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“Under FCC ¶15.239(b), unburied “ground” conductors of every physical orientation are not allowed”
But, “The position of the FCC as to whether or not elevated horizontal wires used as a counterpoise for, and/or to “top load” a monopole must be included in the 3 meter total permitted by ¶15.239(b) is unknown”.
This makes it very difficult to determine what is or is not acceptable. A counterpoise serves as an RF ground system. When unburied it must be symetrical as opposed to a buried “offset” counterpoise so as not to radiate. The same applies to top hat loading.
So, what you have told us is per ¶15.239(b) ALL UNBURIED GROUND CONDUCTORS OF EVERY PHYSICAL ORIENTATION ARE NOT ALLOWED and the position of the FCC on elevated (unburied), non-radiating ground systems is unknown.