A Clip Posted on Another Part 15 board, and of Interest Here:
The FCC doesn't care if your transmitter is certified or not, as long as it is operating in compliance with the rules and regulations. Nevertheless, there still is one major advantage to a certified unit; They are already built and ready to use. Plug and play, as it were.
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Just to note that setups/operators using transmitters in the AM/FM broadcast bands that were/are FCC-certified under Part 15 are NOT immune from FCC action if their installation and/or performance is found by an FCC field inspection to be non-compliant with Part 15.
Examples of such can be found via a reading of the FCC NOUOs issued to the operators of such certified transmitters, based on the public statements of users (and others) pertaining to those systems.
That was from a post of mine emphasizing that a certified transmitter has no real advantages as far as an inspection goes.. and I do consider them to be "plug and play" transmitters, since you don't have to build one before making use of it.. You basically plug it in and start transmitting! - although it's true there is a bit more to it than that, but I'm not sure why you turned the phrase into a question.
... I do consider them to be "plug and play" transmitters, since you don't have to build one before making use of it.. You basically plug it in and start transmitting! - ...
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However the compliance of such a system with Part 15 depends on its installation and performance with respect to Part 15 -- whether or not that operator had to assemble that system from component parts or a commercial kit, or used an assembled, commercially-sold transmitter certified under Part 15.
Such "Plug & Play" concepts might serve the beliefs/hopes of the operators of such Part 15 AM/FM systems, but doesn't necessarily give them immunity from FCC NOUOs.
Even if you're not 1 micro volt past 15:239 if you operate too close to an adjacent station and someone in your neighborhood (or coverage area) complains about your operation you can receive a NOUO. As I read some of these NOUO's that are a few uV/m's past what is stated in 15:239 it seems as though the metro areas are of concern. There are some that didn't even list the field strength. Could those be strictly interference based and not compliance based? If someone is interfering with a nearby station I don't believe it matters to the FCC what your field strength is because to them your a Radio terrorist when you cause interference to others. So everyone needs to practice common sense when starting up an FM or AM microcast station.
I once owned a car which was "certified" by the manufacturer to be able to go 180 miles per hour. Even the casual observer knows that this is not legal on our public streets.
In the case of Part 15 transmitters, this is not so obvious, especially with FM since there is no speedometer.
This topic comes up often and is annoying to some here but consider that there are new members and others who visit who do not know that a certified transmitter is not assurance of legal operation and, just as with my car example, this is on the owner/operator.
Rich and Rich Powers are saying the same thing in this respect but Rich Powers' point was the relative ease with which a certified transmitter can be placed into operation, with the later added caveat that certification by itself doesn't guarantee compliance.
Neil
Yes, exactly. I thought I was very clear in emphasizing the point that certification has no bearing whatsoever over the legality of an improper install.
eh.. that should be - the illegality of an improper install
This discussion is a bit of an over-simplification.
Practically speaking, if you're broadcasting with an unmodified certified FM transmitter, then there is no way to effectively measure your field strength. And as we've seen, and I've experienced, the 200 foot rule is not always an indicator of compliance (range really depends on the receiving equipment and a whole host of other factors). Plus, installation parameters are NOT included the rules. At that point, you're doing the best you can do, and I doubt very much that field strength would be the basis of an NOUO, regardless of your actual field strength. If you're interfering with a licensed station, that's another matter.
With Part 15.219 AM, installation parameters ARE part of the rules - if you go outside the installation parameters specified, then of course you are not compliant and if caught, you can expect to get shut down at best. Otherwise, if you are using an unmodified transmitter, and not interfering with any licensed station, you should be OK.
There's risk in everything that we do. But this continuous harping on the possibilities of not being compliant and the FCC (or Industry Canada) coming after you even when using a certified transmitter and following each and every installation parameter in the rules only serves to discourage newcomers when in actuality the risk is very low. Certainly the lowest it can get in this hobby (or business).
If I were ever confronted by Industry Canada or the FCC when using an unmodified certified transmitter and staying within any other rules (such as antenna+ground < 3 meters) would be to suggest to them (nicely, of course) to 1) go talk to the manufacturer who is supplying the equipment, as they're the ones who get the equipment certified and 2) if using FM, to suggest to them that there needs to be a better method of determining compliance other than requiring very expensive test equipment that is out of reach financially of most people.
I have a very short memory and reading topic after topic, sometimes I get lost in the mix of words.
I personally do not have a problem with Rich, he probably pays me no mind, since I do not quote math in my topics, that is more likely because I am lost a lot of the times in these equations and numbers, but I do have to admit, seeing his numbers quoted in many topics across this board, helps me to remember what I have forgotten about those numbers by reading topics that are unrelated to his quoted numbers. So an occassional refresher does help my memory.
I really do appreciate his participation here, because I have to admit, he is teaching me something I appear to be slow at learning.
I have a long history in electronics, even in Citizen Band radio 26.965 to 27.405MHz, but AM and FM part 15 is a totally different animal, which is very difficult to follow and learn, since the FCC made it difficult for the average Joe to learn and use properly.
Needing spectrum analizers, needing field intensity units for AM and FM is ridiculous, who can afford any of those?
CB radio was easy, no more than 4 watts at the FINAL output stage on AM and 12 watts PEP on SSB, antenna height no more than 60 feet total, no more than 100% over-all average modulation. A no-brainer!
CB related RF meters were under or slightly over 100 bucks, or more if you really wanted a fancy looking one.
Bruce.
"I once owned a car which was "certified" by the manufacturer to be able to go 180 miles per hour. Even the casual observer knows that this is not legal on our public streets."
Except that you have a gas pedal and it doesn't cost you $15,000 to know what the speed limit is where you're driving.
This is why the FCC certification on the WH should either hold up in court, or be removed altogether. How can the FCC give anyone a NOUO when they certified the unit?
"Yes, this unit is certified as legal, but here's a NOUO anyway".
"Just to note that setups/operators using transmitters in the AM/FM broadcast bands that were/are FCC-certified under Part 15 are NOT immune from FCC action if their installation and/or performance is found by an FCC field inspection to be non-compliant with Part 15."
Then the FCC should remove the certification. How can a company sell a certified plug-and-play transmitter and still get a NOUO from it if used as intended?
How can a company sell a certified plug-and-play transmitter and still get a NOUO from it if used as intended?
NOUOs are not issued to those with certified units who have installed and use them as intended
NOUOs are not issued to those with certified units who have installed and use them as intended
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As intended by whom?
The FCC? The transmitter manufacturers? Their distributors/installers/advocates? End users?
As intended by the FCC who certified them.
Looking only at FM for now and Part 15.239 it is safe to say that essentially the limit is on field strength which most of us are not equipped to measure, thus the "no speedometer" reference. Keep in mind that a broken speedometer is not relief from a ticket.
With a certified transmitter installed and operated per the manufacturer we are placing trust in them that their device meets the legal requirements of certification and we will be OK. But, as Tim in Bovary has reported, this may not always be true and lacking the means to measure field strength places the user in an awkward position.
What other things can be measured by the user which could be meaningful to assess compliance? One idea is to have power and antenna specifications but the comparatively high efficiency (compared to 3m on AM) of even a short length of wire at FM frequencies means that the power involved to produce the field strength limit of 15.239 is too small to be measurable with commonly available equipment. Therefore, I believe that this is not going to work as an alternative to field strength.
On that dismal note let's be realistic and practical. If a person is using a certified transmitter and has not modified it and is not causing interference there should be no problems. Even using the somewhat shaky 200 foot guideline for non-certified transmitters should not be a problem. People doing this are not intentionally violating rules and are not pirates, and almost all of the citations are for field strengths orders of magnitude above the limit. So, relax, stay legal as best you can, and press on.
Neil
I would dare add to this as to say if you live in an area where Radio Piracy is a problem I'd advise you not to operate a broadcast transmitter. You have a lessor chance of any issues if you are in a somewhat rural area and keep the blank frequency rule above and below your frequency you transmit on. Even if your transmitter happens to be certified and over the 250 uV/m @ 3 meters you'll probably be OK if your rural and its not an obvious mod aka you tampered with the transmitter. Neil is right too because all the talk about FM and getting in trouble with a certified transmitter is cause for alarm for the new comer. If people are so worried they really need to be an active participant of the FM Initiative and or generate a iron clad petition that will stick based on these factors constantly mentioned. I think that the format for save Internet Radio could also be used in this. Changing the wording and keeping some of the same format will be effective. Carl has started a statement that could be used and it looked really nice. We would just need to get the public together on this. One way to stop the possibility of a NOUO for a certified transmitter on FM would be to require the transmitter to identify itself with the FCC ID in CW or forced computer voice every hour. So if it has the FCC ID number blasting every hour you can't be NOUO'd on FM. That is one thing I didn't think of in the FM Initiative but maybe its time to force these manufacturers to play the FCC ID once per hour if its a true certified transmitter. This could even be a static RDS signal too. All the more reason for the FM Initiative.