Total posts : 16
These same questions continue to be raised from time to time concerning enforcement of Part 15 of the Rules and Regs. The data provided by Phelgm 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 input power exceeding 10-25 milliwatts or both, 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 compaintants. 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 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 its repaired or the equipment is 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