The 200ft Elephant

Because elephants leave a lot of it 🙂

The easy answer is that there has never been issued an NOUO for "going over 200 feet." Notices are issued for either field strength (usually ridiculously beyond the guidelines) or violating the three meter rule (antenna and ground lead - again, usually for a ridiculously long ground lead).

If you read a good number of NOUOs you'll start to see a pattern - 100,000 uV/meter at 25 meters is not "just slipping over the line," a 50 foot ground lead is not a "good faith mistake" when siting a transmitter.

In fact, if you read the last few years' NOUOs you'll see that none of the topics folks usually sweat on these forums (capacitive hat, center loading, 1 mW vs 10 mW, etc.) ever make the enforcement lists. It's the poor souls who buy a 10 watt AM or FM unit off of ebay or run a 50 foot "ground wire" to an AM transmitter (and only two of those) - or sellers of devices not certified, who get a letter.

Again, in my opinion, I think the only reason the "200 foot" notation was added was to offer some real world description of the user experience for non-technical users when sellers were making outrageous range claims. Toy walkie talkies, cordless phones and baby monitors are Part 15 devices, too and back in the 80s and early 90s companies used to claim "1000 foot range" and such, which was pretty much impossible.

Scwis, Your points are well taken, but I wasn't really meaning to elaborate, or indicate that I had personal concern about the legality of my signal going farther than 200ft. That's not what I think, though I realize that is what it sounded like..

My concern is on how to respond if and when a local resident finds that statement on the FCC website, and points it out, potentially seeding doubts in the local community about the valid legality of my station.

The reason I worried about it is due to the fact that my goal is do this commercially, and if legality rumors start flying around, it would certainly cause advertisers to feel less secure about supporting the station.

This is a small island with heavy tourist traffic, and I feel secure that a commercial Part15 can work here..
But it also involves local trust.

If I cant answer the 200ft thing (should it arise), and effectively dismiss it, it could hurt things.

So then, if need be, how do you eliminate the 200ft elephant in the room for the average Joe?

Worry about the 200' issue is an analytic tool which you can use to measure your comparative situation.

Most people cannot even estimate 200', not one is going to get out a measurement device and mark it off, and anyone we even reads the number "200'" will not begin to wonder what you are doing. People are not critical thinkers because that skill isn't taught in schools (as it once was). Except in professions where members wouldn't be concerned about how many feet you had. You are imaging people who are petty and looking for trouble. Such people aren't clever enough use mathematics.

However, you are within your rights any way because 200' isn't actually in the rules. True? Therefore it is an informal estimate, and acting within the rules, you are lucky enough to do better than 200' The literature that mentions "200'" is giving a ballpark figure, and avoids the elaboration that would follow if they'd bothered to detail all the exceptions.

You are legal, so act legal.

If for AM, I would respond that the 200 foot statement is only a "guideline" for a typical transmitter system and not a rule and that my station is not typical in that it has been optimized for legal operation under the rules (15.219). Advances in ground planes, antennas, and efficiency produce greater range than given in the guidelines and are legal.

For FM it is much more difficult because we are limited by the field strength at a distance and almost all of us are not able to measure this. If you are using a certified transmitter according to the manufacturer's instructions that is your defense. If not, then the 200 foot suggestion, if this is your range, implies you are legal though this doesn't prove it.

I tend to over think (and worry) about such things and my wife tells me "Why don't you wait until it is a problem?" That being said, I do try to minimize the chance of a problem but don't obsess over it (not saying that you are).

Neil

Hi Rich,

Don't work yourself up over the 200 ft. thing. That came from a notice put out some 15 years ago IIRC, based on the original Part 15 rules from 1934. Who writes blurbs for the FCC might not even recognize details in citing their own regulations. As for FM, well, that is a field strength issue. Range, then, like AM, is often a function of receiver selectivity and sensitivity.

So ... if someone points out that FCC page, you should just clarify that reception distance ... range ... varies widely with individual sense of what constitutes a clear signal, and for AM, modulation, atmospheric conditions, time of day, ground conductivity, and on the quality of the receiver. Therefore, considering the nature of the beast, setting a reception range of AM radio is a relative, indeed almost arbitrary, thing. Radio engineers know that.

For example, in my case, a daytime signal can barely be heard, let alone be clear, on a cheap clock radio at almost any distance, a decent car radio varies from 700' to a mile (occasionally more), a $5000 communications receiver, filtered, with frequency-tuned preamp, and longwire (300') outdoor antenna can receive it with good clarity at about 9 miles along the coast. Of course, after sundown, skip makes for much more noise in the AM BCB, so the practical listening area of usable signal decreases.

Ease your mind. In any case whatever, the main points to consider and avoid are interference with licensed stations and grossly illegal physical characteristics of the installation.

What do you think now, Rich Powers? Some very well reasoned points of view have been put here in response to your concern about the 200-foot question.

Do you have more confidence in your safety as a conscientious part 15 operator?

The service you are providing sounds worth doing.

Yes... some very well reasoned points of view indeed.
That's the kinds of insights I was hoping to hear, and I feel more relaxed now.

Thank you much guys

Perhaps the FCC compares it to what they consider adequate signal for a commercial station.

Granted, you're not going to have the 1mv/m FM or 2mv/m AM signal at 200 feet but, at 200 feet your signal will be strong enough to sound full quieting.

And as stated by others, 200 feet is only a guideline, not a rule.

Besides, what average Joe retailer is going to look this up if they can even find the info on the FCC website. They just want to get their message on the radio.

When you talk to the average guy on the street about the trouble you can get into being a pirate operator, they just can't understand what the big deal is.

I just attended a meeting with a group of politicians (part of my day job) and watching them in action yesterday reminded me of this thread.

Perhaps this might help, along with the technical info discussed above.

Local gadfly: "I read on the FCC web site that you can only transmit 200 feet."

RichPowers: "Well, good afternoon friend, my name is RichPowers, thank you for taking a moment to visit with me today. Please tell me more about your concern."

Local gadfly "I read on the FCC web site that you can only transmit 200 feet, and you say your station goes farther than that."

RichPowers: "I see, so what is your question today?"

Local gadfly: "You say your station goes farther than 200 feet, how can that be legal?"

RichPowers: "Did the web site say my station can only transmit 200 feet?"

Local gadfly: "The FCC says that Part 15 stations are 'limited to an effective service range of approximately 200ft' and your a Part 15 station, right?"

RichPowers: I am really pleased to be speaking with someone who is so well versed on the FCC regulations. As you might recall from your reading, the FCC web site specifically states that an exception to the 200 foot rule would be stations operating under Part 15, section 219, are you familiar with that regulation as well?"

Local gadfly: "Well..., I do remember seeing some other regulations referenced..."

RichPowers: "Exactly. I operate under the 'exception for some transmitters operating in the 510 kHz to 1705 kHz band is found in 47 C.F.R. S:15.219. Specifically, Section 15.219(b) of the Rules states 'the total length of the transmission line, antenna, and ground lead (if used) shall not exceed approximately 3 meters.' Operators under 15.219 often experience ranges greater than 200 feet, based on local conditions. We are very fortunate to live in an area where local conditions are highly favorable for Part 15.219 operations and I am so proud to be able to serve our community in this innovative way."

Local gadfly: "Oh..., I didn't know about..., that..."

RichPowers: "And no one could rightly expect you to, my friend, low power broadcasting is a somewhat complex field and I have dedicated myself to mastering this little known technology to serve our fair community. I am so grateful for community minded neighbors like you who provide me with the opportunity to discuss important matters like compliance with FCC regulations and I can tell for our conversation today that we are certainly on common ground there. Thank you so much for your insightful question!"

SCWIS, your conversation with a gadfly was a very suave bit of political finesse.

We now have a prize radio station in the community that is allowed to exceed 200-feet because of professional intelligence. The whole community is much the richer (pun on Rich Powers?).