Using Metal Roof As A Ground

Aha! You've fallen into the grounding legalities loop! If you truly believe that the FCC Part 15 regulations specifically spell out what they mean by grounding strap and you feel that you can't use an elevated antenna because of that interpretation, then you can't use your metal roof and sleep at night without worry. Imagine the havoc you would cause if your metal roof happened to be grounded!

In my opinion the FCC part 15 ground strap reference is vague. It does not specify to what the strap can be connected. I have an FCC registered part 15 transmitter that came with an alligator clip ground wire. The instructions say to clip it to a cold water pipe, electrical ground, or large metal object. Okay, that doesn't necessarily prove anything.

However the FCC revised the part 15 regulations late last year. They had the opportunity to address this issue, yet they made no changes in regard to part 15 am grounding. If this were truly an important issue I'm sure the FCC would waste no time in clarifying the regulation. I know that someone got a reply from the FCC on this board that the elevated ground system was not in compliance with their interpretation of the rules. So that amounts to another opinion on a vague regulation. I have never found a reference anywhere to any FCC action based on an improper part 15 grounding system.

So it all comes back to you. If you truly believe that the ground strap cannot connect to an elevated ground, you would be wrong to use your roof. In my case I believe the regulations are too vague to be enforceable and I'm prepared to defend my installation if needed.

by MRAM 1500 kHz

Yeah, of all the FCC actions I've read listed on the FCC website, they never mention the grounding issue when they shut someone down. Instead, they cite for excessive field strength under part 15.209.

I interpret this as they have decided that your station doesn't meet part 15.219 for whatever reason, (ie. improper antenna due to grounding) since field strength is not limited under part 15.219. Once they consider your station to be under Part 15.209, power and antenna are not the problem, it's the field strength which is easily measured and recorded.

If the station doesn't conform to part 15.219, then it makes sense to cite the station under part 15.209 for excessive field strength and that's why you don't see grounding mentioned.

Of course, this is my interpretation of the situation but we don't want to go down this road.

The comments regarding field strength are exactly on target. Part 15 rules do not specifically mention elevated ground systems. However, several articles re: the use of metal roofs as station grounds have been addressed by FCC inspectors. In a word, NO. They consider elevated metal roof systems as breaking the scope and "intent" of the rules, not just bending them a little. Inspectors will accept a single conductor of 12 AWG or larger running the shortest path possible to earth ground as acceptable. Stay away from "elevated" ground systems. Stay away from lengthy ground conductors using circuitous routes.

Next, just a word about the newly adopted Part 15 rules. The FCC, for decades, has considered newly adopted rules as additional or amended rulings, not replacements. In other words, if a previous rule was not included in the newly adopted rules does not mean it is not still in effect. If the old rule is amended, then it is essentially replaced by the amendment. If a new dimension is added to the rules to clarify or change the interpretation of an aspect of the rules, then these are considered new additions. This is exactly how the inspectors enforce the rules. So, just because you don't see the rule in the most recent adopted rules, doesn't mean you are reading the entire scope of the body of Part 15 rules and regulations. In addition, CFR 47 contains the entire body of rules and regulations for the FCC. However, it does not contain the Sections of Communications Law used to enforce the rules and regulations. Those "federal" laws are passed by Congress and signed into law by the President and enforced by the FCC and the Department of Justice.

One of the new federal laws, for example, allows local authorities under execution of "probable cause" to, without a search warrant, search your premises/home if they suspect a crime is in process of being committed or has been committed. So, some of what I have read on web reflectors and information shared in emails does not take into consideration that we operate unlicensed radio stations at the whim of federal law, the FCC and law enforcement personnel.

And finally, when planning the design and construction of your station, use the most conservative design you can and still be satisfied with its performance. Remember also, broadcasting practice and content are taken into consideration. What you say, how you say it and the scope and target of your statements are issues that bring your station to the attention of the FCC. Newspaper articles, websites, public service projects, advertising (on and for the station) will all flip switches that cause the FCC to take a closer look.

Marshall Johnson, Sr.
Rhema Radio - The Word In Worship
http://www.rhemaradio.org

QUOTE:And finally, when planning the design and construction of your station, use the most conservative design you can and still be satisfied with its performance. Remember also, broadcasting practice and content are taken into consideration. What you say, how you say it and the scope and target of your statements are issues that bring your station to the attention of the FCC. Newspaper articles, websites, public service projects, advertising (on and for the station) will all flip switches that cause the FCC to take a closer look.

And boy am I glad we did get the web, newspaper, and tv press on the Manteca Local Radio Station. We were conservative enough to run the exact equipment that was in the 1967 Stanford AM Studio (not like it.. it was it), plus some modern additions of the dual cd deck, and computer automation.

Thanks to the coverage, and my calling the FCC to come take a look at what I had, we ended up with local support that was awesome. If you are running up to par, I recommend getting the fcc to come take a peek at your station - we aren't doing anything wrong, and unless you are - theres no reason not to have em come on down 🙂

The FCC are not our enemy. There is nothing scary or wrong about them. If you are running a pirate station, well then, be scared - eventually you'll get asked to take your stuff down.

Fellows, I've worked part time at an AM station for over 50 years and have found for the most part the FCC inspectors to be congenial. The ones I worked with would give a little and take a little and never held us to the strict letter of the law. If they really didn't like something we changed it. They weren't someone to fear but would set us to their way of thinking and give us time to make the change. Granted, we tried to run a good ship for a small station and didn't have equipment falling apart and our paper work was up to date. I've read testimonies of Part 15 AM'ers who used an uncertified kit with an elevated antenna and 20 foot ground lead, breaking the strict interpretation of two of the rules, who invited the FCC in and passed with no problem. If you've really made a sincere effort, and if the inspector really does show up and you're congenial with him, he's not going to slap the cuffs on you or take your equipment, but tell you what changes need to be made before operating again. Otherwise keep the programming clean and decent, and don't interfere with a licensed broadcaster or your neighbor's television. Jim B

The FCC is a federal agency charged with executing the Communications Acts passed by Congress and signed into law by the President. CFR 47 is the embodiment of the scope of administrative law concerning the FCC. These are usually referred to as rules and regulations. I was first licensed as a broadcaster in the mid-1960's. And have been a licensed broadcast engineer since 1971. I also carry credentials as a volunteer FCC examiner and hold an Amateur Extra Class license. I have been a technical consultant to the FCC as a radio broadcast engineer. My job was to assist licensed AM or FM broadcasters make changes required by FCC inspectors. The broadcasters worked with me on an entirely voluntary basis.

My experience is that most broadcasters want to follow the rules and make the requested changes in order to comply with federal rules and regulations. Very occasionally though, a broadcaster with a chip on the shoulder would get nasty and argue with the suggested changes. I never found arguing with the FCC did much good. It usually just got folks in a deeper "pickle".

The FCC inspectors for the most part are not Wyatt Earp with a badge and a grey suit. They are federal employees trying to keep order in a very fast paced and confusing environment. I have had a very good relationship with most of the FCC inspectors I have come in contact with. One or two being the exception.

Questions continue to be raised from time to time concerning enforcement of Part 15 of the Rules and Regs. The data provided by the Phelgm enforcement database URL only deals with violations on the AM and FM broadcast bands. And for the past 2-plus years, less that 2 dozen AM stations were even contacted concerning a violation. All the AM stations listed eventually came under continued scrutiny when the operators continued operation with "way" too much transmitter power over an extended period of time (most over a year). Most involved an FCC inspector visit AND a "postal" notification of apparent violation.

The movie "Dumb and Dumber" comes to mind when assessing the intellect of these folks. Absolutely NONE of the enforcement records show any complaints involving "improper grounding", "antenna too long" or "uncertified transmitter". And even though having an antenna too long or a homebrew transmitter could cause the station to exceed the FCC field strength limits, the notice of violation records show these stations way over the legal field strength limit (they aren't even close).

Non-broadcast Part 15 enforcement logs show the biggest violators of Part 15 are WiFi and wireless telephones, all of which have to be FCC certified.

The enforcement records for the past several years do show increased activity by FCC inspectors. However, over 90 percent of the activity is concerning complaints involving FM transmitters. FM stations who run gain antennas or transmitters with excessive signal strength quickly find themselves in trouble.

Here is my suggestion for AM stations:

1. Run a transmitter only after extensive testing as to the purity of signal (no harmonics to screw up shortwave listeners). Measure and record all test data including type of modulating audio, transmitter input power and listening/test results.

2. Keep complete records of all transmitting equipment including purchase records and certification paperwork. This includes antenna, feed system, transmitter, audio processing and audio sourcing equipment.

3. Keep a log of equipment inspections and the result, and a log of operating hours and conditions. Sign/initial and date all entries.

4. Keep all documentation where you can get at it quickly and have it neatly organized.

5. Keep and file all letters from the FCC, listeners or complaintants. Attach a letter outlining the disposition. Include in the file any special community programming your station has aired (date/time).

6. Periodically, measure transmitter input power and "relative" field strength. Keep a record of all such testing.

These are more than "cover your backside" exercises. These are practices that will demonstrate to FCC inspectors you intend to be responsible and compliant with all of the rules and regulations. And any time you can make their job easier, they are quick to appreciate your efforts.

And finally, if they instruct you to turn it off until your station equipment is changed, repaired or replaced, turn it off and do exactly as they request. After you have complied with there request(s), WRITE them a letter outlining the amelioratiing actions you have taken and when they were completed. Include in the letter, your test data. And continue to execute the list above.

If this seems like a lot of busy work, I have been inspected by the FCC on several occasions, as a broadcaster (non-Part 15), as an amateur radio operator and other radio services as well. I have never gotten a notice of apparent violation. I have done everything mentioned above. The key word here is "cooperate". Of all the "bozo's" in the enforcement log who got tagged with a "notice" or a fine, none really cooperated with inspectors or were responsible for communicating with the FCC. 'Nuf said? What do you think?

Marshall Johnson, Sr.
Rhema Radio - The Word In Worship
http://www.rhemaradio.org