Post by Deleted on Oct 11, 2015 21:14:57 GMT
FM MANIFESTO 2 - Carl Blare
Part 1 of the FM MANIFESTO, posted at part15(dot)us, proposes upgrade of the U.S.(Homeland) FCC Rule 15.239 so that the allowed field strength matches the Canadian BETS Standard (4X the strength). In Part 2 we add additional Proposal for Improvement to FCC 15.239.
There should be more critical reviews written about the imperfections (shortcomings) of Part 15 rules for intentional radiation operation. To blindly promote and insist on compliance with the rules as they are lacks reflective thought and soon becomes boorish.
15.239, covering operation in the FM band, is written for the manufacturer of certified transmitters, but does nothing but confound the typical user of such equipment.
15.23(b) does better at speaking to the average hobbyist: "It is recognized that the individual builder of home-built equipment does not posses the means to perform the measurements for determining compliance with the regulations."
The dogmatist will predictably not allow 15.23(b) to have any meaning for those interested in 15.239, but that's the boor talking.
A certified device under 15.239 ends up being a "part" in a home-built system, and even more obviously an uncertified kit-built transmitter is home-built.
The second sentence of 15.23(b): "The builder is expected to employ good engineering practices to meet the specified technical standards to the greatest extent practicable." But again we are put in a lurch, the first lurch being 15.239 itself. Our second lurch is lack of instruction about how the one who lacks the means to perform measurements is expected to "employ good engineering practices."
Therefore with regard to an "FM Initiative" we call on the FCC to provide guidelines accessible to the average user for legally complying with operation in the FM band.
Further, greater heed should be paid by operators under Part 15 in all bands to 15.15(c) "...the parties responsible for equipment compliance are encouraged to employ the minimum field strength necessary for communications."
Another related concern is brought about from the finding by Tim in Bovey that prominent certified FM transmitters were measured at far above their legal expected field strength. By this the end user has no assurance at all he is running a compliant transmitter. At present the responsibility for compliance rests with the operator. Neither the manufacturers of so-called "certified" equipment nor the FCC is culpable for failings on both their parts in the certification program.
Therefore two remedies are sought by this FM Initiative: Foremost, the FCC must develop rules and guidelines accessible by the average home user of Part 15 devices. Then, anticipating a means will be provided to set proper field strength, a control adjustment should be mandatory on all FM Part 15 transmitters to set field strength at or below the legal level.
This is a work in progress and not a final publication.
Part 1 of the FM MANIFESTO, posted at part15(dot)us, proposes upgrade of the U.S.(Homeland) FCC Rule 15.239 so that the allowed field strength matches the Canadian BETS Standard (4X the strength). In Part 2 we add additional Proposal for Improvement to FCC 15.239.
There should be more critical reviews written about the imperfections (shortcomings) of Part 15 rules for intentional radiation operation. To blindly promote and insist on compliance with the rules as they are lacks reflective thought and soon becomes boorish.
15.239, covering operation in the FM band, is written for the manufacturer of certified transmitters, but does nothing but confound the typical user of such equipment.
15.23(b) does better at speaking to the average hobbyist: "It is recognized that the individual builder of home-built equipment does not posses the means to perform the measurements for determining compliance with the regulations."
The dogmatist will predictably not allow 15.23(b) to have any meaning for those interested in 15.239, but that's the boor talking.
A certified device under 15.239 ends up being a "part" in a home-built system, and even more obviously an uncertified kit-built transmitter is home-built.
The second sentence of 15.23(b): "The builder is expected to employ good engineering practices to meet the specified technical standards to the greatest extent practicable." But again we are put in a lurch, the first lurch being 15.239 itself. Our second lurch is lack of instruction about how the one who lacks the means to perform measurements is expected to "employ good engineering practices."
Therefore with regard to an "FM Initiative" we call on the FCC to provide guidelines accessible to the average user for legally complying with operation in the FM band.
Further, greater heed should be paid by operators under Part 15 in all bands to 15.15(c) "...the parties responsible for equipment compliance are encouraged to employ the minimum field strength necessary for communications."
Another related concern is brought about from the finding by Tim in Bovey that prominent certified FM transmitters were measured at far above their legal expected field strength. By this the end user has no assurance at all he is running a compliant transmitter. At present the responsibility for compliance rests with the operator. Neither the manufacturers of so-called "certified" equipment nor the FCC is culpable for failings on both their parts in the certification program.
Therefore two remedies are sought by this FM Initiative: Foremost, the FCC must develop rules and guidelines accessible by the average home user of Part 15 devices. Then, anticipating a means will be provided to set proper field strength, a control adjustment should be mandatory on all FM Part 15 transmitters to set field strength at or below the legal level.
This is a work in progress and not a final publication.