Total posts : 45366
“In our discussions with the FCC massive metal that is connected to the dirt, such as a water pipe, can serve as an acceptable ground. I have been told that the FCC generally won’t interfere with a site engineers decision (if the site engineer decides to call a water pipe ground) unless the decision seems outlandish. We feel a large piece of wire, coming up from the dirt can also be called ground at the top tip. As long as the wire takes a direct path straight down to the dirt, this is best for lightning protection. We have had this set-up pass FCC field inspection many times. Our transmitter was certified using this configuation. “
I think the key word in that is “acceptable”. That the Rangemaster was approved with that type of configuration indicates that at least at the height it was mounted at the certification with the guage of wire used, it was found “acceptable enough” in that instance whether or not it constitutes a textbook definition of a “true rf ground”.
In the practical sense, it doesn’t matter what a manufacturer feels, what a website or textbooks says or what anyone thinks.. What it’s going to boil down to is what the inspector looking at it judges as acceptable so far as if one gets written up or is told they can’t do it as they have it currently set up. Not unless you get told it can’t be a certain way or get written up and you officially contest it. Then it may make some difference, but in the sense of avoiding trouble, all the definitions in the world may not keep it from happening. Basically if you’re “pushing the envelope”, then it’s a possibility if a local licensed station or whoever wants you gone. They complain, the FCC will check you out.
But let’s be realistic here, that’s their job. They also check the licensed stations to make sure their tower is properly labelled, their power is in the right range, they’ve been properly keeping the assorted logs including the ones showing how the station does stuff for the local community and so on. They know they have a trained engineer (also licensed by the FCC), that the licensed station was properly set up with a certain number of radials in their grounds system, and on and on. There is also a sizable amount of money/property involved in most licensed stations, so they aren’t usually just going to get annoyed with the biz or move and leave that area without media.
On the other hand, we’re unlicensed, anybody can build a little transmitter, no engineer has to check it out before it goes on the air, no logs are required, and so on. Even if a part15 is doing a really great job of serving a part of the community, there’s no guarantee at all that they’ll still be on the air tomorrow. Heck, we don’t even *have* to identify ourselves on the air with so much as a station name and city.
So why should they favor a part15 station over the licensed stations? They’re licensed and have a considerable number of rules to follow to make sure they operate it right and at least somewhat serve the community. We’re unlicensed and have very few rules, none of which other than “don’t cause interference” actually deal much with how to operate it as a station.
Then consider that, being unlicensed, pretty much the only way they ever run into a part15 station is when there’s a complaint. It’s kind of understandable why they’d be biased towards the licensed stations. Also consider that the FCC historically has generally considered that the public interest on the public broadcast airwaves is best served by big stations rather than small ones. A few big stations is a whole lot easier for them to take care of than a lot of small ones, and we’re even further down the scale than just small. Their manpower and resources are not unlimted, especially in these days of tight budgets.
Now stop and consider that for decades, part 15 stations were at most “yardcasters”.. But with fairly recent innovations, now (at least on AM) they *can* get ranges of a mile or two. I think that Rich said that the theoretical range was between a mile and 2 miles to a good reciever, so well say that 1-2 miles is at least theoretically acheivable by practical means. Maybe it takes a decent receiver to pick it up at that range, but over most of the decades part15 has been around for it would have taken a decent receiver to even pick it up right across the street from the house the xmitter was at. And at least theoretically, a “network” of synched transmitters spread out across a city *could* cover an area well enough that was sufficiently large to possibly challenge a licensed stations for listeners. Ok, much as we *like* those innovations, it is going to result in some of the licensed stations viewing us no better than they do the pirates and filing complaints. Heck, unless they really keep up on recent developments in part15 technology they’d assume that anything with that much range would *have* to be a pirate. So would the FCC until they check it out. But an encouraging point is that even when they’re busting obvious FM pirates, they always look to see if it *could* be a part 15 FM by the field strength, that policy shows right in the wording of those NOUOs. And for part15 AM they certainly seem to be standing by the specs of 15.219(b).
With the licensed stations, you don’t think they report pirates because as licensed stations they stand for truth, justice and the American way (and have to keep away from kyptonite), do you? They report pirates because they are competition. Because pirates could take some of their listener base, which will reduce ad revenues, which will result in loss of money. That’s what it’s going to be about. And they can justify their paycheck to their board of directors or corporate stockholders by saying they eliminated a threat to the station’s income. But so far it *looks* like the FCC won’t just shut down a part15 AM station for just existing, so long as it’s strictly by the provisions of 15.219(b). No guarantees of you’re in a “grey area” on those rules, they might pass it, they might not, but it’s probably best not to count on any slack.
So while this is the way it is, it doesn’t mean it’s the way it always has to be. And what we’re permitted isn’t all that bad. You can bet it’s more then the licensed stations and the NAB wish anybody (other than their people) be allowed to have.
I’m going to be honest on one point, though.. I think that the more we use “grey areas” to push the range, the more chance we have of a new set of part15 regs being drafted that will just outlaw at least some of what we’re definitely permitted now. I also feel that probably using synched multiple transmitters to make a “network” to cover any sizable part of a city is likely to lead to local licensed stations really wanting us just gone. And they’re the ones that pay fees, have big lobby groups, and etc. Underserved areas might get cut a bit more slack, but in areas that already have several or many local stations, that “grey” is going to go to black and white real fast when the licensed stations start viewing you as competition. Or even as something that’s handy for them to justify their paycheck to the stockholders by eliminating.
I checked back on the threads, and Rich calculated the range to a good car radio to be 1.5865 miles. I’d bet the FCC is quite capable of doing the same calculations and already probably has, and anything much over that approximate range is going to get looked over very closely if a local station gets upset over the possibility of losing some listeners to you. But that is *not* a minor amount of range, especially in a town or city. Draw a circle like that on a map around your location and it’s likely to be quite a lot of streets and houses.