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It seems to me that, if you choose to provide documentation to the FCC, all you have to do is demonstrate compliance with 15.209 or 15.219.
Part 15.219 states:
Section 15.219 Operation in the band 510 – 1705 kHz.
(a) The total input power to the final radio frequency stage (exclusive of filament or heater
power) shall not exceed 100 milliwatts.
(b) The total length of the transmission line, antenna and ground lead (if used) shall not exceed 3
(c) All emissions below 510 kHz or above 1705 kHz shall be attenuated at least 20 dB below the
level of the unmodulated carrier. Determination of compliance with the 20 dB attenuation specification
may be based on measurements at the intentional radiator’s antenna output terminal unless the intentional
radiator uses a permanently attached antenna, in which case compliance shall be demonstrated by
measuring the radiated emissions.
Based on this, it seems reasonable to document that your input power is less than 100 mW, your antenna, line, and ground lead length total is less than 3 m, and your out of band emissions are less than -20dBc.
If you are using a certified transmitter, the first and third requirements should be met and defensible by the certification. The second, antenna etc. length, varies with the installation and perhaps could be detailed.
The other option is to let the inspector determine compliance if you are visited.
I will also add, having been an inspector in other technical matters, that the responsibility for me was to validate that the information submitted was truthful and accurate. I don’t know the FCC’s policy on this, but mine was to personally inspect and interview as needed.
I will defer to the experience of others as to whether a preemptive or upon request response to the FCC is appropriate.
Am I oversimplifying this?