FCC's John Reed Comments on Part 15 AM Rules and Interpretations

Following in this post is an exchange of e-mail between John A. Reed, Senior Engineer, Technical Rules Branch at the FCC Office of Engineering and Technology in Washington, DC and me, and is quoted here with his written permission.

I re-arranged them to be read in chronological order from the top down. I don't know why the time on John Reed's e-mail responses are earlier than the times on my e-mails they answer, but I left them alone.

This isn't really easy to read and maybe to understand fully, but for those who persist, Mr Reed's responses should go a long way at dispelling some of the beliefs commonly held by Part 15 AM users, and even some manufacturers of Part 15 AM transmitters -- whether or not they are FCC-certified for Part 15 use.

//

From: Richard Fry
Sent: Tuesday, August 26, 2008 8:39 AM
To: John Reed
Subject: Part 15 AM Rules

Hello again, Mr Reed -

I posted the text below the line in response to a query on a "Part 15" website. Does my analysis and commentary appear to be accurate as far as the technical and FCC reality?

Regards,
Richard Fry
_____________________

The FCC has two areas of Part 15 applying to the MW AM broadcast band.

Under 15.209 the power of the transmitter and the length of the transmit antenna, feedline and ground are undefined. The only requirement is based on the field strength that such a system can produce at 30 meters.

Under 15.219 the field strength is undefined, but transmitter input power,and the overall length of the antenna, feedline and lead to ground are limited.

The FCC advises anyone who asks that these two forms of Part 15 rules were intended to provide very nearly the same performance, and that 15.219 was included as an alternate to 15.209 to eliminate the need for Part 15 AM users to be able to measure field strength accurately -- which requires expensive test equipment.

In the FCC document linked at the bottom of this post, the approximate maximum coverage radius they expect for a Part 15 setup is about 200 feet (for both AM and FM).

But the realities of physics allow a system operating strictly under 15.219 to produce a greater radius than 15.209 does, when referring to the same field strength (other things equal).

For example, the analysis in this link http://i62.photobucket.com/albums/h85/rfry-100/FCCAction-Unlicensed1500kHz.gif shows that, for ideal conditions a system operating strictly under 15.219 could produce a field strength at 30 meters that in this case is about 250 times greater than is permitted under 15.209. Probably such realities were unrecognized by the FCC when 15.219 was added to Part 15.

From the text of some of the FCC NOUO documents, it appears that they will physically inspect an unlicensed AM system they are investigating to see if it complies either with 15.219 or 15.209. Whether or not the transmitter itself has been certified by the FCC for Part 15 use has no bearing on this, and is never mentioned in the NOUO.

If the system obviously violates 15.219 such as when using an "elevated" installation with a long, radiating conductor to an r-f ground, then they assume that 15.209 applies. Note that the ground conductor includes more than the short "ground lead" connecting the transmitter to a conducting path to r-f ground (a metal flagpole, tower, "lightning ground" conductor, etc). Physics shows that an r-f ground does not exist at the top of any of those structures, and that the entire length of the conducting path to a true r-f ground radiates as part of the antenna system.

In practice, the radius to a given field strength is less for 15.209 systems than for fully legal 15.219 systems (other things equal). But if the inspected system does not meet the installation/operational requirements of 15.219, then any field strength that the FCC measures showing that the limit at 30 meters is excessive under 15.209 can/may lead to an NOUO. And any system intended to operate under 15.219 (even strictly so) almost certainly will exceed the limits of 15.209.

So the safest approach to avoid an NOUO is to insure that the Part 15 AM transmitter is installed within several inches of the physical earth, and that the top of the radiator connected to the r-f output connector of the transmitter is not more than 3 meters above the physical earth. Then, using a transmitter that is FCC certified for Part 15 AM should assure that the transmitter input power limit of 15.219 is met, and that using such an installation should not result in an NOUO if inspected by the FCC.

FCC LINK: http://www.fcc.gov/mb/audio/decdoc/scandoc/910724/1.jpg

From: John Reed
To: Richard Fry
Sent: Tuesday, August 26, 2008 8:18 AM
Subject: RE: Part 15 AM Rules

There are a few problems here.

1. The expected range for unlicensed FM is considerably less than that of unlicensed AM - probably on the order of about 30 feet or so. Yes, I know that a Public Notice was released saying that unlicensed AM and FM transmitters have 200 feet of range. On the practical side, however, you're lucky to even get 30 feet in the FM band. I did see one experiment achieve 400 feet of range when operated in a remote area with a low background noise level and no other FM stations any where near the selected frequency, using a very sensitive FM receiver with a good antenna, and transmitting in a mono mode with 75 kHz of deviation applied to the modulation. This is why our rules do not specify a range - it's a relative term that is completely dependent on the environment. The same applies to range estimates for operation in the AM band. (That same Public Notice also incorrectly stated that you can have 50 mW ERP in the AM band and 10 uW in the FM band. The 250 uV/m at 3 m limit in the FM band translates to an ERP of 11.4 nW or 0.000,000,014 W. A field strength level of 24 uV/m at 30 m, as permitted under Section 15.209 at 1000 kHz, translates to an ERP of 10.5 nW. The non-technical author of the notice should have checked with the engineers before writing this. Note that the numbers in this Public Notice are not binding - the equipment must meet the standards in the actual regulations.)

2. The paper you cite in http://i62.photobucket.com/albums/h85/rfry-100/FCCAction-Unlicensed1500kHz.gif uses an RF loading coil to match to the impedance of the shorter antenna, thereby considerably increasing the resulting field strength. When a loading coil is employed, we consider its electrical length as part of the antenna. If a loading coil of the type described is installed, the antenna (plus connecting cable and ground lead) will far exceed the permitted 3 m length. When the antenna and ground meets the requirements in Section 15.219, you will have a much lower field strength.

3. A transmitter is certified under Section 15.209 or 15.219. If it was certified under Section 15.209, the radiated emissions must comply with the limits in that section. If it was certified under Section 15.219, the input power and the combined lengths of the antenna, connecting cable and ground must comply with the limits in that section. There is no need to check for compliance under Section 15.209 when the transmitter was certified under Section 15.219. If the 15.219 system exceeds the standards in that section, it is in violation of the rules. Of course, if the 15.219 system exceeds those specifications the radiated emissions also will exceed the 15.209 limits. The field inspection folks may check for both simply to show that the system is not compliant under any of the possible standards.

From: Richard Fry
Sent: Tuesday, August 26, 2008 11:54 AM
To: John Reed
Subject: Re: Part 15 AM Rules

Thank you for your reply.

Could you please comment further on these quotes from it, with the respect the questions they prompted?

"1. That same Public Notice also incorrectly stated that you can have 50 mW ERP in the AM band and 10 uW in the FM band."

I believe the notice states "0.010 microwatts" for FM, rather than 10 uW. A value of 0.010 µW is 10 nW. Also it can be noted that 10 nW is a little less than the power given per the equation in FCC OET Bulletin 63 to produce the maximum Part 15 FM field from a 1/2-wave dipole, which is 11.43 nW, although the equation in OET 63 applies to the power radiated by an isotropic antenna, and yields an answer of 18.75 nW. That 18.75 nW must be reduced by the peak gain of the 1/2-wave dipole, which is 1.64 (18.75 / 1.64 = 11.43, approx).

"2. A field strength level of 24 uV/m at 30 m, as permitted under Section 15.209 at 1000 kHz, translates to an ERP of 10.5 nW."

This is true for far-field conditions, but according to Figure 6-5 and the accompanying text of Kraus' Antennas, 3rd Edition, a distance of 30 meters lies well within the near-field boundary -- which exists at about 47.7 meters for this setup (please see the clip of this at http://i62.photobucket.com/albums/h85/rfry-100/KrausGraphicFields-.jpg ). As such wouldn't the ERP needed to produce 24 µV/m at a 30-meter distance be less than 10.5 nW?

"3. When a loading coil is employed, we consider its electrical length as part of the antenna. If a loading coil of the type described is installed, the antenna (plus connecting cable and ground lead) will far exceed the permitted 3 m length."

Is this an administrative interpretation? Wouldn't a "pure" application of physics show that, while there could be a relatively small amount of radiation from a loading coil, that radiation is far less than is produced when the amount of wire comprising the coil is analyzed separately in the form of a linear radiator?

Also, do you agree that the entire conducting path to an r-f ground buried in the earth constitutes the ground lead used on Part 15 systems, and that the ground lead is not limited to the length of a short conductor connecting the transmitter chassis to a grounded flagpole or tower?

Thank you,
Richard Fry

From: John Reed
To: Richard Fry
Sent: Tuesday, August 26, 2008 11:27 AM

Subject: RE: Part 15 AM Rules

Re 1: You are correct; the PN references 10 nW, not 10 uW. However, we go by the field strength limit which works out to an EIPR of 18.75 nW or an ERP of 11.4 nW.

Re 2: Free space propagation equations are less than reliable under most real world situations. At 1000 kHz, assuming a small antenna, the near field/far field would occur at approximately 48 meters. That means it's easy to play games with the field strength measurement, moving the receiving antenna by a small increment to obtain a large change in measured signal level. I realize that the equation doesn't work at 30 m but wanted to provide a relative example.

Re 3: This is how we've always interpreted 15.219. The entire point of limiting the antenna length and the length of the connecting lead and ground lead is to ensure that the resulting antenna is extremely inefficient. It's not just the radiation from the loading coil; it's the much higher field strength that results from the system after you match impedances.

As to the ground lead, this is exactly what we've been saying all along. If you attach your ground lead to a drainpipe, billboard, or other structure, that structure becomes part of the ground lead and is included in the 3 m limit. Similarly, if you install a ground plane or otherwise change the ground efficiency.

*** End of e-mail sequence

Yawn...

William C. Walker said:

Yawn...

Click to expand...

Apparently Mr Walker believes this topic has little or no value. Perhaps it does not, for him, but for others -- please consider this:

Beliefs and assumptions about what Part 15 rules mean and permit have been used to support various system designs and operating modes not supported by the FCC (and physics), according to John Reed.

These unsupported beliefs and assumptions are not limited to, nor do they exclude any individual or firm -- be it Rangemaster, Talking House, SSTRAN, Ramsey or other OEM, or any user of Part 15 equipment.

Those following the FCC's rules for Part 15 as governed by physics and as described in John Reed's statements will have no cause for concern at reading the information I posted.

But OEMs and users need to know what they are permitted to do, technically and legally, which is the purpose of my posts.

Once this is known, it is their decision whether or not to comply. If they do not, that is done at their own risk. But at least it was their concious decision, and not based on lack of knowledge.
//

I think it is safe to say that what I am about to say will speak for most of the people that utilize this message board.

Fry, you keep beating people over the head about this issue and it has grown tiresome for most. In other words we are SICK of your preachy, condescending tone.

I have family and friends that work in some pretty important positions in the Federal government around the country and in DC. I've dealt with the FCC about this in the past and in fact, I have a good friend from my childhood years that works at the FCC in DC. I know the deal about part 15 and understand how American law is written and to be interpreted. Obviously ANY transmitter that has been Type Accepted by the FCC for Part 15 use does not violate its own rules otherwise it would not be Type Accepted. And please don't say for the 100th time "it's all in how you use the transmitter". WE ALL know that and don't need to hear it again.

One thing I've learned over the years is that people like you, who are quick to point an accusing finger at others, often times are in need of closer scrutiny. People like you make the most noise about others as a distraction from your own life because people like you, usually have something to hide...

William C. Walker said:

Obviously ANY transmitter that has been Type Accepted by the FCC for Part 15 use does not violate its own rules otherwise it would not be Type Accepted.

Click to expand...

It would interesting to know the process used by the FCC to define and examine the applications for certification of the Part 15 transmitters used on the AM broadcast band.

I believe the compliance testing itself is done by non-FCC labs. If the FCC expected and required compliance to the extent outlined in John Reed's comments, then systems with antenna loading coils (wherever located), systems using long feedlines to remote tuning units, systems tested while supported on grounded vertical conductors (masts), and systems with extended grounds connected through the AC power lines probably should not have been accepted.

If the test lab has not furnished a complete enough report for the FCC to determine this level of detail, and the FCC certified them anyway -- does this exempt the users of that equipment from compliance to John Reed's statements?
//

It seems to me that you are alleging that the Lab's doing the testing are not doing things on the up and up. Grounds for a lawsuit if the right person so desires especially since you don't have any real proof to make such claims. On some message boards you would be labeled as a Troll i.e. as someone deliberately antagonizing others.

John Reed merely writes the rules at this time. He did not write the rules when the first Part 15 units were Type Accepted. And at some point he'll retire and someone else will take his place. John Reed does not enforce the rules because that is up to a different branch of the Department. This is how law works. Congress creates laws, law enforcement enforces and then the Judiciary Dept. judges.

Like it or not, the government is a bloated bureaucracy that is highly compartmentalized and often times what one department does conflicts with that of another. Unless the FCC withdraws Type Acceptance of these units and that is not likely you should quite simply stop harassing people that don't seem to agree with your assessment of the rules.

Rich, I cannot help but believe that you are somehow trying to wipe out Part 15 AM radio.

" So the safest approach to avoid an NOUO is to insure that the Part 15 AM transmitter is installed within several inches of the physical earth, and that the top of the radiator connected to the r-f output connector of the transmitter is not more than 3 meters above the physical earth."

This quote from you that you tried to get Mr Reed to agree to would basically put Part 15 AM out of business. Talking house transmitters for example is a indoor tabletop product, it has it's ground connected to the ground on the wall socket, and could not comply. It would make Part 15 Am installations, for the most part impractical. The logical conclusion would be that you are trying to eliminate it.

Mr Reed confirms that a 15.219 system will exceed the radiation limits set in 15.209

Your "clarifying" statement from Mr Reed is not at all that. You never even told Mr Reed you were looking for clarification to broadcast to the Part 15 world, or to prove your opinions. (Did you leave anything out of the e-mail, it seems to abruptly end?) Mr Reed will tell you himself that he actually is not the final authority in the DC office in this area.

Here is the latest policy statement from the DC office meant to be used in the way you are using Mr Reeds comments:

"The 3-meter combined length specified in Section 15.219(b) refers to the length of all radiating elements. Attaching the ground lead to an unshielded radiating object, or the addition of a ground screen, will cause the effective length of radiating elements to exceed 3 meters, in violation of Section 15.219(b)."

As you can see this is a bit different, and a bit easier to comply with. I go in to great detail on my webpage how to comply with this policy. It is as simple as limiting the radiator to 3 meters.

And for those reading this board, please realize, don't take anything you read on the internet as gospel, most is tainted by agenda or error, always go to the source, (in this case the source would be the FCC)

Hamilton said:

...You never even told Mr Reed you were looking for clarification to broadcast to the Part 15 world, or to prove your opinions

Click to expand...

As I posted originally, John Reed gave me his permission to publish our e-mail exchange on Part 15 websites before I did so. Here is a paste of it:

From: Richard Fry
Sent: Tuesday, August 26, 2008 2:30 PM
To: John Reed
Subject: Re: Part 15 AM Rules

Thanks once again for your reply.

Your information will be valuable to Part 15 users. Would there be any problem if I posted our unedited* e-mail exchanges of today on several websites read by the Part 15 community?

* unedited except, with your permission, changing "10 m" to 30 m in the last sentence of your response # 2 below -- which I suspect was a typo.

Richard Fry

From: John Reed
To: Richard Fry
Sent: Tuesday, August 26, 2008 1:29 PM
Subject: RE: Part 15 AM Rules

Not a problem and thanks for picking up the typo. Too many things at once here today.

(Did you leave anything out of the e-mail, it seems to abruptly end?)

Click to expand...

What I posted was the complete technical exchange. All that was omitted until now was the permission request and grant to publish our exchange to the web.

//

And I want to make clear that I have no agenda here.

I was alarmed to see a field strength/distance figure given on the NOUO and in the Part 15 rules for AM and just wanted some clarification on the issue.

C5

Each Field Office has its own interpretation of the rules.

I am acquainted with someone that is better acquainted with John Reed at the FCC than Fry. A few years ago Reed told my acquaintance that 15.219 applies to intentional radiators like the Rangemaster while 15.209 applies to Carrier Current operations.

William C. Walker said:

I am acquainted with someone that is better acquainted with John Reed at the FCC than Fry. A few years ago Reed told my acquaintance that 15.219 applies to intentional radiators like the Rangemaster while 15.209 applies to Carrier Current operations.

Click to expand...

Why not remove the hearsay element? Ask John Reed for his direct response and his permission to quote it, and then post it here.

//

Fry. I'll bet you can hear an ant fart.

Let's put things in perspective here... When the FCC came out with these rules a while back, their intention was to limit interference with licensed broadcasters. I cannot imagine any Part 15 AM broadcaster even with long radiating ground leads ever causing a problem (Part 15 FM is a different story). So it would seem that the FCC rules were successful, and these same rules removed pressure from the FCC by granting people access to their airwaves and not giving everything to broadcasting corporations just to make more money.

Those with deep pockets and monetary interests have successfully lobbied the government and as a result, the FCC has allowed IBOC digital radio broadcasting for AM which DOES cause terrible interference and has effectively ruined the AM band for DX listeners and Part 15 broadcasters. Now THIS, in my mind is illegal and should be stopped. Where are the laws to protect the public? isn't this the job of the FCC in the first place? Why are they not fulfilling their oath of office to uphold honesty and ethics? Is it any wonder that those in charge of financial affairs allowed the current fiasco to develop. THIS is the important stuff, not the length of ground leads, antenna loading coils etc.

I have mentioned this before to Mr. Fry and suggested that he use his skills in this area rather than keep harping on the Part 15 business - which really amounts to nit-picking a very small and harmless activity. If Mr. Fry continues to dwell on these issues (which he no doubt will), he ultimately could risk destroying one of the only radio activities still left to the general public - and it's pretty measely anyway.

R. Fry said:

William C. Walker said:

I am acquainted with someone that is better acquainted with John Reed at the FCC than Fry. A few years ago Reed told my acquaintance that 15.219 applies to intentional radiators like the Rangemaster while 15.209 applies to Carrier Current operations.

Click to expand...

Why not remove the hearsay element? Ask John Reed for his direct response and his permission to quote it, and then post it here.

//

Click to expand...

Rich,
Why would I want to do that? John Reed is not the contact person in the DC office for that type of question. I am interested in only “official” FCC interpretation.

Hamilton said:

Why would I want to do that? John Reed is not the contact person in the DC office for that type of question. I am interested in only “official” FCC interpretation.

Click to expand...

Keith, note that I was responding to Wm Walker, who was reporting a hearsay statement attributed to John Reed.

Regardless, it would be logical to confirm John Reed's position on this by asking John Reed directly.

//

Krimless, please read my response in the above topic. You are right on. I agree.
We never did need unbadged police in America, but apparently we need them in regards to part 15 radio.
I simply can't see what the policing is all about!

Basically if an AM (or FM) full power station is being interferred with by a part 15 station (hardly likely), they would call the part 15, or with no luck on that, call the FCC who would look at it if it seemed like a disaster was coming.

Since we know we already have 100+ and 1,000+ watt pirates already on the air, and staying there, I fail to see how a part 15 station who MAY have a nice range legally is the subject of talk on this board. I know I'm wasting my time here, but there are others who have so much time on their hands that they have to comment constantly about things that in reality make no difference, compared to what I talked about above.

The rangemaster, ramsey, sstran, .........all of those and more, are all the same product.
I bought a bananna that cost 29 cents and it tasted the same as the bannna that cost me 3 cents. It's the same commodity.
It's how you use it.....legally.

How about this?.......lets see how we can use part 15 radio to America's advantage instead of slamming it up and down for no good reason?

I notice a lot of professional radio broadcasting advice; little of it has to do with part 15 broadcasting; a good place for this would be the engineering board.......what these people want is advice on how to make a little transmitter and antenna work, not explanations on why they shouldn't try. But that is what this board now trys to do.

It's the reason I haven't posted here in a long time, and now that I"ve had my say, I think I'll say goodbye.

carlvenorden said:

I know I'm wasting my time here, but there are others who have so much time on their hands that they have to comment constantly about things that in reality make no difference, compared to what I talked about above.

Click to expand...

Carl -- those who received FCC citations for Part 15 violations (and those who don't wish to) probably don't think that knowing and observing Part 15 rules and policies, and the physics behind them "in reality make no difference."
//

I think people need to know and understand that “no thanks to Rich” seemingly the quarter million or so talking house transmitters in operation are now not operating legally (to the letter of the law) Read the latest policy FCC policy statement:

The 3-meter combined length specified in Section 15.219(b) refers to the length of all radiating elements. Attaching the ground lead to an unshielded radiating object, or the addition of a ground screen, will cause the effective length of radiating elements to exceed 3 meters, in violation of Section 15.219(b).
This is a recently issued FCC policy.

Since as far as I know all AM transmitters including talking house bring the ground out the power supply directly to electrical power supply building ground (actually we don’t we have a separate lighting ground) the ground would be part of the radiating system, which is in violation.

And this is not just talking house, it is any AM transmitter out there that works this way.

Now things are trying to go even a step further, it seems that Rich wants FCC policy to somehow limit locating Part 15 AM within inches of actual dirt!
This would make almost all installations impractical. The talking house which is an indoor only transmitter would need to somehow be located with in a few inches of dirt. A hardship on even technical people, an impossibility on non-technical people, and almost all of the talking house units are owned by non-technical real estate agents and such.

Outdoor transmitters such as ours would be subject to vandalism, an eyesore, just impractical. Let’s be honest, what are the odds of a landlord letting you put a Part 15 in when you tell him it has to be installed in the front of the building in the flower bed or such? And what about apartment dwellers, or people in big cities who haven’t seen dirt since they were born? They would just be denied the option to own a Part 15 AM.

Looking at all this I come back to the conclusion that Rich, you must have some sort of agenda here to neuter Part 15 AM, why do you fight so hard for this?

Look at the e-mail to John Reed, Rich talks about the FM material, and then at the end throws in the “real” question about the AM grounding, the “meat” question. He phrases the question so all Mr. Reed has to do is agree with him and Rich has what he wants!

There are so many other just causes out there that scream for attention. Eliminating Part 15 AM just does not seem like a good cause.

Hamilton said:

I think people need to know and understand that “no thanks to Rich” seemingly the quarter million or so talking house transmitters in operation are now not operating legally (to the letter of the law) Read the latest policy FCC policy statement:

The 3-meter combined length specified in Section 15.219(b) refers to the length of all radiating elements. Attaching the ground lead to an unshielded radiating object, or the addition of a ground screen, will cause the effective length of radiating elements to exceed 3 meters, in violation of Section 15.219(b). This is a recently issued FCC policy.

Click to expand...

Keith, you haven't given your source for this "FCC policy," or the date of its release, but regardless, there is nothing in this statement that is not supported by the words of 15.219 as they have existed for many years, and/or is supported by John Reed's comment earlier in this thread, which I repeat: "As to the ground lead, this is exactly what we've been saying all along. If you attach your ground lead to a drainpipe, billboard, or other structure, that structure becomes part of the ground lead and is included in the 3 m limit."

So it isn't correct to write that any Part 15 AM transmitter system is "now not operating legally," no thanks to me. The rules have been there all along.

Since as far as I know all AM transmitters including talking house bring the ground out the power supply directly to electrical power supply building ground (actually we don’t we have a separate lighting ground) the ground would be part of the radiating system, which is in violation.

Click to expand...

And does the "separate lightning ground" for your Rangemaster 1000 produce radiation? If not, how has that been prevented in all installations?

Now things are trying to go even a step further, it seems that Rich wants FCC policy to somehow limit locating Part 15 AM within inches of actual dirt! ... Outdoor transmitters such as ours would be subject to vandalism, an eyesore, just impractical.

Click to expand...

This was offered as a possible solution meeting Part 15 AM rules, policies and physics. As an equipment manufacturer, perhaps you can develop and publish a means you prefer that accomplishes the same thing.

As far as eyesores, are you thinking that your Rangemaster 1000 Part 15 AM system mounted outdoors on a 20 or 30 foot guyed mast is less of an eyesore than without the guyed mast?

Looking at all this I come back to the conclusion that Rich, you must have some sort of agenda here to neuter Part 15 AM, why do you fight so hard for this?

Click to expand...

My only agenda is to learn and propagate the facts about what Part 15 AM rules, policies and physics legally enables, and to make them known to others. My prompt for doing so came from reading the posts on Part 15 boards.

A lot of people think that truly legal Part 15 AM will allow them to become "community broadcasters," with coverage areas of 5 or 10 square miles. And there are operators claiming to operate under Part 15 who claim such coverage areas (whether true or not), and write about them constantly on the various boards -- which encourages others to expect such coverage for their systems.

There are plenty of posts based on lack of knowledge, urban legend, wishful thinking and hearsay. Shouldn't people be able to read all sides, and make up their own minds about what they wish to do, and at what risk?

//

OK Rich, Lets go through all this, one item at a time.

True, I haven’t given the source, it was the DC office, and was released to all field agents. I think that is enough. It was released about a year ago (I think)

“, there is nothing in this statement that is not supported by the words of 15.219 as they have existed for many years”

Not true, 15.219 is very vague, the policy referred to would not be needed if 15.219 was clear.

“If you attach your ground lead to a drainpipe, billboard, or other structure, that structure becomes part of the ground lead and is included in the 3 m limit."

What the ground lead is attached to is NOT the issue, the issue is “does it radiate?” if it does not then it is not included in the 3 meter limit, if it does then it is included in the 3 meter limit, can you see that?

“So it isn't correct to write that any Part 15 AM transmitter system is "now not operating legally," no thanks to me. The rules have been there all along.”

Not exactly, the rules were there, but vague. It seems that attention being called to the situation has caused a tightening of policy. As a rule any time you ask for a policy from the FCC you are going to get locked down to the tightest possible interpretation, any one who has dealt with the FCC knows that. You have been dealing with them your entire career so you know that.

“And does the "separate lightning ground" for your Rangemaster 1000 produce radiation? If not, how has that been prevented in all installations?”

Rich, have you bothered to check out my website at all, there is information there on how limit the radiator to 3 meters.

Quote
Now things are trying to go even a step further, it seems that Rich wants FCC policy to somehow limit locating Part 15 AM within inches of actual dirt! ... Outdoor transmitters such as ours would be subject to vandalism, an eyesore, just impractical.

”This was offered as a possible solution meeting Part 15 AM rules, policies and physics. As an equipment manufacturer, perhaps you can develop and publish a means you prefer that accomplishes the same thing.”

Here is what you said:

“So the safest approach to avoid an NOUO is to insure that the Part 15 AM transmitter is installed within several inches of the physical earth, and that the top of the radiator connected to the r-f output connector of the transmitter is not more than 3 meters above the physical earth. Then, using a transmitter that is FCC certified for Part 15 AM should assure that the transmitter input power limit of 15.219 is met, and that using such an installation should not result in an NOUO if inspected by the FCC.”
Not biting on the one Rich, I believe you were hoping that Mr. Reed would agree with you, then you could stretch that into blanket statement that all ground has to be the dirt, just as you have been wanting. Also as I have said, just look at my website for information, many ways to limit the radiator are there.

“As far as eyesores, are you thinking that your Rangemaster 1000 Part 15 AM system mounted outdoors on a 20 or 30 foot guyed mast is less of an eyesore than without the guyed mast?”

I think you are grasping for anything here Rich, of course a transmitter up on a roof, allowed to be placed where practical, hidden from view with the other radio equipment is less of an eyesore then in the front yard. I think the guyed mast approach is not used often and when it is, there is plenty of room for it, out in the country or such, and if it is used the ground wire can be installed inside of the mast to prevent radiation, as described on my website. Of course care has to be taken to be sure the ground wire is kept from the mast at the top (doesn’t short).

“My only agenda is to learn and propagate the facts about what Part 15 AM rules, policies and physics legally enables, and to make them known to others. My prompt for doing so came from reading the posts on Part 15 boards.”

That doesn’t make sense considering your actions. There is a difference between helping others learn/know the rules (when they are interested) and actually influencing the rules in a negative more restrictive way against the very hobby you purport to be helping.
There are a lot of small guys out there that love being able to have a voice in a small way, that possibility is less now.

“A lot of people think that truly legal Part 15 AM will allow them to become "community broadcasters," with coverage areas of 5 or 10 square miles. And there are operators claiming to operate under Part 15 who claim such coverage areas (whether true or not), and write about them constantly on the various boards -- which encourages others to expect such coverage for their systems.”

Rich, does this bother you? I know it bothers the NAB and big business broadcasting (money, money,money).
I think people that have made a science out of seeing what kind of range they can get given the restrictions they are under are very cool. Of course given the new restrictions their challenge is tougher, but more power to them! If a smart guy out on a hill in Utah can get 3 miles (with a sensitive receiver) and broadcast to his neighbors legally then I say very cool! I have found that these type of reports are only in the country with low noise floors, and with people that have put a great deal of time into there systems. What if anything could you have against people doing that?

Rich, Have you ever tried one of these high performance AM systems to see what range you could legally get out of it? I challenge you to do so. With you tech knowledge you could do well. Last time I asked you the only part 15 you ever had was some sort of 100 foot thing.

The challenge of seeing what range you can get under the limitations is part of the fun!

Also I know you think that the ground wire adds a lot to the overall radiation, but from field testing it really doesn’t.

Also it is possible to cover a large area with many transmitters, but you reach a point at which it becomes so expensive to do so, you might as well buy a station.