Separating exciter and amp of TR-20

Thanks to all who have helped with suggestions on how I might operate my transmitter within legal parameters. It seems that the other part of my original question has slipped through the cracks. The part about perceptions - as long as I am within the letter of the law, am I perfectly safe? or, in the event of FCC involvement, will I be facing an uphill battle to prove compliance (operating a 20-watt transmitter at only 100 milliwatts, for example) while operating in free-radiation mode? I'm assuming I'll be reasonably safe for carrier-current operation, since that is what the transmitter and coupler were designed for and presumably verified by Radio Systems as being compliant prior to marketing and commercial sale.

There are sticklers who hold tight to a severe and very particular interpretation of rules, and it's good to have one provide input every once in awhile.

But the more imaginative and creatively thoughtful curiousity about what rules say and how elastic they are is also useful.

Indeed, "campus" and "camp" are inter-related words, and their definitions might have many forms, including my proposal that educational purpose could arguably define a "campus."

I think a carefully and sincerely developed theory such as that posed by MrNaturalAZ could be written down in the form of a policy and kept with your station documentation, for submission to the FCC if they ever raise an issue. It would go toward showing responsible intent.

Even sticklers are sometimes wrong in the eyes of the FCC.

ADDING

Regarding the acceptability of using the exciter section of a 20-Watt transmitter, with modifications as we have discussed, I suggest also in this case that documentation might smooth any interaction with the FCC...

In this case you would neatly draw a Part 15.219 Schematic of the modified version, with technical notes of explanation, and excluding (in the picture) the 20-Watt amplifier section.

Such a schematic could aid the inspector in realizing what you have done and why it complies.

Words belong to the public, and "campus" is a word. Let's see how people have used this word:

http://en.wikipedia.org/wiki/Campus

We learn that the word campus has traditionally been associated with institutions of higher learning, but changes have taken place as corporations like Microsoft refer to their Redmond, Washington, facility as a campus, and some hospital complexes consider their grounds to be a campus.

This flexibility is not something that must be rigidly proven by a supreme court case, but is part of the natural domain of how we use words for our own purposes.

The FCC does not have a proprietary use of the word "campus."

It would seem that the burden of proof for compliance with part 15.219 would be on the operator. This is only my opinion based on much of what I have read and inspectors, like any enforcement personnel, will vary in their ability to be reasonable and receptive to input and explanation. Usually if the inspector finds you out of compliance you receive a Notice of Unlicensed Operation and are directed to cease operation.

There is no guarantee that you will not be inspected but if you comply with the rules and don't do things which annoy people the chances of a visit are slim.

I have been doing part 15 AM and FM for over 50 years and have done my best to be compliant and have had no problems at all from the FCC. This doesn't mean I won't but I'll deal with that if it happens. Just be careful with the technical limits and reasonable if visited. Otherwise, carry on.

Neil

The above image is Saint Leo University. The boundry is basically the entire image as the campus extends across the road to the right and the university owns the property to the middle of the lake on the left. Left = North in the photo. So defining the campus boundry can be tricky.

I was browsing teh FCC database the other day and interestingly there was not a single action against an AM operator. Every single one was FM. Perhaps it's just because FM is more popular, perceived as more desireable, and equipment is inexpensive and readily available. Or maybe the FCC doesn't pay as much attention to AM, or the propogation peculiarities of AM make detection more difficult or less likely.

As a side note, I also observed that an overwhelming majority of the FCC actions were in Florida. Not sure if it is because radio "piracy" is more common there, or other reasons, but it seemed like 75% of the cases were there.

Anyhow, most of the documents are similar, and go something like this:

Complaint received (though sometimes a station is just discovered by random monitoring by field officers).

Site is located via RDF. Nearly always a rooftop antenna is observed. Field strength readings are taken and determined to be excessive.

Contact is made with operator, who usually admits to operating the station and knowing it to be illegal (though occasionally they have a tall tale to tell).

Unfortunately the documents tend to be very vague about technical details. I'd certainly be interested to know what the FS readings were; if they were just barely out of compliance, or was the station obviously grossly overpowered. In other words, was the operator at least trying to be legal, or simply careless scofflaws?  Also no mention of the specifics of antenna and transmitter, though nearly every case involved a plainly visible outdoor antenna.

In any case, I suppose the key is maintaining a "clean" operation and a low profile. It's also reassuring that over the past few years worth of FCC actions, not a single one has been on an AM station.

Also, in keeping with some of the suggestions, I shall thoroughly document any transmitter modifications I perform, as well as documenting power measurements as well as FS readings and/or subjective coverage data. I also plan to incorporate phrases like "Part 15" and "serving the community" in my sweepers to demonstrate intent.

Looks like a lovely campus. I'll bet an AM signal travels quite a way across that lake.

It is a great place. Here is a very short but fun video:

There may not have been any actions against AM stations, but there certainly have been NOUO's issued (essentially a cease and desist order).  It could be that the AM stations are far more compliant or attempting to be, whereas the FM stations are true pirates.

The FCC does pay attention to unlicensed AM stations.

Agreed that the FCC cites for AM part 15 operation are rare but they do occur. All except one that I know of resulted from excessive ground length and the exception involved a certified transmitter (under part 15.219) where the cite was for 15.209. The details of this are still not well known.

A little off topic but for future reference, I posted an analysis of FM part 15 NOUOs using the reported field strength and distance in the FCC NOUOs to estimate the effective radiated power output of the FM transmitters' antennae. I searched the forum but could not find it so here it is from my archives:

Pertaining to published FCC NOUOs for part 15 FM the cites resulted from excessive field strength. Granted there may have been other factors which attracted the FCC's attention (such as objectionable content or interefence) but the field strength measurement was the basis for the actions. In several of the NOUOs that I studied the calculated ERP from the antenna was well within the capabilities of commonly used FM transmitters. Based upon my calculations, the citations are not reserved for operations using tens to hundreds of watts.