It looks like the last line was cut off for some reason. I got this from a web search and that is how it was posted.
FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON, D.C. 20554
GRANT OF EQUIPMENT AUTHORIZATION
Certification
Hamilton PCB Design 134 Wind Chime Ct. 20594, Raleigh, NC 27619 Date of Grant: 07/17/1998 Application Dated: 05/08/1998
Attention: Keith Hamilton
NOT TRANSFERABLE
EQUIPMENT AUTHORIZATION is hereby issued to the named GRANTEE, and is VALID
ONLY for the equipment identified hereon for use under the Commission's Rules and
Regulations listed below.
FCC IDENTIFIER: NWXAM1000
Name of Grantee: Hamilton PCB Design
Equipment Class: Part 15 Low Power Communication Device Transmitter
Notes:
Grant Notes FCC Rule Parts Frequency Range (MHZ) Output Watts Frequency Tolerance Emission Designator
37 15 1.2 - 1.71 %
37: This device has shown compliance with new rules adopted under Docket 87-389 and is not affected by Section 15.37, transition rule.
TITLE 47--TELECOMMUNICATION CHAPTER I--FEDERAL COMMUNICATIONS COMMISSION PART 15--RADIO FREQUENCY DEVICES Subpart C--Intentional Radiators Sec. 15.215 Additional provisions to the general radiated emission limitations. (a) The regulations in Secs. 15.217 through 15.255 provide alternatives to the general radiated emission limits for intentional radiators operating in specified frequency bands. Unless otherwise stated, there are no restrictions as to the types of operation permitted under these sections. (b) In most cases, unwanted emissions outside of the frequency bands shown in thes
That's the way it seems with this ground issue. If I purchase an approved transmitter and I am told how to install it for maximum range (by elevation and long grounds). Then I am told by an FCC agent that it is in violation - what am I supposed to think? The product I purchased is now not doing what I expected. I realize that it is up to individual agent interpretation, but this is a most unsatisfactory way to go about a business. One of the reasons of paying for a certified device is peace of mind. How can purchasers of transmitters reduce the risk of being in violation? Do we have to practice the art of deception with the FCC and hope for the best? Do we tell customers in small print that we cannot be 100% sure that their installation will be deemed OK by the authorities unless they are mounted on the ground? Maybe we are giving the FCC agents ideas by discussing these issues openly on this site.
Gerry
Gerry posted: I wonder what the FCC agents would say if an elevated transmitter was supplied with isolated power and audio using transformers? The lines going up to the transmitter would still radiate due to RF coupling even though they are not directly DC connected. Also if you feed a ground-mounted transmitter with power and audio that is not isolated, the lines would still radiate anyway.
The type of isolation that is needed is for r-f (AC above the audio range), not DC. If that is done carefully, the conductors leading away from the tx and connecting to anything else will not radiate any significant amount of r-f, no matter what their length.
What an FCC agent might say about this is questionable, no doubt.
//
Gerry posted: Maybe we are giving the FCC agents ideas by discussing these issues openly on this site.
A reasonable guess is that the FCC has long known that elevated "Part 15" AM (whip/mast) installations with long, conducting paths to an r-f ground do not meet 15.219.
But what the FCC doesn't know (until discovered by them) is the location/operator of such installations.
A manufacturer of Part 15 AM transmitters posting information about how to install and operate them would do their customers a good service if they didn't publish/post statements that could lead those customers into installing such elevated/whip-mast systems with long, radiating paths to r-f ground -- which could lead them to conflicts with the FCC.
//
Manufacturers likely post this information when customers keep inquiring how to get better range - so it's easier to put it up on the website under the FAQ. You make a good point about doing the customers a service by not posting this type of information. Maybe the way to go would be to provide this information behind some sort of User ID/password scheme when someone buys a unit.
Gerry
Well,
an update to the situation is that there was more to this than just a extended ground issue. There were other issues i can't go into. if keith or the party who has the station want to chime in, but i can't say what it was. but apparently when they nit pick over the ground it's because they feel the operator is doing something wrong or trying to pull something over on them. They won't come out and tell you what. they'll just nit pick the ground issue.
Thank You,
Rev. Robert P. Chrysafis
Universal Life Ministries
http://www.ulc.org
Moderator Hunterdonfree
http://groups.yahoo.com/group/hunterdonfree
Rev. Robert and all:
That's good to hear that there are other circumstance involved.
I VOTE FOR NOT DISCUSSING GROUND WIRE LENGTH ANY MORE ON PUBLIC FORUMS! 🙂
I vote that discussions on subjects or topics which may be of interest and provide useful information continue.
It is disappointing that, once again, information is withheld and allusion to other mitigating factors is made without elaboration. I can understand that posters may not want to disclose all they may know regarding a specific event but ending discussion will leave us where we are...with incomplete information minimally useful as a guide.
Neil
Before we give in to paranoia, it might be good to consider something. If the FCC just wanted to "mess" with a part15 AM station, they didn't need to go to 15.219(b). All they'd have to do is tell you that your station is "causing harmful interference" as per 15.5.
Not knowing all the particulars, it's hard to second-guess the precise reason/intention, but I'd say that their calling 15.219(b) in this case and the church case more likely boils down to "if you're doing more than yardcasting under part15 then toe the line if anybody at all complains". They didn't tell either station they couldn't be on the air, just that the antenna had to more strictly comply with 15.219(b) if they were going to continue being on the air.
Harmful interference is no more defined than what officially constitues an acceptable ground vs a ground wire. They could just keep saying you were still causing harmful interference and then hit you with an NAL or citation for "willful" and/or "repeated" since they had talked to you and told you to stay off the air until it was corrected. On the other hand, if you drop the xmitter and antenna to ground level and it's not more than 3 meters tall total, then you it is obvious you did indeed comply.
But the FCC inspectors wouldn't be the only sort of inspector that will "trade technicalities" if they think someone is trying to pull something they shouldn't. For example, say the FCC drops by to tell a part15 operator that there have been complaints from local residents of indecent language occurring between the hours of 6 AM and 10 PM. The operator points out that he's part 15 and there is no specific rule about content for part15 stations that forbids it (say maybe they're running adult comedy occassionally for example, or allowing people who call in for a talk show to use any language they please). The FCC inspector says "Hmm well you have a point there. Oh and I couldn't help noticing your antenna doesn't meet with 15.219(b) specs. Fix that before you transmit again."
I picked that as an example largely because I very much doubt that this case or the church case were for indecent language. Rev Chrysafis specifically said that this station ran good family-friendly programming. But even though it was picked to not be the likely cause in this case, the general gist of the example is probably clear enough. If they were yardcasting then it isn't public and it wouldn't matter. If they're doing more than that, then there can be concerns which may not be specifically stated for part 15 but which the FCC feels should be attended to by any person or group transmitting radio on what are considered definitely public frequencies.
But back to my point, if it had been a matter of the FCC just wanting either station off the air, that could have been done many ways other than 15.219(b). 15.219(b) can be complied with even in the strictest sense by limiting the combined feedline, antenna and groundwire length to 3 meters.
Daniel
[added on an edit after reading Rich's post]
Basically I agree with Rich. The implication is that if they had been in compliance with the specs of 15.219(b), they wouldn't have had a problem. And if they corrected their system to comply with 15.219(b) then they were welcome to continue to operate. At least unless there is some data not being stated that is pertinent, that would be the simplest logical interpretation of the actions of the FCC in this case as it was in the church case.
PhilB wrote "I VOTE FOR NOT DISCUSSING GROUND WIRE LENGTH ANY MORE ON PUBLIC FORUMS! "
_________
I vote to bring this subject out of the realm of guesswork and wishful thinking so that Part 15 AM operators better understand how their antenna systems really operate -- which can lead them to an informed choice in the system configuration they decide to use.
Hints about the "real" reason for Part 15 AM citations being due to something other than an antenna system not meeting 15.219 apparently are desirable to some, but one wonders how this benefits them, or anyone.
If the systems in these citations actually met 15.219, the FCC would have no regulatory basis to cite them for not doing so.
The issue here is that printed documentation and posts from some Part 15 tx manufacturers encourage the buyers of those txs to install/use them with an antenna system that is non-compliant with 15.219, which exposes those buyers to FCC citations.
The subject of what constitutes a compliant antenna system with respect to the radiating conductors leading to an r-f ground should be made more public, rather than seeking not to discuss it. Avoiding or ignoring the reality of this subject does not make it go away, or minimize the risk of those who do so.
//
Oh yes. I found out that the hamilton rangemaster was type certified mounted at 6 feet above ground.
Thank You,
Rev. Robert P. Chrysafis
Universal Life Ministries
http://www.ulc.org
Moderator Hunterdonfree
http://groups.yahoo.com/group/hunterdonfree
I agree, a subject better left alone! It could be used by the nutty sorts to quench all Part 15 AM. I think already because this issue is so prevalent that if the FCC has trouble with a site it is the first thing they jump to. If you look at RM competitors talking sign and talking house they are ridiculously out to lunch on the ground thing. Why do we seem to take most of the flak? Maybe because I am more accessible I guess. The talking house ATU connects to the inside unit with up to 100 feet of coax, outside braid GROUNDED! AND from what I understand, they (like we do) recommend that the ATU be grounded down to a lighting rod for lightening protection. This puts ground all over the place. The talking sign provides a case grounded 50 ohm output for an external antenna and also has case grounded audio inputs. I would guess that the longer the cables, the more your radiation from that unit. Both these units were certified.
If you just take time to sit back and look at the FCC rules in general there are lots of areas that require some common sense interpretation. In reading subpart (b) just because it talks about ground lead and doesn’t define what ground is doesn’t mean that automatically means that it is saying all ground has to be the dirt and all part 15 transmitters (even indoor models) have to located 2 inches away from the dirt. Imagine walking down the sidewalk in NYC stepping over Part 15 transmitters because someone had to drill a hole in the sidewalk to get their part 15 close to the dirt. I too am getting tired of this issue. People just need to use common sense, things can be ground, not just the dirt. This is standard engineering.
I think it’s interesting about the fellow that had the problem, it seems that the RM unit was doing to good a job, a local broadcaster felt he was getting to much range (I wonder if he was taking rating points?) and probably called the FCC to shorten his range up a bit. From what I understand they said 20 feet high was to high but 10 feet was OK so go figure. I guess if he was covering a large area they perceived him as an issue, they are under pressure often from local broadcasters. The FCC are good guys usually and they probably felt like they had to go and at least do something. The fellow involved did the right thing by cooperating fully.
Wasn't my friend WNAR was it?
WDCX AM1610 Part 15
John
Owner-Operator-Chief Engineer-Program Manager
No it wasn't WNAR.
It was a nice retired fellow, I talked to him, won't give his name. He bought the unit used and was just having a good time playing oldies.
I had one other thought, maybe I am being paranoid but I wonder if some who purport the all ground must be the dirt thing could be part of the FM Part 15 transmitter industry. They would love to see their competition killed off. Since legal FM only gets shouting distance basically requiring ridiculous limitations on an industry (like having to locate an indoor product outdoors) could benefit their business.
I think our society as a whole suffers from LOCS (lack of common sense).
There was another Part 15 broadcaster using our unit a few years ago, he got some rating points in his area which made a local licensed broadcaster hot. (mess with people’s money and you find out something real quick). The local broadcaster called the FCC and told them there was a 1000 watt pirate broadcasting in the area when it seemed he knew that the signal was a legal part 15. Well when the agents (3 I think) drove 100-200 miles and arrived to find a legal part 15 they were mad. They did ask that the ground be rerouted I believe, the Part 15er had it routed horizontally over the top of a building, not a direct path to the dirt. When the Part 15’er rerouted the ground the FCC returned and gave the blessing. The part 15’er was allowed to stay on the air the entire time. As far as I know they are still on the air. A similar situation but with the more recent situation the agents were a bit tighter.
Neil you can call me directly if you want further information, Ill tell you what I can.