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“Cranking the numbers in this citation shows that a radiated power of about 9 nW from a 3-m vertical will produce a groundwave field of around 27,000 µV/m at a radius of 35 meters. So apparently this operator wasn’t doing anything not permitted by 15.219.”
There is no way… a 100mw Am transmitter would do this at 27,000uV/m at 35 meters….
I calculated that this person was using 20 watts and probably was using a TIS/HAR transmitter with anywhere between 20-30 watts of power depending on the gain of the antenna….
You are right to believe there is some suspicion with the quote above.
9nw is not the 100mw the FCC defines as the Part15 power for AM and this amount of RF would go no further than the room the transmitter would be in!