Total posts : 45366
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.
