Rich
Full Member
RF Systems Engr (retired)
Posts: 112
|
Post by Rich on Feb 21, 2019 14:26:26 GMT
RE: ... don't argue over what you think the rules should be. Just follow the rules.
The issue here is that often those rules are not clearly expressed or understood.
For an infamous example, a "ground lead" as stated in FCC §15.219(b) is/was considered by some Part 15 AM operators to be limited to a short wire (~12" to 18") leading from the "ground" terminal of the transmitter to anything else, including a conducting path such as the top of a 20- to 50-foot tall, grounded, metal tower or pole.
But in reality, the physical length/height of the entire conducting path that exists from the transmitter ground terminal PLUS all other conductors connected in series with it will radiate. That total length added to the ~3-meter "whip" antenna easily can make the radiating length of that antenna system exceed the 3-meter limit of §15.219(b).
This point is almost impossible to learn about without "input" from other than the FCC Rules, such as via the various Part 15 websites.
|
|
|
Post by End80 on Feb 21, 2019 14:43:50 GMT
|
|
|
Post by End80 on Feb 21, 2019 15:01:12 GMT
... my research concludes that in spite of it, it is very clear that the length of the ground lead is not a genuine concern to the FCC and never what gets a part 15 station shut down - the lead is only the justification for a citation to be issued... But the only thing that leads to an AM part 15 to be shut down is -always- for ranges exceeding about a mile. Now you can call that all opinion, but it is fact. ... It is also a fact (of physics) that a "long" conducting path attached to the r-f ground or chassis of an elevated Part 15 AM transmitter adds to the ~3-meter length of a whip antenna attached to that transmitter. Other things equal, that increased radiating length produces greater coverage areas for that system than if the radiating length was limited to 3 meters. So if it exists, a long ground lead can lead to an FCC citation. Very rarely has the FCC ever referred to received field strength or "range" when issuing an NOUO based on §15.219.
I'm putting this here as a placeholder and will respond later today, but I have to leave now....
Ok, it looks like we're not working today after all..
Rich, I agree all your points above are accurate, every one of them. But by examining all the high profile part 15 AM installations in history reveals the undeniable fact that part 15 AM installs have never been required by the FCC to meet the 3 meter limit rule. What has been required is that the range of those installs be limited to under a mile. It's been this way consistently for almost 50 years, and is still consistently observable today. I've pointed this all out before numerous times in this and other forums, and to avoid my becoming even more increasingly repetitive there's no need for me to spell it all out again, but the evidence of it can be found within numerous of my historic posting at my part15lab blog site which I know you have frequented numerous times.
True, I don't recall ever seeing any NOUO that specified range, nor do I expect to, it is always the ground lead which is cited - nevertheless, the reality, whether you accept it or not, is that it is not the ground lead which is actually causes the NOUO to be issued, the ground lead is only the justification used for the citation because there is no limit on field strength under 15.219, but it's clear that extended range is the true issue. I highly suspect this issue is addressed within one of the blacked out retracted portions of the official agents handbook which was released under the FOIA request several years ago, or in one of the sections they withheld in entirely for reasons quoted as: "that disclosure of this information would allow circumvention of the law."
There's no doubt an official leniency exist in regard to the 3 meter limit, although they withhold this information from disclosure to the general public, there's no question it exist, not only because they imply it in their responses to FIOA request, but also since there's just too much evidence pointing to it over 50 years of established practice..
This is why I believe a hobbyist concern should be less about his ground lead and more about ensuring his range is generally limited to no more than a mile.
You know, you don't need a license to commute by bicycle, but the written law on most states says you must wear a helmet, have turn signals or use arm signals, not ride on the sidewalks, have a headlight a night... all of which are generally ignored and not enforced in most cases everywhere, however, if you are creating a problem somehow then they will cite those rules as a basis to get you in check... This is very much the same situation as with part 15 unlicensed broadcasting.
The rules are a form of control, not dictatorship. I actually admire your technical expertise and knowledge, but your apparent worship of a rule pertaining to a hobby you have no interest in anyway can sometimes get annoying and frustrating.
Incidentally, for future reference, the partial contents which R fry quoted of mine concerning this thread in originated at alpb.boards.net/thread/2848/happened-alpb and I carried it over here to keep it in context.
|
|
|
Post by thelegacy on Feb 21, 2019 16:55:57 GMT
I have what is in part a statement and in part a question regarding Range. Some of it is due to what an agent told me, Procaster's site, Rangemasterr's statements, and Bill Backer's statements. And let's not forget Tim in Bovey with his High Profile Procaster getting 1 1/2 mile (I'm shooting for 1 1/4 to a Tecsun PL-380nRadio). Here goes the can of warms. Bill Baker of ISS during his tests specified ranges of 1 1/2 miles easily covered on the iAM transmitter with the Range Extender 2.5 due this spring. ISS has been having FCC agents right there during their many installs all approved.
Older statements by Procaster talk about Ranges of 1 1/2 miles (I'm looking for that 1 1/4 mile to get to the Deltaville Market). That being said I should not be one of the poster boys for going way beyond average part 15 Range by getting my transmitter away from obstructions to achieve this. And one should look at youtube find the range test where it was 1/5 miles by Red Horse and the Led Zepelin song Your Time Is Gonna Come playing. Shows his High Gain coil antenna at work and he had No NOUO for it.
Then we have KTGR and their 6 mile range to a Portable Radio Now that is Way More Than I've Seen on part 15 installs with a Procaster and he is happily operating his verry high profile part 15 station!! So what gets some in trouble must be what the agent told me Not to do (Don't Cause Harmful Interference)!
Looking at one of the only ground lead citations we find in a high profile. From what I've gathered by reading KENC was informed he was causing a problem for some of a nearby licensed station's listeners that would have told me to check things out or stop till I could find the issue. Instead Ken said No way could he be causing any issues because the station calling him about the complaint was way too far. A grudge match began until the station owner had enough of it and called in a complaint to the FCC to shut him down. We find he had the station installed on top of the town's Water tower. Well this could indeed cause a problem and here is my theory how it did.
The radiation not only went down the tower but followed the water into Everyone's home. It was amplified as it followed the towns water system and some folks have their water line next to a power line now you have a sort of carrier current method of which the waves traveled. It caused front end overload to some people's Radios when trying to receive other AM stations. Ken should have known this therefore he was at fault and the FCC had put up with his antics long enough and had him shut down and the legal way was the long ground issue because it would have took a book to write up how the interference was caused. Shame on Ken for not even trying to stop the interference issues.
In conclusion be a good operator and listen to someone if they take the time to call you to warn you that your causing interference. After all I think it was nice of the caller to call and warn. Many folks won't even do this. There was one NOUO for a talking house and I can assume it was due to its horrible harmonics issue I've conplained more than once about without any further action on part of many. My engineer also saw an issue with the transmitter and I stopped using it till he brought me one that didn't have the same harmonic issues.
|
|
Rich
Full Member
RF Systems Engr (retired)
Posts: 112
|
Post by Rich on Feb 21, 2019 17:45:20 GMT
... But by examining all the high profile part 15 AM installations in history reveals the undeniable fact that part 15 AM installs have never been required by the FCC to meet the 3 meter limit rule. What has been required is that the range of those installs be limited to under a mile. It's been this way consistently for almost 50 years, and is still consistently observable today. ... The link below leads to the NOUO for KENC. Note that: - It states the FCC-measured field intensity of KENC when referencing their non-compliance with FCC §15.209 (2nd paragraph of the NOUO)
- It omits field intensity when referencing their non-compliance with FCC §15.219 (3rd paragraph of the NOUO), but does reference the effect of their long, conducting tower path connected at its top to their "ground lead" as making their installation non-compliant with §15.219(b) — the basis for the FCC NOUO
Furthermore, no credible, published information traceable to 47 CFR Part 15 Rules publicly is known that states the acceptable, typical, or maximum "range" of a Part 15 AM station compliant either with §15.209 or §15.219.
|
|
|
Post by End80 on Feb 21, 2019 18:41:05 GMT
Rich, I know all that. And no there is no published public document concerning permitted maximum range of an AM part 15 station.. I just said all that myself and addressed it specifically, but you don't want to see it, so you won't accept it. I could spend hours meticulously detailing the evidence of this truth citing reference after reference over a 50 year period and you still would not accept it even though it's undeniable. Your field of vision is too narrow focused concretely on the rules and it he theory of caricaturics surrounding it, but you disregard the rest of the picture. If you could look beyond your charts and graphs and look around at what is and has been then you'd see what I'm saying.. but you'll never do that. The published rules are god and nothing else, not even actual and evident truth can change that for you.
Legacy... I read your first paragraph and immediately knew it was way off base. Bill Baker would have never said anything like that, he is quite notorious about being careful what he says about part 15 range and always has been. In every article, interview, website, discussion, case study, correspondence... the range for his part 15 installs he has always said when using the external ATU at about a 1/4 to 1/2 radius. I have a hard time believing he would ever risk saying something like that. Now he does quote and average of 3 to 5 miles range for his licensed T1S installs, so maybe you're confusing the claims with that.
As for other manufactures of part 15 transmitters, yes they've all claimed excessive range possibilities, however they don't claim its legal, but actually provide a disclaimer. And for the 5 mile range claim.. like I said before, yes it's possible with a part 15 transmitter, I've actually done better than 5 miles before, but no, not legally. Those kind of ranges don't even have a semblance of legal.
I'm not sure if you really believe this stuff you say yourself, or if you actually do know better and are just trying to convince others as a means of condoning your own objectives. But no, it's not even close to being legal.
|
|
|
Post by End80 on Feb 21, 2019 18:52:29 GMT
The two extreme views going in two different directions in this thread reminds me of a song by Steelers Dan...
|
|
Rich
Full Member
RF Systems Engr (retired)
Posts: 112
|
Post by Rich on Feb 21, 2019 19:05:18 GMT
... And no there is no published public document concerning permitted maximum range of an AM part 15 station. ... I could spend hours meticulously detailing the evidence of this truth citing reference after reference over a 50 year period and you still would not accept it even though it's undeniable. ... you disregard the rest of the picture. ...
As for the FCC tacitly approving of the operation of Part 15 AM stations non-compliant with §15.209 or §15.219 as long as their "range" does not exceed one mile, probably all readers of this thread would appreciate seeing Rich P's details of this even for one or two provable cases. I know I would.
|
|
|
Post by End80 on Feb 21, 2019 21:07:51 GMT
... And no there is no published public document concerning permitted maximum range of an AM part 15 station. ... I could spend hours meticulously detailing the evidence of this truth citing reference after reference over a 50 year period and you still would not accept it even though it's undeniable. ... you disregard the rest of the picture. ...
As for the FCC tacitly approving of the operation of Part 15 AM stations non-compliant with §15.209 or §15.219 as long as their "range" does not exceed one mile, probably all readers of this thread would appreciate seeing Rich P's details of this even for one or two provable cases. I know I would.
Ok, briefly, I'm not going to pull out the individual documentation for this but just relay the information I have in my head from the past two years of in depth research..
During the periods from 1968 to 1973, this is when the first whip and mast part 15 outdoor transmitters came into existence and were being used in Yellowstone, the first two years leading up to 1970 there were only six of them in operation, pole mounted, well grounded and activated by a hose stretch across the road in various spots along a one way stretch of road, when the car ran over it activated the tape deck and the signal would tell about the particular area you were driving through as long as you were within a mile range, and this same process continued with each additional transmitter for each area..
In 1970 they moved the transmitters to other locations in the park and issued press releases to various newspapers and other media outlets. That's around the time the FCC first came into the picture and began working with them. Let me make clear that they were not operating under any special wavers but strictly under the same rules we do.
In 1971 they began taking bids for additional transmitters to be manufactured, "Info Systems" company won the bid an initially manufacture 15 more for Yellowstone, those were manufactured by Development Technologies Inc. (DTI) in Bozeman Montana, there were also about a half dozen manufactured by International Telephone and Telegraph (ITT) in California for the highway department and Yosemite National Park. A year or two later TSI began making them. There are numerous newspaper and mainstream magazine reports about these all of which describe ranges from 1/2 on up to a mile, they are all pole mounted.
The Yellowstone installs were all pole mounted, or on roof tops, some as high as 30 feet, 96" in whips and ground radials were employed with those radials positioned in such a way that assisted the signals working in a semi directional way when desired. The FCC was closely monitoring this frequently and park documentation confirm this.
More transmitters were ordered and install in Yellowstone in 1972, and by 1973 they had 33 of them, and the practice had already spread to numerous other national parks and rest stops (over 30 of them) the highway department began using them and doing all kinds of installs called "zones" where multiple transmitters were lining highways for miles allowing continuing reception to moving cars.. there were multiple meetings with the FCC and the highway department, the FCC was trying to steer the highway department away from free radiate part 15 towards part 15 buried cable for these purposes but the cost was prohibitive.
The FCC felt the situation was getting out of hand, and was telling the highway departments they should not be using part 15 as a national service, the ground lead issue was frequently mentioned but none of the installs anyway were being cited. Around this same time the Yellowstone park documents said something to the affect "we are still having problems with the FCC and may have to scrap the whole project".
But that didn't happen, sometime in mid 1973 the part 15 whip and mast model was modified and experimental licenses began to be issued providing even greater range - this was the initial steps to establishing a licensed TIS, but the majority of the existing part 15 stations in the national parks and forestry services continued as normal - pole mounted 10 to 15 feet well grounded with ground radials employed.. both the experimental higher power and the existing part 15 systems continued like this until 1977 when TIS became official.
Jump to the early 1980s.. the Talking House comes out FCC part 15 certified, despite the fact that they do not conform to the 3 meter rule (they still don't). Thousands are manufactured each year and widely use primarily for the realtor market. Widely publicized on major nationwide network news, newspapers, magazines.. the issue of violating the three meters is never addressed or cited.
Jump to the 1990s Atlantic Record and tapes receives wide public nationwide attention for 5 or 6 years straight over their use of part 15 high on billboards, top of buildings, tops of Kentucky Fried Chickens, another record company (BMG?) began doing the same thing..
Then you have all the many SeaGrant documented installs and studios during the 1990s on into then present all pole mounted above reach thought the country.
There's four things in common about all those installs through the all those years.. 1. They were all part 15 AM 2. They all had long ground leads. 3. They all maintained their range to under a mile, and 4. Not one of them were ever cited or shut down as long as the range was maintained.
Now in to the 2000s.. Everything was as it had always been until about 15 years ago when you came in the picture and started stomping on everyone hobby for no apparent reason. And then KENC high profile station who was obviously not keeping is transmitters range in check but far exceeding a mile each got shut down. However, every other part 15 install in the us (probably thousands of them) presently still in great numbers at Yellowstone and many other National Parks, Forestry services and Historic sites, marinas, etch, they still operating with long leads... they are not operating under any special privileges either, I have dug for that kind of information, they operate entirely under the same 15.219 rules we do..
I know I'm leaving pieces out because it's just not coming to mind at the moment, but the point is the ground lead has never been the issue, until you personally made it one, it operated bent just fine for decades before you decide that was unacceptable.
Ok?
|
|
Rich
Full Member
RF Systems Engr (retired)
Posts: 112
|
Post by Rich on Feb 21, 2019 21:41:13 GMT
Ok, briefly, I'm not going to pull out the individual documentation for this but just relay the information I have in my head from the past two years of in depth research. ... There's four things in common about all those installs through the all those years.. 1. They were all part 15 AM 2. They all had long ground leads. 3. They all maintained their range to under a mile, and 4. Not one of them were ever cited or shut down as long as the range was maintained. You have posted a lot of information about your POV and recollections, but maybe you'll agree that without documentation proving that information was/is true, it is only hearsay.
Your points 1 & 2 in the quote above are jointly exclusive, as unlicensed AM stations with "long ground leads" are not Part 15 AM stations if they do not meet either FCC §15.209 or all of FCC §15.219 including §15.219(b).
|
|
|
Post by End80 on Feb 21, 2019 22:12:57 GMT
Ok, briefly, I'm not going to pull out the individual documentation for this but just relay the information I have in my head from the past two years of in depth research. ... There's four things in common about all those installs through the all those years.. 1. They were all part 15 AM 2. They all had long ground leads. 3. They all maintained their range to under a mile, and 4. Not one of them were ever cited or shut down as long as the range was maintained. You have posted a lot of information about your POV and recollections, but maybe you'll agree that without documentation proving that information was/is true, it is only hearsay.
Your points 1 & 2 in the quote above are jointly exclusive, as unlicensed AM stations with "long ground leads" are not Part 15 AM stations if they do not meet either FCC §15.209 or all of FCC §15.219 including §15.219(b).
I have all the documentation, I don't feel like making the effort right now it takes to cite each of the hundreds of sources simply for the sake of your satisfaction right now, it's exhausting work, but it is forth coming in a complete work... not to be presented in the angle of the apparent convolution of part 15 rules vs. establish and accepted practice as I have presented here, but rather on the angle of significance of how the part 15 AM hobby was the direct catalysts to an actual working manifestation of TIS, and how part 15 continued on as before sonce. But the facts I illustrated above will still be clearly evident.
It's coming, with thorough reference citations of everything... it's not my POV, it's documented history, what you are calling my recollections is actually just a quick summery I provided even though I knew you would not accept it. In fact even when I do provide the complete works of my research in a suitable form you will still disregard it and hold tight to the rules of a hobby which you never have had an interest in participating with yourself, but only aimed to ensure that those who do are wrong and you are right.
The most striking thing that stands out to me personally in all my research of the high profile extensive use of part 15 AM over a 50 year time span is that I could not find one - not even one single example of an install which conformed to 15.219 as it is written, despite the fact that an FCC official presence was involved in some way directly with all of them.
It's fact, I'll lay the documentation out properly when I'm ready to, when I'm finished and you can read it then. But I know you'll dogmatically hang on to your rule anyway, proof won't sway you.
|
|
|
Post by thelegacy on Feb 22, 2019 4:36:23 GMT
But at the end of the install we will operate our stations as we see fit Not trying to be smart I too have seen at the School For The Blind MSB for short in Lansing, Michigan since 1971. The transmitter was on the third floor of what was known as North Wing Three. The Transmitter was on 1610 Khz and the range was 2 miles off campus of MSB. The station was called WMSB and was widely known in Lansing.
The School For The Blind was on Willow and Pine Street and you could easily hear that transmitter all the way to Shop Rite (Back Then). No NOUO's were issued and plenty of people knew of our station at the Michigan School For The Blind. Was it a "by the book" part 15 install? honestly who knows. But the range greatly exceed a mile that I can rest assure all of you and I'd dare call the signal an Album Rock quality signal.
Now with the crappy AM Radios Today yes your Range would be 1,000 feet (if your lucky). But to a GE super Radio, Zenith (Back then) you heard that station and it was a very simple set up with a copper pipe, bed spring looking coil antenna.
The name Rangemaster in and of itself means you want Range. This is why one would pay nearly 1 grand for such a transmitter. Call me crazy but I'm sure in my area the agent was right in telling me I could reach the Deltaville market with a legal install. Its 1 1/4 miles via GPS (I suppose someone will fly over my area and measure to be sure I don't exceed 1 1/4 miles I'll be watching the skies everyday lol.
So there must have been a good reason such a high profile station back then was allowed continued operation. I don't think it was just because we were kids. Now the constant advertising Kentucky Fried Chicken on AM may have annoyed someone to the point they wanted to shut that station down for good hence why it was and ground lead was the only legal thorn they could get the FCC to throw at them.. Maybe their range was heard 6+ booming miles and someone wanted to DX and could not due to the repetitive barking of KFC ads. However its been my experience that if your not a nuisance your OK in most cases. There is got to be one person in a crowd of 50 who is not going to like your unlicensed station no matter what. I'm even looking at neutral injection carrier current and a 30 Watt amplifier if this continues to be a thorn someone wants to put in my side. Remember 30 Watts is what it will take to get to the market via power line injection and a 100 Ft from the lines signal. It would be BOOMING then and could cause me to have to use the shed outside of the complex in order not to cause RF issues to the other residence in the apartment a unnecessary problem this could cause when I can simply use an antenna install so long as no one whines about it. Either way I'll get the range I want.
The FCC has visited my station (AM Station going 2 miles to a Kenwood car Stereo) and over a mile to a Tecsun PL-380. They looked at the antenna for quite a long time and saw no issue. The station is very much liked in my town as I get donations of sometimes 100's of dollars. So The Legacy is far from a nuisance and soon will have an EAS system running in its audio chain (A well welcomed addition).
I don't hide my station. I don't have to hide. I'm proud of it. The fact that some want to shut me down due to jealousy makes me want to keep doing better as far as my on air performance, adding the EAS, and on the Internet being made North America's True source for Real Non repetitive 1 MONTH(Unless otherwise requested and requested songs are not repeated for 24 hours) of Album Rock. Yes other Radio Stations should learn people are tired of repetition. So they need to stop crying and learn from The Legacy north America's True Album Rock authority.
|
|
Rich
Full Member
RF Systems Engr (retired)
Posts: 112
|
Post by Rich on Feb 22, 2019 11:51:31 GMT
... The most striking thing that stands out to me personally in all my research of the high profile extensive use of part 15 AM over a 50 year time span is that I could not find one - not even one single example of an install which conformed to 15.219 as it is written, ... There is at least one such example, and it has been described by its operator in text and photos on various Part 15 websites, including Part15.us/Part15.org, IIRC.
It consists of a ~3-meter, base-loaded, vertical monopole with its base located several inches above the earth, and driven against a set of buried radials using a home-built transmitter with a "Class E" r-f output stage. It operates in the "Extended AM Band" (carrier freq = 1610 to 1700 kHz). That system was carefully installed and optimally adjusted by its operator to comply with all of FCC §15.219.
He has reported hearing its signal on his car radio at a horizontal distance of ~1 mile in an urban area, for which r-f theory shows/supports that probability for good AM receivers in low-noise locations.
That operator is well known here for his technical expertise. Maybe he will identify himself in this thread, if he wishes to do so.
|
|
|
Post by End80 on Feb 22, 2019 17:33:15 GMT
Ok, I'll repeat again; I don't mean as in more recent individual and rare cases, I was really referring common use to the last half century in general; park and forestry departments, Sea Grant operations, Talking Houses, talking billboards, even Atlantic Records 9 year run, etc. These were all the regular most common and establish methods as it's always been. I know in recent years there are some hobbyist which have resorted to installing right above the dirt.. this is something completely new, and really a bit extreme, but yes it conforms 100%, but such practice has no history whatsoever of being normal with part 15 installs, or for that matter ever occurring at all... but, as I keep emphasizing, the range itself of those has always been limited maintained and not the ground lead.. nor do they today.. it's only some hobbyist who have resorted to such extremes after being brow beat in the forums.
But ok, I really need to drop out of this discussion entirely now.
|
|
|
Post by mark on Feb 23, 2019 3:54:54 GMT
Want to say to thelegacy I wish I knew how you get donations to buy your stuff. I wouldn't mind getting a Procaster as I want an AM transmitter also but so expensive and even with a phone call to try to get a better price even if the $695 was in Canadian dollars and not US dollars(which would mean close to $1000 Can), still it's $700 almost. Donations would be good! Problem is all the other AM transmitters that are less money like the Spitfire, Talking House, Sean Cuthbert etc are not good here and Industry Canada read me the riot act when I asked about this and made it clear that if not in their data look up registered with them.....even if you are following the rules.....no use! They don't accept FCC part 15 even though it's the same as RSS-210 because I "imported" a non certified transmitter. I want to be legal so I am keeping with the subject of this thread. Would really be nice to have people donate money to me to get the Procaster. Also to have as back up as in Toronto there's only one or two FM spaces to go and would want an AM to have as back up should that change. Or move, one or the other.
|
|