- August 21, 2007 at 2:09 am #6985mojoeParticipant
Total posts : 25
I’m going to relate a recent experience with the FCC, but before I do, I want to make it clear that I don’t want this to degenerate into a discussion about ground wires and such. I am only posting about this to relate a positive experience that I had with the FCC regarding my Part 15 station. I would appreciate that any questions pertain directly to my interaction with the agent and not technical aspects of my installation. I have already explained my installation to the satisfaction of the agent and don’t need to do so here. (Sorry for the preface, but regulars here understand why I thought I needed one.)
A little while back, I got an email from an FCC agent. I replied and offered to email my station documentation. The agent said he’d like to see the documentation and we also coordinated a time for a phone conversation. During our conversation, the agent asked me a few simple questions about my installation. I answered each one and was very open about what I was doing. I made it very clear that I was operating under Section 219 of Part 15. The agent was satisfied with my answers and was impressed with the documentation that I had emailed him. He concluded that I was operating legally and that no visit was necessary. I told him that any time he was in town, that he was welcome to physically inspect the station.
Although I was apprehensive at first, the whole experience turned out very well. The agent was very pleasant and we had a nice chat about my station and Part 15 related issues.
As to what prompted the FCC agent to contact me, it was a complaint, of course. The agent would not divulge who the complaintent was. I described to the agent how my station ID’s every hour and how every three hours, I announce the Part 15 nature of my station and give an email address for contact. Doing these things make it very clear that I am not a pirate and am trying to operate within the very limited confines of Part 15.
One interesting thing about all of this: the agent was not familiar with the SSTRAN transmitter. He was familiar with the Hamilton. I assume that this is because of the kit vs assembled nature of the two. In an email, I had pointed to the SSTRAN web site and also the antenna plans that I was using (I included my modifications in my documentation). The agent was very impressed with both the kit and the antenna. Kudos for Phil.August 21, 2007 at 2:26 pm #15901radiopilotGuest
Total posts : 45366
Glad that you had an excellent going with the FCC agent, as I’ve told many here and in the other ‘radio boards’, that going to the FCC and either setting up an appointment for the agent to stop by and or send the documentation for your station in to them is a very good thing to do, as you has just witnessed.
In the past several instances where the agent stopped by my station to chat, never have any negative comments been talked about the station, the ground, the antenna, etc.
They have all the documention neatly in a folder next to the sation (in fact better than most licensed stations), and they have commented very favorably to the point of helping me get a LPFM license, so that paperwork is already submitted for the next LPFM window.
Mojoe, I too have the SSTRAN and when he saw the transmitter up 35 feet in the air, he wanted to hear the music being played and commented how very good the transmitter was sounding for a mere 100mw., as he was used to 5-50kw stations and how bad they sounded due to bandwidth limitations.
Thank you for posting your comments, it’s something all can learn from and perhaps remove that fear of the FCC as they work for us and it in your interest to get them on your side now.
Another comment is had you sent your station documentation in alot earlier (prior to the complaint), do you believe the FCC would have contacted you since they ‘already’ knew who the broadcaster was and how much power along with the fact it was a legal part15 broadcaster?
Did you mentioned to him what would happen again if another ‘licensed’ broadcaster or other complaint came in to the FCC office?
RadiopilotAugust 21, 2007 at 8:07 pm #15903mojoeGuest
Total posts : 45366
I don’t know whether contacting the FCC upfront would have made any difference. The agent wanted to talk to me on the phone, as opposed to via email. I don’t think just documentation would have satisfied him (although it helped a lot).
Personally, I don’t think upfront contact is a good idea. They are too busy and probably don’t want to be bothered unless there is a complaint (I was told there are only three agents for this area of the country). As others have mentioned, because of the staffing, they are mostly complaint driven.
As for being contacted again, if they get another complaint, they have to investigate. The only time they wouldn’t bother is if it was an obvious case of repeated complaints by the same individual, in an effort to harrass me. This type of thing has been known to happen.
Speaking of commercial stations, we only have two AM stations here. One of them is using WAY more bandwidth than they should. They have been like this for years. I don’t know how they get away with it.August 25, 2007 at 7:02 pm #15922Ermi RoosGuest
Total posts : 45366
I was a circuit design engineer (including RF circuits) for a medical device company for several years, and there were many FDA inspections. Since the inspectors were allowed to ask any employee anything, all employees received training in how to talk with the inspectors. It appears that FDA enforcement is quite a bit more aggressive than that of the FCC, but inspectors from all of the government agencies behave according to the same principles. So, I thought I would releate what I was taught about inspections and inspectors.
There are routine, or scheduled, inspections, but a Part 15 operator is likely to be inspected “for cause.” This is a serious matter, since the purpose of the inspection is to determine if the rules are being complied with, and to gather evidence against you. One interrogation technique is to be friendly and chatty. Don’t let your guard down. While you may think you have nothing to hide, you may reveal something that may not seem important to you, but could be very significant to the inspector. Another interrogation technique is using awkward silences. The rules of social interacton require filling in the silences, but keep your mouth shut! You might blabber something significant that can be used against you.
When you do speak, speak only the truth. If you don’t know the answer to a question, say so. If you don’t completely understand a question, ask for clarification. Do not answer overly broad questions. Try to narrow the scope of your response. Don’t argue.
If you give the the inspector any document, make sure you have a copy. The FCC will not give you a copy of the document you submitted. They will first insist that you submit a Freedom of Information request, and then they will not honor your request because the file relates to an ongoing investigation. This is the way the FDA behaves, and I have seen from reading forfeiture orders that the FCC behaves that way, too.
So, it is good to be honest and cooperative with the inspectors, who everybody says are “nice guys,” but be prudent too, and protect your interests.August 28, 2007 at 12:31 pm #15923SaGRGuest
Total posts : 45366
What exactly did you offer up as documentation?
I think designing a standard packet for all of us to have on hand would be a good idea.August 28, 2007 at 8:37 pm #15924radio8zGuest
Total posts : 45366
It seems to me that, if you choose to provide documentation to the FCC, all you have to do is demonstrate compliance with 15.209 or 15.219.
Part 15.219 states:
Section 15.219 Operation in the band 510 – 1705 kHz.
(a) The total input power to the final radio frequency stage (exclusive of filament or heater
power) shall not exceed 100 milliwatts.
(b) The total length of the transmission line, antenna and ground lead (if used) shall not exceed 3
(c) All emissions below 510 kHz or above 1705 kHz shall be attenuated at least 20 dB below the
level of the unmodulated carrier. Determination of compliance with the 20 dB attenuation specification
may be based on measurements at the intentional radiator’s antenna output terminal unless the intentional
radiator uses a permanently attached antenna, in which case compliance shall be demonstrated by
measuring the radiated emissions.
Based on this, it seems reasonable to document that your input power is less than 100 mW, your antenna, line, and ground lead length total is less than 3 m, and your out of band emissions are less than -20dBc.
If you are using a certified transmitter, the first and third requirements should be met and defensible by the certification. The second, antenna etc. length, varies with the installation and perhaps could be detailed.
The other option is to let the inspector determine compliance if you are visited.
I will also add, having been an inspector in other technical matters, that the responsibility for me was to validate that the information submitted was truthful and accurate. I don’t know the FCC’s policy on this, but mine was to personally inspect and interview as needed.
I will defer to the experience of others as to whether a preemptive or upon request response to the FCC is appropriate.
Am I oversimplifying this?
NeilAugust 29, 2007 at 2:50 am #15925mojoeGuest
Total posts : 45366
My documentation consists of:
– the assembly manual for the SSTRAN transmitter;
– the assembly instructions for the SSTRAN antenna;
– a document showing my modifications to the SSTRAN antenna;
– a document that I put together listing my frequency, location, name, contact info, date of first operation, statement of purpose, overall description of station hardware (with some pictures) and a station log.
In my email, I sent everything but a copy of the transmitter assembly manual, as I didn’t have it scanned. I referenced the SSTRAN web site for both the transmitter and antenna. I also included a picture of my rooftop installation.
All of the above documentation is in a folder and can be instantly presented for inspection if needed.August 29, 2007 at 6:42 pm #15927radiopilotGuest
Total posts : 45366
My comments follow along the lines Mojoe has given to the FCC, except since they came over to the actual location I was able to show them schematics of the installation drawn into CAD program printed and in the folder along with the SStran transmitter documents, the audio chain component list, antenna specs (coil, antenna info along with similar coil/antenna info from Hams, rf antenna engineering text, etc.)
It has a schematic of the radials along with the wire gauges, height of the antenna, grounding, etc., the installation down to the screw and nut, along with the frequency of broadcast, logs, and radius of coverage (estimated based on driving tests) and listeners to the station that have called in.
There is a schematic of the various components and cable runs (not that the FCC needs this) but it gives them an indication you are serious about what you are doing and not just transmitting via a ‘pirate’ operation.
As Neil states above you ONLY need to show compliance to the Part 15.219 and it’s emissions but this is only part of what you need to show the FCC if they decide to show up at your door. It’s best to be prudent and not hide anything.
Best is document everything about your station as best as you can regarding the Part 15 rules then be ready to show them everything to the best of your knowledge that you are in compliance let them determine if you are or not.
I’ve yet to have any problems for almost 3 years that I’ve been on the air constantly.
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