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Part 15 FM: FCC-Leg...
 
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Part 15 FM: FCC-Legal Considerations

 
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Last Post by Anonymous 11 years ago
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 Anonymous
(@Anonymous)
Posts: 0
 

No commisoner ever said.  Commisoners are politicians.  They probably don't even know Part 15 exists. Non-factual stuff in a newspaper.


 
Posted : 01/07/2015 8:23 am
 Anonymous
(@Anonymous)
Posts: 0
 

Read the document from the FCC which is similar to Industry Canada also and sections 15:23, 15:7, 15:201, 2.803...the section covering kits clearly states that ANY kit designed or invented by an individual can be used for his or her OWN use in compliance with rules BUT if that person intends to sell or market the design or kit for others to purchase as a business it has to be tested and approved by the FCC with a label with certification# with the product. So that would mean that Ramsey and SStran for example or the few individuals on You Tube selling their designs of AM transmitters on Ebay are ILLEGAL! so how are they getting away with it? The document is plain as day.

Also section 2:803 also says that the importing, selling, etc of ANY transmitter has to be certified with # on product or it's an offence.

Then, how can sellers through Amazon be selling uncompliant Chinese transmitters under the name of Fail Safe or other brand names? How can Canakit be selling non tested Industry Canada approved transmitters here in Canada? Ebay is full of these.....how come Ebay isn't cited for having these for sale on their site?

Also if you have an uncertified transmitter it doesn't matter if you are using it legally or not.....you can be told you can't use it and it can be confiscated!

My advice, is similar to Thelegacy....If you want to go on AM stick to the ones that have the certification like Talking house and for FM Decade, Wholehouse 3, etc.

But my question is how do all these companies or designers sell all these transmitters and get away with it? The FCC and Industry Canada can go on line and see this like we can and know they haven't tested and approved them.

 

Mark


 
Posted : 01/07/2015 8:42 am
 Anonymous
(@Anonymous)
Posts: 0
 

What does the number "98" have to do with anything? Why not just say "100-feet"?

My little AM station goes farther than 98-feet even when I only use 36 mW to the final RF stage (the lowest power setting on the AMT5000 transmitter).

Mr. Druid Hills said, "Commissioners are politicians," and that is true, but someone should tell them that the word "politician" comes from the expression "someone who pretends to be polite - a politician."


 
Posted : 01/07/2015 8:48 am
 Anonymous
(@Anonymous)
Posts: 0
 

Mark asked: But my question is how do all these companies or designers sell all these transmitters and get away with it?

My Answer:  Because the FCC does not give a shit.  Plain and simple. Take a chill pill and enjoy the hobby.


 
Posted : 01/07/2015 9:10 am
 Anonymous
(@Anonymous)
Posts: 0
 

@post 15:

Where in part 15 does it say anything about 98 feet? The only place I saw 98 feet was in a news article about an unlicensed AM transmitter that was not operating following 15.209 or 15.219.
If you read the NOUO, actual government documents on the unlicensed transmission, there is no mention of 98 feet. There is no bigger picture; unless a range limit is published it means nothing.

An AM transmitter certified to comply with 15.219 installed at ground level with completely buried (non-visible) ground radials where the total length of the antenna and ground lead is 3m will always pass the 15.219 part of an FCC visit. Such a transmitter, by virtue of being certified, will not be able to operate on 1710. (There are probably ways to use a 15.219 transmitter above ground and have it pass a 15.219 inspection, but the ground mount case is the easiest to prove compliance for. People who have yards for radial fields have an advantage; the FCC doesn’t care if that is unfair. People who live in multi floor apartment buildings are at a disadvantage, the FCC doesn’t care if that is unfair. All the FCC cares about is 3m total of antenna and ground.)

@post 17
On this board we worry about intentional radiators. There is a whole set of rules for unintentional radiators. Many consumer electronic goods, such as wall to usb charging bricks or CFL’s emit RF hash up and down the spectrum unintentionally (they do it but they are not designed to). The FCC could make huge gains saving AM radio by going after non-compliant unintentional radiators. Every day there are more non-compliant unintentional radiators brought into the country and sold than non-compliant intentional radiators. If the FCC is unwilling or unable to handle the bigger problem (unintentional radiators), they are probably worse off for the smaller problem (intentional radiators). There is a pattern in NOUO’s/NOV’s against non-broadcast company entities. Someone complained or someone did something visible and drew the attention of the FCC; or the FCC wanted to make an example.

Selling GPS/Cell jammers is illegal, the FCC found a store selling them and busted them.
Someone drew attention to their unlicensed station, the FCC investigated and found non compliance.

If noncompliant transmitters on ebay and amazon bother you, complain the FCC, ebay, and amazon. If you make a big enough stink maybe the FCC will go after ebay or amazon. If ebay or amazon thinks the FCC could go after them, they may restrict selling transmitters.


 
Posted : 01/07/2015 9:19 am
 Anonymous
(@Anonymous)
Posts: 0
 

STCV Said: Such a transmitter, by virtue of being certified, will not be able to operate on 1710.

 

I said:  Sure you can, but at greatly reduced power.


 
Posted : 01/07/2015 9:43 am
 Anonymous
(@Anonymous)
Posts: 0
 

If I can play devil's advocate here, I don't believe that anywhere in the rules does it talk about 'radiating grounds'.

The rule states that the total length of the feedline + antenna + ground wire have to be less than 3 meters in length.

The intent of the rule may be to limit radiating grounds, but that's not what is written.  Actually, I believe the intent is to limit range, period.

All that goes to show is that it is the FCC inspector who passes judgement on your installation.  There have been elevated installs with long ground wires that have been OK'ed.  Also ones that have a short ground wire attached to a metal structure that have also been approved.  And many others that have not.  The FCC inspector has the final say.

This has all been talked and argued out many times.  The least risky installation is ground mounting.  I don't know if an FCC inspector has ever rejected radials, but I suspect that that is within the realms of possibility, particularly if the inspectee is uncooperative.  Elevated mounts are the most risky, even if you don't hook up a specific ground wire, because it is entirely possible for an audio or power feed to act as a ground if none other is available.

Overall, if use Part 15.219 on AM, it's much more difficult to know if you're compliant in the eyes of an FCC field inspector than for FM.  FM is cut and dry by comparison - if you meet the field strength limits, then you're likely compliant.


 
Posted : 01/07/2015 10:44 am
 Anonymous
(@Anonymous)
Posts: 0
 

... I don't believe that anywhere in the rules does it talk about 'radiating grounds'. The rule states that the total length of the feedline + antenna + ground wire have to be less than 3 meters in length. ...

Actually the rule states "The total length of the transmission line, antenna and ground lead (if used) shall not exceed 3 meters."

In this context the "ground lead" is the complete conducting path from the transmitter r-f reference plane to an external r-f ground -- typically, something buried in the earth.

It can be proven that a vertical tower, metal flagpole, aluminum mast, steel framework etc connected to the earth at the bottom does not have the same r-f characteristics at the top that it has at the bottom.  

The top of those conductors is not an r-f ground.  Therefore the short lead some people consider to be the entire "ground lead" and connecting to the top of such towers, etc is in fact just a section of the complete ground lead.

RF current flowing along those towers, etc produces radiation.


 
Posted : 01/07/2015 11:37 am
 Anonymous
(@Anonymous)
Posts: 0
 

Sorry, not ground wire, but ground lead.  Rich, I don't necessarily disagree with your definition, but it is YOUR definition.  Ground lead is open to interpretation, and it has been interpreted differently by different FCC inspectors in the past.


 
Posted : 01/07/2015 1:04 pm
 Anonymous
(@Anonymous)
Posts: 0
 

... Ground lead is open to interpretation ...

Not by the principles of physics.

Those wanting to believe otherwise are free to do so, of course.


 
Posted : 01/07/2015 1:44 pm
 Anonymous
(@Anonymous)
Posts: 0
 

Rich quote: "Those wanting to believe otherwise are free to do so, of course."

At this point Part 15 beliefs become religious, protected by our Constitution.

Therefore, persons with a religious objection to short ground leads by any name, are protected "on religious grounds" (pun intended).


 
Posted : 01/07/2015 2:24 pm
 Anonymous
(@Anonymous)
Posts: 0
 

But we're not dealing with the principles of physics here.  We're talking about written regulations.  That can be interpreted in different ways.  And they have been by FCC inspectors.


 
Posted : 01/07/2015 3:28 pm
 Anonymous
(@Anonymous)
Posts: 0
 

Knowing you are a bookstore man, at least in past experience, I thought you might enjoy a quotation from one of your popular authors that supports a position you frequently hold...

Aristotle wrote: "We see men of experience succeeding more than those who have theory without experience."  - Metaphysics I


 
Posted : 01/07/2015 4:17 pm
 Anonymous
(@Anonymous)
Posts: 0
 

By "commissioner" do you mean inspector?

The KENC situation was a case of the installation being non-compliant for using the water tower as the ground and by a very unreasonable/ill-informed field inspector who insisted that the installation comply with both 15.209 and 15.219 rules.  The Rangemaster notice clearly states that it is FCC certified under 15.219.  Ken Cartwright pointed that out to the inspector who basically ignored it.

In the end, Ken called Oregon Senator Ron Wyden who had been a supporter of KENC and his office contacted the FCC.  At that point, the FCC basically backed off, instructing Ken to reconnect the ground for the sake of lightning protection and observe the 3m rule.  About this time, Keith Hamilton developed a ground filter, the AM1000FIL, which would be placed between the ground lead from the transmitter to an earth ground for lightning protection.  The FCC indicated to Keith that it would approve of such an installation.  So the "98 feet" requirement for part 15 AM is bogus.

 


 
Posted : 03/07/2015 3:56 pm
 Anonymous
(@Anonymous)
Posts: 0
 

Keith Hamilton developed a ground filter, the AM1000FIL, which would be placed between the ground lead from the transmitter to an earth ground for lightning protection.  The FCC indicated to Keith that it would approve of such an installation.

If, after the original NOUO, an "AM1000FIL" was installed at KENC, and it prevented radiation of that AM1000 transmitter signal from the structure of that ~ 40-ft tower it was "grounded" to -- then what was the reason that KENC ceased operation after that filter was installed, and the operation was re-tested by the FCC?


 
Posted : 03/07/2015 4:20 pm
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