Total posts : 45366
If the tuning circuit of the transmitter were modified so that it could feed a quarter wave monopole, the field strength reading can be easily achieved. A long enough ground lead should also be able to obtain the stated field strength, but this would be a very long ground lead indeed.
The NOUO suggests that the FCC has decided that a field strength reading above some limit (maybe above 15,000 uV/m at 30 m — just a guess)is prima facie evidence that the requirements of Section 15.219 are not met, regardless of what the ground lead length is. In case someone is using a, say, Class EE+ transmitter with a superconductive loading coil, he can argue his claim that he is compliant with 15.219 in his response to the NOUO.