Home › Forums › temp › Part 15 AM legalities, citations, and manufacturers’ advice › This is getting difficult
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Once again you have posted an excellent commentary and I really appreciate your thought provoking approach to the subject. I hope what I have to say in response adds to what you have said.
You mentioned knowing the history of how we got here. We do. Around 1937 the FCC rules were extended to allow for “phono oscillators” for the purpose of allowing the production of phonographs which could work with existing and expensive radios (about 1 week’s pay from what I have read) without requiring duplication of the audio amplifiers and speakers. Due to the difficulty in measuring field strength as specified in 15.209, part 15.211 was established as prefaced in 15.211 in the ’50s by the phrase “in lieu of field strength limits in 15.209…”. In subsequent revisions, this became 15.219 and the phrase “in lieu of ” was dropped, though it appears that this makes no difference since we can choose 209 or 219. One point to infer is that the original intent was not for anything other than personal use of these devices in one’s own home; that is to say community broadcasting was not and is not the intent of part 15 rules.
Through clever advances in technology we now have the means to achieve ranges which were never intended in the original rules. Our advantage is that the rules have not been revised to further limit the AM range so it would only work in one’s home.
You also discussed that we should obtain information. I agree, yet my attempts to put aside opinion and gather real facts have not bourn fruit. Recently, on another board, I asked the operator of a part 15 AM station which “passed FCC inspection” to share the details of his installation. One poster said it was not proper to badger him since his station was “approved” and that he did not need to justify anything to me. All I sought was information about a station which is “legal” so we may get some guidance yet there is no information forthcoming. We have the situation of the citation of a church, yet we really do not know the facts in enough detail to understand what really happened. I have seen statements alleging that many “elevated” transmitters were inspected and cleared by the FCC yet there is no data of which I am aware, anecdotal or otherwise, which enumerates those who were and those who were not. We are left to speculate that it is “up to the FCC inspector” and the installations detailed on the Rangemaster site “may be a gray area”.
It may well be that if one reads the actions on the FCC site one gets the impression that few AM part 15 operations are cited and that may indeed be the case. It may also be true that we need not worry about enforcement against ground leads which are 20 feet long. This thread is full of opinion and I really wish we could start getting some facts. Lacking this I tend to take the literal mathematically and physically supported position that the rules address the ground lead length to be from the transmitter to the dirt.