy one kit, build it under the manual for assembly and set it according to the above specs... am I legal to transmit under Part15 Rules?
Please indicate where I would be violating the rules if any?
Thank you
Nicolas Rios
Fuels Systems V22
Boeing Helicopters
610-591-3721
Now this is the Chief of Engineering and Technology response:
From: OET Generic account [[email protected]]
To: EXT-Rios, Nicolas
Subject: Response to Inquiry to FCC (Tracking Number 621612)
Inquiry:
Hello, I am inquiring about a kit used for AM broadcasting and the kit''s spec are 100mw to the final stage with the included antenna of 3 meters and the ground.... Now Part15 Rules 15.3 indicates (p) Kit. Any number of electronic parts, usually provided with a schematic diagram or printed circuit board, which, when assembled in accordance with instructions, results in a device subject to the regulations in this part, even if additional parts of any type are required to complete assembly. and Part 15.219 indicates: Sec. 15.219 Operation in the band 510-1705 kHz. (a) The total input power to the final radio frequency stage (exclusive of filament or heater power) shall not exceed 100 milliwatts. (b) The total length of the transmission line, antenna and ground lead (if used) shall not exceed 3 meters. (c) All emissions below 510 kHz or above 1705 kHz shall be attenuated at least 20 dB below the level of the unmodulated carrier. Determination of compliance with the 20 dB attenuation specification may be based on measurements at the intentional radiator''s antenna output terminal unless the intentional radiator uses a permanently attached a! ntenna, in which case compliance shall be deomonstrated by measuring the radiated emissions. Now does this mean as long as I buy one kit, build it under the manual for assembly and set it according to the above specs... am I legal to transmit under Part15 Rules? Please indicate where I would be violating the rules? Thank you Nicolas Rios Fuels Systems V22 Boeing Helicopters 610-591-3721
Response:
Yes, It is legal to transmit under part 15 Rules with a kit (used for AM broadcasting) that you build under the manual for assembly and set it, which meet the specification.
Now if anyone wants the original email to Walid Kassem and the return email from The Office of Engineering and Technology... please write me an email at [email protected] and I'll forward the email.... I KNEW the kits were legal!!!!
<< I KNEW the kits were legal!!!! >>
I always thought so and have pressed on with a kit. I should have read the regs instead of listening to the naysayers in the other camp. Their negative talk got me to wondering.
The FCC is only concerned with what is radiated. Over the decades, I've known engineer owners who have put some MacGyver stuff on the air, both AM and FM -- and they got licenses. Heck, for a long time, commercial TV video recorders didn't meet specs, but that was all that was available for a long time. So the FCC let those pass.
But the FCC may look harder at an installation that had not been type approved, should there be a question regarding its operation.
Many thanks, Radio Pilot, for your public service in this matter.
Bill in SE Texas
Thanks Bill...
Unfortunately even with concrete emails from the Above person at the FCC... those that believe more than the FCC continue their rant as to how kits are illegal and that they need to only buy 'certified' equipment or that they have to 'homebrew' only! These notions are only biased for these people to sell their product only! Now the letter states clealy my question to the FCC... did most people understand easily what I'm asking and if so what FCC rule or law I would be breaking? It states my intention clearly... now the Chief Engineer of the FCC wrote back with his reply after he researched it also! Read the other info board for yourself how they are attacking now.
RP: << Read the other info board for yourself how they are attacking now. >>
I'll do that. Maybe they've learned some of us are working on using a CB whip antenna with the AMT3000 -- and that threatens them. 🙂
Bill in SE Texas
😀
Bill, you probably hit the nail on the head on that one!
I used the cb whip on my design because it was easy and not highly visible... ie., the hose clamps just did not appeal to me or crushing the 3/4" pipe either... so I designed my own antenna... it uses a threaded screw which lowers and raises the 1/2 copper pipe through a 12" travel... I think if you have not built the antenna, you may want to build this one... I'm hoping to get at least another 1/2 mile to my range by not having any mechanical connections... take a look....
Antenna pictures:
This is wikhradio from the other board, the moderator. I believe every word of this, and am sorry for any miscommunication on the other board.
Jake
Very nice craftsmanship there, Radio Pilot.
I know of a couple of fellows who are using my mechanical installation. They are now working on suitable coils to go between the AMT3000 and the whip antenna feedthrough.
As soon as I get a chance, I'm going to rewire variable C5 to be permanently across C23. Then, using the internal coils, I'll determine what inductance is needed for both the top of the Ex Band and to get to the bottom of it or lower, at least down to 1600. (Below that is too congested in the Houston-Galveston area.)
Then I'll make a more efficient coil to get me to the top and put it inside the J-box between the transmitter and antenna feedthrough. For moving through the band, I'll put small value coils in the L4 to L7 positions.
The value of C23 may need changing, too.
Bill
http://members.aol.com/K5BY/MP_Radio/MP_Radio0.htm
Bill, Thank you for the kind comments....
Yes the whip does work fine but you need a large ground system to make it work, originally I had 8-30-40 foot radials and got 2-3 miles... which incidently is not bad.... but I wanted my whole island completely under my coverage... so I soldered extra lengths to the existing radials and added 56 extra radials 50 feet long each... and let me tell you the range just got better... I believe that if the radials are are 1/4 wavelength to the height of the transmitter it'll cover 10 miles or more... there are people in the other camp that suggests their transmitter can be heard 10 miles... whether clear or not is the issue... now I salt my radials after each rain to keep the conductivity high and use a sprinkler system to keep the soil moist....
Your comments below seem interesting... but I believe 'sync' the signals on two or more transmitters is what we want... I'm going to place another order for another AMT-3000, because I believe I've found a way to do it... if I do it'll be something everyone can do... no need to 'sell' anything... if you've built the transmitter, you have the knowledge to make the change.... let me know how it works out with the change above.....
Fascinating, Radio Pilot!
I assume that I'll eventually have to take my transmitter off the pole and put it in the yard with radials. I live in the middle of a NW-SE corridor. The good news is that the ground conductivity in my area is 15-30 micromhos. The bad news is that the longest dimension of my property is NE-SW, with the Bay NE and grazing land SW. LOL I figure I would put as many short radials as possible but as long as possible in the NW-SE direction.
I can't "salt" my ground, although I know that helps. I recall reading about a ham living in the desert who filled an old water heater with rock salt, punched holes in it, added a filler pipe, and then buried it below his vertical antenna. He would periodically fill it with water -- and the ground (and range) got gooder and gooder as the salty water spread out. 🙂
I'd be interested in syncing two AMT3000s. It is claimed on the other board that even if the two transmitters are close together (but not "on top of" one another), the range will increase 25%. I assume one's signal fills in some gaps of the other's signal.
I plan to buy another transmitter, even if only as a spare. I suppose with my tinkering I should also buy a bag of 2N2222s -- my favorite transistor. 🙂
Bill in SE Texas
Phill, I did similar to what the other person you mentioned did, I use water softner salt and crush it and use my spreader on the area where the radials are...
You should get excellent results in your area if you make the radials as long and practical! My area has a conductivity of 4-8mhos and that to me might as well be zero... also I added potting soil mix around the radials before they were covered so the salt has someting to hang on to... sand is not very good at holding anything...
I looked at obtaining the military version of the PN2222s as a replacement for the transistors in the kit... they are far superior and it ups the range slightly because they are rated higher.. but still are equal to the transistors in the transmitter manual...
radiopilot
You're doing very good then, RP, with that poor of GC.
The soil here is gumbo fill dirt. Should I lay radials, I need to do it after a good rain. Else I'll have to use a power saw to cut the slits for the ground wires.
Bill