So basically you are saying it is implied the end user must duplicate the test environement in which to operate the equipment.
That certainly is not a real test then is it? It eliminates the intended use of the device for which it is being certified. That being the case, the FCC would not permit marketing of the equipment.
You are still missing the point. The certification accepts the fact that the AC ground IS part of the system, field strength be damned.
That being the case, by your rationale, the power supply cord itself would violate the 3 meter rule regardless of what it is plugged into and the device would not have been certified Part 15.219.
Your statements start with "Probably" and "Even if" so you are extrapolating an opinion based on unknown specifics.
the end user must duplicate the test environement
My comments were about the physical configuration of the equipment system used in the test, not where those tests were conducted.
It is commonplace for transmit system compliance tests to be made in an anechoic chamber. This reduces the affect of signal reflections from the physical environment on the fields emitted by the transmit antenna -- which would produce inaccurate conclusions about system performance.
This does not mean that the user must install that system in an anechoic chamber, just that its certification results are based on the physical configuration of the system that was tested. In this case that did not include a "ground lead" configuration comprised of the a-c wiring of a large apartment building (or even a small home).
The certification accepts the fact that the AC ground IS part of the system, field strength be damned.
There is no restriction on field strength for systems strictly meeting all of FCC ¶15.219. But meeting ¶15.219(b) requires that the length of the antenna and ground lead (if used) cannot exceed 3 meters.
Physics shows that the entire length of the conducting path leading from the transmitter chassis to a buried ground rod at the a-c service entrance of the building (or elsewhere) adds to the radiating length of whatever conductor is attached to the transmitter r-f output connector.
If the total length of that conductor to the ground rod plus the length of whatever conductor is attached to the r-f output connector of the transmitter is 3 meters or less, then that system is compliant with ¶15.219(b).
If that total length exceeds 3 meters, then that system is not following all parts of ¶15.219, regardless of any Part 15 certification it may have.
This situation is similar in practice to when any Part 15 AM transmitter is installed in manner that is non-compliant with ¶15.219, even though it may be FCC-certified under ¶15.219. Cases of this are seen in the occasional NOUOs issued to unlicensed operators of transmitters in the AM broadcast band.
In such cases the FCC may apply ¶15.209 as a requirement for that system. This __MAY__ be the reason why the FCC NOUO to Jerry Gaule did not cite ¶15.219, only ¶15.209.
Of course, ¶15.209 has no limitation on antenna length/height or transmitter power, but it does have a (very low) limit for the legal fields that may be radiated.
There is no restriction on field strength for systems strictly meeting all of FCC ¶15.219. But meeting ¶15.219(b) requires that the length of the antenna and ground lead (if used) cannot exceed 3 meters
I own 2 Talking House devices. We are now back to the discussion of what is is. Both Talking Houses come with a 3 meter wire antenna. Also a wall wart with approximately 6 feet of conductor. You are seeing where I am going with this...
No one can say why the FCC ignored the device certification. It was not stated in the NOUO. You can't assume and state as fact.
The FCC is not going to address it. Like most managers, they have to stick by their employee's judgement or appear foolish.
Like all of these discussions, it's moot.
Thanks to Rich, everyone is painfully aware of the difference between Part 15.219 and Part 15.209. None know the reasoning behind the agent's decision, not even Rich.
You can restate the rules 1+n times ("n" for you John) but the question will remain unanswerable.
It only proves that you put your money down and you take your chances because at the end of the day it won't matter if you satisfy the rules, they can still shut you down just because.
"You can restate the rules 1+n times ("n" for you John) but the question will remain unanswerable.
It only proves that you put your money down and you take your chances because at the end of the day it won't matter if you satisfy the rules, they can still shut you down just because."
this is now my absolute favorite non-technical post in the.. 10 years (holy crap) that this site has been online. I think when anyone starts this discussion again, someone needs to just say "31045".
Awesome.
even at near 1AM
Well, if it was the only non technical post on this forum I might feel bad.
When does technical post become non-technical from technically a technical perspective?
And now that is second fave.
Amazing one year later this topic is still active after a recent revival!
safe to say my part 15 supercluster is slowly being revived in a new city 🙂
"my part 15 supercluster is slowly being revived in a new city"
WOOOHOOOO!!!!!!!
Glad to see Mighty 1650 in Cluster Flight!
I guess that either you guys missed my post earlier or you chose to ignore it. The Talking House was certified with a 3 meter wire and a 1.8 meter line cord making the combined length 4.8 meters.
It was subtle but yes, I saw it. The problem is as Rich F. states the AC "ground" wire behind the outlet counts as part of the total length which by that way of thinking makes it non-compliant. Can't win!
In addition to the "problem" that (by one claim) the electric ground wire adds to the total length of the antenna/transmission-line and ground lead, is it not also true that the audio cables connect the transmitter ground off into the near or far distance and connects there to the entire maze of ground connections serving the entire radio station?
Whether it's madness or a neurological impairment, by such obsessive "logic" part 15 couldn't possibly obey the rules EVER!
and I have to say that
life is too short to worry about all of
that stuff.
At age 59, I act like age 75. (Or
so my family says.)
Why? Because I worried about all
of that stuff.
Very best wishes,
Bruce