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I would like to conduct a survey of sorts. I have been reading many of the past topics about legal issues (long grounding leads, transmitters built from kits, etc). And I have heard lots of allusions to different stories of Part15’ers being visited by the FCC, but I am new to this all and I have never heard the stories that other people talk about.
The reason I am bringing this topic up again is because the pastor of one of the local churches wants me to set up a transmitter for his church. And I am still a little concerned about the various legal issues involved – especially since it’s not just an individual, but a whole church involved>
I would like to conduct a survey of sorts. I have been reading many of the past topics about legal issues (long grounding leads, transmitters built from kits, etc). And I have heard lots of allusions to different stories of Part15’ers being visited by the FCC, but I am new to this all and I have never heard the stories that other people talk about.
The reason I am bringing this topic up again is because the pastor of one of the local churches wants me to set up a transmitter for his church. And I am still a little concerned about the various legal issues involved – especially since it’s not just an individual, but a whole church involved>
I have read all the theory, but now I would like to know some statistics. 🙂
So my survey is as follows:
1.) Have you ever been visited by the FCC (while using a transmitter at Part15 power levels) and if so, what was the outcome?
2.) Also, do you know of any actual stories of Part15’ers -operating at legal power levels – being visited by the FCC, and what was the outcome?
3.) If you or someone was shut down, what was the reason?
4.) Are there actual instances where Part15’ers were shut down for having a long grounding lead, or using a transmitter built from a kit?
Total posts : 45366Try Phelgm’s FCC Enforcement Database
http://www.diymedia.net/fccwatch/ead.htm
His home page, obviously,
Total posts : 45366I did a cursory look of the stations listed and noticed the lack of AM stations on the list. I don’t want to read anything into this, but I have to wonder why.
PhilcoBill
Old Time Radio
650 KHz
Elkridge, Maryland
Total posts : 45366by MRAM 1500 kHz
I posted a similar survey request some time ago and there were no responses by anyone being visited. My intent was to dispell the rumors that the FCC targets Part 15 broadcasters.
Yes, Pirates as they are called running outrageous power levels show up on the FCC offenders page. And yes, there may be a few legal Part 15 stations that were visited because someone thought they were illegal even when there was no interference caused. None have been reported here recently.
Find a clear spot on the dial with no adjacent local stations. Follow the appropriate Part 15 rules. Don’t broadcast offensive material. You should be OK. Remember, even if you are 100% legal technically, you can be shut down if your station causes interference to a licensed service. That doesn’t mean you will be arrested or fined, just required to stop transmitting until the problem can be corrected.
Call an FCC Field office and talk to them about your intent. I would hope they will take a few minutes to listen to your concerns and answer your questions.
These same questions continue to be raised from time to time concerning enforcement of Part 15 of the Rules and Regs. The data provided by Phelgm URL only deals with violations on the AM and FM broadcast bands. And for the past 2-plus years, less that 2 dozen AM stations were even contacted concerning a violation. All the AM stations listed eventually came under continued scrutiny when the operators continued operation with “way” too much transmitter power over an extended period of time (most over a year). Most involved an FCC inspector visit AND a “postal” notification of apparent violation.
The movie “Dumb and Dumber” comes to mind when assessing the intellect of these folks. Absolutely NONE of the enforcement records show any complaints involving “improper grounding”, “antenna too long” or “uncertified transmitter”. And even though having an antenna too long or a homebrew transmitter could cause the station to exceed the FCC field strength limits, the notice of violation records show these stations way over the legal field strength limit (they aren’t even close).
Non-broadcast Part 15 enforcement logs show the biggest violators of Part 15 are WiFi and wireless telephones, all of which have to be FCC certified.
The enforcement records for the past several years do show increased activity by FCC inspectors. However, over 90 percent of the activity is concerning complaints involving FM transmitters. FM stations who run gain antennas or transmitters with input power exceeding 10-25 milliwatts or both, quickly find themselves in trouble.
Here is my suggestion for AM stations:
1. Run a transmitter only after extensive testing as to the purity of signal (no harmonics to screw up shortwave listeners). Measure and record all test data including type of modulating audio, transmitter input power and listening/test results.
2. Keep complete records of all transmitting equipment including purchase records and certification paperwork. This includes antenna, feed system, transmitter, audio processing and audio sourcing equipment.
3. Keep a log of equipment inspections and the result, and a log of operating hours and conditions. Sign/initial and date all entries.
4. Keep all documentation where you can get at it quickly and have it neatly organized.
5. Keep and file all letters from the FCC, listeners or compaintants. Attach a letter outlining the disposition. Include in the file any special community programming your station has aired (date/time).
6. Periodically, measure transmitter input power and “relative” field strength. Keep a record of all such testing.
These are more than “cover your backside” exercises. These are practices that will demonstrate to FCC inspectors you intend to be compliant with all of the rules and regulations. And any time you can make their job easier, they are quick to appreciate your efforts.
And finally, if they instruct you to turn it off until its repaired or the equipment is replaced, turn it off and do exactly as they request. After you have complied with there request(s), WRITE them a letter outlining the amelioratiing actions you have taken and when they were completed. Include in the letter, your test data. And continue to execute the list above.
If this seems like a lot of busy work, I have been inspected by the FCC on several occasions, as a broadcaster (non-Part 15), as an amateur radio operator and other radio services as well. I have never gotten a notice of apparent violation. I have done everything mentioned above. The key word here is “cooperate”. Of all the “bozo’s” in the enforcement log who got tagged with a “notice” or a fine, none really cooperated with inspectors or were responsible for communicating with the FCC. ‘Nuf said? What do you think?
Marshall Johnson, Sr.
Rhema Radio – The Word In Worship
http://www.rhemaradio.org
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Total posts : 45366I am just curious if you have any personal experience to offer.
Neil
Total posts : 45366by MRAM 1500 kHz
I’ve never had any notices or visits from the FCC. That’s a good thing. I have to much to lose just to have a larger coverage area for my station. I have an Amateur Advance Class license and a General Class Commercial Radiotelephone license. I’m sure the FCC would expect me to know right from wrong.
I’m sure a lot of us bend the rules a little but I’m not going to do anything to make it obvious.
Total posts : 45366mram,
My comment didn’t line up right. I was directing the query as to personal experience to the original poster, but thanks for your reply.
I too have an Amateur license at stake and that is probably why I am a little more concerned with the letter of the rules than many would like to see in my comments.
Neil
Total posts : 45366I too have multiple licenses (Amateur Extra Class + General Radio Telephone Operators License), plus FEMA and State of Oregon em-com certifications at stake.
Having consulted for the FCC in helping folks with interference and rules violation problems, you quickly learn the meaning of the word “egregious”. The inspectors and field engineers I worked with emphasized approaching potential or possible violations with an even hand. Most radio people usually don’t know they are in violation. And when the deficiency is pointed out, along with a possible solution, most were quick to fix things. But there are, seemingly always, the operators who write their own rule book. These are the folks you read about in the FCC enforcement logs.
When you are the consultant sent to rescue the scofflaws from the jaws of the FCC, you quickly discover you are dealing with a different animal. These are the folks the FCC keeps a close eye on. And as a consultant, you never trust these people to do what they say they will do. They will say anything to save their skin and their station. Covering you backside and documenting everything with logs and pictures becomes essential.
If you, or someone you know, doesn’t fall into that category of radio station operator, you really have little to worry about.
All FCC regulatory Parts, including Part 15, have one or two issues that drive inspection efforts for that particular radio service. Part 15’s inspection focus is range/field strength respective to antenna system length and transmitter input power. Additional consideration should be given to the fact that Part 15 deals with a bunch of “intentional” radiators. Wireless phones, garage door openers, WiFi (in several flavors), audio/video linking, microwave ovens, broadband over power lines, medical technology and a variety of remote control and security devices all fall under some section of Part 15.
Part 15 broadcasting is a sliver thin segment of the radio service under regulatory control by the FCC. 90 percent or more of all Part 15 broadcasting inspection visits are in the FM service. The notices of apparent violation dealing, almost exclusively, with “no license” and “field strength at X-distance is over acceptable regulatory limits”. In fact most of the reports I have read, the station is operating at significant multiples of the legal limit. In every case I have researched, the reason for excessive field strength has been too much transmitter input power (usually in excess of 5 watts). 10 to 25 milliwatts on a modest antenna is really all that is needed.
I have designed, built and licensed LPFM stations of 2-3 watts that cover an entire small city. And the signal is quite respectable on table radios indoors.
In conclusion, I assure you the folks in the FCC enforcement logs are station operators who have not taken the effort or the time to consider whether their transmitter/antenna systems are anywhere near compliant with the Part 15 rules. On the other hand, all of us need to be vigilant and continually test our equipment and stay current on record keeping and changes in the rules.
Marshall Johnson, Sr.
Rhema Radio – The Word In Worship
http://www.rhemaradio.org
Total posts : 45366[quote=kk7cw]…90 percent or more of all Part 15 broadcasting inspection visits are in the FM service. The notices of apparent violation dealing, almost exclusively, with “no license” and “field strength at X-distance is over acceptable regulatory limits”…. 10 to 25 milliwatts on a modest antenna is really all that is needed.[/quote]
But recognize that 10 to 25 milliwatts applied to a simple 1/2-wave dipole produces a field far above the FCC limit for Part 15 FM. That takes only ~11.4 nanowatts.A power of 10 mW radiated from a 1/2-wave dipole produces a 234 mV/m peak field at 3 meters — which is ~937X higher than the Part 15 FM limit.
I believe there are examples in the FCC EB list where the action was taken based on 10 mW or less of radiated power.
This is not to “bash” people that do, or suggest doing this, just to inform them of the numbers, and possible detection risk.
Total posts : 45366Hello all,
To add to Marshall’s and Rich’s comments I offer a mini study which I posted on another site which is copied in part below in case you didn’t see it. Granted there may have been other factors which attracted the FCC’s attention (such as objectionable content or interefence) but the field strength measurement was the basis for the actions. In several of the NOUOs that I studied the calculated ERP from the antenna was well within the capabilities of commonly used FM transmitters. Based upon my calculations, the citations are not reserved for operations using tens to hundreds of watts.
I do not suggest that you will have trouble with a high field strength, rather that you could have trouble, even with milliwatt levels of ERP. My intent here is to add to the pool of knowledge regarding part 15 FM operation.
Here is what I did:
I was curious about the FM transmitter power levels involved in FCC NOUO (notice of unlicensed operaton) actions so I did a bit of research. The FCC states in the NOUO the measured field strength at a distance. From the FCC site, I selected some NOUO reports for FM and noted the field strength and distance. I then calculated the approximate ERP involved with each of these.
I used the following assumptions to calculate the ERP:
1. The peak free space field strength produced by 11 nanowatts ERP at 3 meters is 250 uV/m.
2. The antenna is a resonant dipole. (Actual antennas may have more or less gain than a dipole so these numbers do not represent the exact transmitter output power.)
3. The field strength increases linearly with distance upon approaching the antenna.
4. The distances and field strengths reported by the FCC were accurate.
I derived the equation
ERP(mw.) = (19.6 x 10^-12) x [ FS(uV/m) x distance(meters) ]^2
to give the approximate ERP. Using this, I calculate the ERP numbers below.
FCC NOUO resulted from these calculated estimates of ERPs expressed in milliwatts:
93., 357411., 6.7, 0.001, 289., 0.703, 577., 120., 0.187
Neil
Total posts : 45366The micro power FM broadcasters who get a letter or a visit from the FCC are operators openly and unabashedly violating more than just Part 15 rules. I did mention in my previous comments the use of “gain antennas”. Gentlemen, a half wave dipole in the world of antenna design IS a gain antenna. I don’t care what the antenna catalogues say. I design and manufacture commercial and amateur antenna systems. The theoretical “no gain” antenna used by the FCC for field strength comparisons and analysis is the famous “isotropic” system. Theoretical gain is zero.
However, in the real world, we use shortened antennas (less than 1/4 wavelength, gain less than zero), 1/4 wave antennas (gain near zero) and antenna systems in multiples of 1/8 wave increments from 3/8 wave to 3/4 wave. The longer antennas are specifically used for gain and pattern shaping. ERP is a product of antenna gain. Antenna systems are a complex combination of gains and losses. As broadcasters we are most concerned with the NET gain or loss of the system.
Additionally, how does the Part 15 broadcaster who desires to operate within the letter of the rules and who does not possess a degree in engineering, decades as a practicing broadcast field engineer or a bench full of lab quality test gear, determine whether his operation is legal or not? If antenna length/gain is not definitive, if transmitter input power is not definitive, if relative field strength won’t help and if your receiver is not a benchmark, what is?
The word “intent” is the key to any FCC violation. Ignorance of the rules is not protection under FCC administrative law. But lack of intent to violate the rules is. That is why I recommend keeping complete and accurate records of how you operate and what you broadcast. Remember, there is NO freedom of speech when it comes to the Communications Act of 1934.
In Portland, Oregon or Berkley, California or San Diego operators were visited because of the openly advertised “pirate” status of the stations. Upon visiting the stations blogs and web sites, I found that the transmitters and antennas systems in use would make a licensed lpfm’er drool. Most, and I repeat, most of the enforcement log contains entries from stations and operators who blatantly claim ignorance of the rules or openly advertise their illegal radio operation. If Iwere an FCC inspector and it was brought to my attention that a radio station in my area was using the skull and cross bones as their logo and banner, I would take a second look.
So, before we calculate the ERP of the sun and make a computer analysis of its ability in nano-watts to stay within the rules of Mother Nature, let’s “dumb it down” so that the regular hobby broadcaster GETS IT. Understanding, finally, that after decades fo rulemaking and experience the FCC and federal regulators are STILL trying to reach the same goal.
Marshall Johnson, Sr.
Rhema Radio – The Word In Worship
http://www.rhemaradio.org
Total posts : 45366Hi Marshall,
I believe I understand what you wrote and I did not comment on any of it, so I wonder what point I missed. I simply reported on a paper experiment I performed using published FCC data.
You wrote: “The micro power FM broadcasters who get a letter or a visit from the FCC are operators openly and unabashedly violating more than just Part 15 rules.” I believe I allowed for that in my comments about interference and objectionable content, however the citations I used are for exceeding the allowable field strength. I tried, with my study, to demonstrate the very low power levels (calculated) which resulted in actual public record FCC action.
Since I used ERP, the antenna gain is irrelevant in that ERP includes the antenna gain. I also made no claim about the actual transmitter output power other than to state that the ERPs I reported are possible with low milliwatt transmitter output. Pick an antenna gain from -10 dB to 10 dB, which I trust you will accept as a typical and reasonable range for part 15 FM, and the field strength from a 1 mW. transmitter is still above the limit.
If, as you suggest, we should “dumb down” this so we can provide guidance for those who wish to operate legally, then I offer “if you can receive your FM transmission beyond 200 feet on a car radio, then you are exceeding the allowable field strength”. Though this does not directly relate to the numbers, it does represent the intent of the FCC rules as stated in their public notice on the subject.
Neil
Total posts : 45366[quote=kk7cw]
The theoretical “no gain” antenna used by the FCC for field strength comparisons and analysis is the famous “isotropic” system. Theoretical gain is zero.The gain of an isotropic radiator is not zero, it is zero dBi — and that is about 61% of the peak field gain of a 1/2-wave dipole.
If you want to base the radiated power needed to generate the peak legal Part 15 field while using an isotropic radiator (which doesn’t exist), that value is 18.75 nanowatts. Still a lot short of 10-25 milliwatts.
However, in the real world, we use shortened antennas (less than 1/4 wavelength, gain less than zero), 1/4 wave antennas (gain near zero) and antenna systems in multiples of 1/8 wave increments from 3/8 wave to 3/4 wave.
All of which above will generate considerably more than the legal Part 15 field with 10-25 mW of applied power.
Additionally, how does the Part 15 broadcaster who desires to operate within the letter of the rules and who does not possess a degree in engineering, decades as a practicing broadcast field engineer or a bench full of lab quality test gear, determine whether his operation is legal or not? If antenna length/gain is not definitive, if transmitter input power is not definitive, if relative field strength won’t help and if your receiver is not a benchmark, what is?
That’s why the FCC has a certification program. Using a Part 15 certified FM tx with its integrated antenna, all set up and operating as per the manufacturer’s instructions eliminates the need for an operator to be concerned about compliance issues.
Total posts : 45366Rich,
The “nanowatts” you mention is the amount of RF energy radiated by the antenna conductor. The power level I mention is the transmitter final PA input power. They are different; quite different.
The use of a lossy antenna would allow 10 to 25 milliwatts of transmitter input power to produce the appropriate power for legal field strength. The whole theory behind the Part 15 rules is to control field strength with the use of lossy antennas.
FCC certification does NOT ensure legal operation either. Just ask the folks at Ramsey Electronics. They are unable to certify their Fm-30 transmitters now, after some folks decided to buy export transmitters and blame the manufacturer for their misuse. That’s like blaming auto manufacturers for the irresponsible use by a driver of their make of car. If you talk with Keith Hamilton (one of the good guys) about violating the letter of the rules with a Rangemaster transmitter, he will tell you they can be operated outside the rules and regs. Part 15 certification of hobby broadcast transmitters falls under the same set of rules as ALL other Part 15 devices. The Part 15 enforcement log includes plenty of entries for interference produced and operating outside the rules by all kinds “certified” Part 15 devices.
Regarding the isotropic antenna. You are exactly on target. There are no real-world isotropic antennas. But theoretical gain, at least in popular publications on the subject, puts the gain figure of a dipole at 2.26 db gain over that of an isotropic antenna.
That would make the gain of a 1/4 wave and the theoretical isotropic very close to one another, with the 1/4 wave system winning out due to non-linearity in the radiation pattern. AM broadcast rules have used this thumbnail comparison for over 50 years.
Your text books may not use the same figures or definitions, but broadcast engineering practice for the past half century certainly has. And as far as I know, no major university in my part of the world even have qualified professors to teach broadcast RF practice. That is not to mention the new crop of broadcast engineers who are very good in digital communications techniques, but digital communications do not require the sensitivity of impedance matching required by the electronics of yesteryear. I have taught such courses at a four year university at the invitation of the Department Head, mostly because they have no experience in the field. Some things you can book learn, some things must be learned by doing.
But, I digress. Sorry. The fundamental question remains how do uneducated everyday hobbyists stay comfortably inside the boundaries of the current Part 15 rules and regulations?
I have asked this question on several boards and groups, and as yet no one has been able to offer a satisfactory fool proof solution or answer. Until someone does, the FCC will continue to apply the rules based on the personal interpretation of individual inspectors. The rule of law works poorly in that environment. The first time you get bit by that kind of legal system, I suspect you won’t like it. I know I don’t.
The original forum topic deals with the FCC enforcement of the current version of Part 15 regulations dealing specifically with part 15 broadcasting. And I hope you would agree, the Part 15 rules dealing with hobby broadcasting are sadly lacking. So, has anyone been sent a letter or been visited by the FCC for a violation of Part 15? My money is on, “there will be few takers.”
Marshall Johnson, Sr.
Rhema Radio – The Word In Worship
http://www.rhemaradio.org
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