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

Hi Folks,

By following the posts here I have had a conclusion which I reached a long time ago validated. The FCC's intent with the original part 15 rules regarding AM transmitters was to allow people to use devices for personal use while at the same time preventing interference to other radio services. Thus the rule (15.209) was based on field strength limits at a distance and limited this to a very weak value.

As an alternative to the field strength limits, which are difficult for a hobbyist to measure, the rules were ameded by adding 15.219 to permit systems to be constructed and operated under this new rule.

As you read on, and I develop my argument, keep in mind the original intent of allowing part 15 AM, which I will again remind you, was to provide for personal use and minimize the chance of interference. 15.219 was seen as being equivalent to 15.209 in terms of outcome.

Clever and innovative people have found a loophole in the literal interpretation of 15.219, namely, by using engineered ground planes and loading coils consistant with 15.219, range and field strengths have been achieve under the letter of the law but were never anticipated and are not within the intent of the law. This is great and useful but what has happened is the rules are being reinterpreted, especially with regard to the "ground lead". What has been a useful and lawful "loophole" has been pushed to the point where it now has the attention of the FCC.

The fact is, as I see it, it is now becoming an issue which contradicts the INTENT of part 15.209.

I repeat, the original intent was not provide for community broadcasting and I ask all of us how would we react if we were the FCC and if we knew the original purpose and intent of part 15 transmitting and were now faced with the extended ranges being reported? Extended ranges can be equated to increased interference potential.

I think our time would be better spent documenting that the "loophole" transmitters which operate under 15.219 and which achieve ranges never intended do not, in fact, cause interference problems and do promote community well being. This is a difficult task since it is hard to prove a negative regarding interference. It will be a positive if these transmitters operate according to 15.219 and if that requires a very conservative interpretation of the rules then this is a prerequisite to furthering the cause. If it can be shown that these "loophole" systems are not causing problems then perhaps we can maintain status quo. We could very easily get into a situation where the irresponsible actions of a few will result in the loss of priviledge for the many who are not a fault. This also can include the cavalier attitude regarding the technology and rules which I have witnessed on this and other boards.

Neil

Hamilton said:

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).

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You think it is enough, and you think it was released about a year ago. That doesn't really show a very high level of authenticity, don't you think -- especially from you as a Part 15 AM transmitter manufacturer who reasonably should be expected to be certain of the regulatory environment applying to such equipment.

“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.

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I've checked it out. There I have seen illustrations of your Rangemaster 1000 mounted on a rooftop, using a long conductor to a ground rod near the building -- and with no indication there that any steps must be taken in the installation to prevent radiation from that long ground conductor.

Do you automatically supply/install the accessories needed to prevent radiation from the "lightning ground" conductor to every purchaser of your Rangemaster 1000? How about for the other conductors connected to the transmitter, such as the DC power lines and the progam lines?

I think the guyed mast approach is not used often and when it is ...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).

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You have mentioned this before, and I have sent you NEC data showing that such a ground wire running through, and insulated from a grounded metal tube radiates nearly the same as that ground wire without the tube. The r-f coupling between the tube and the ground wire in this scenario is very high. Not to mention that the Part 15 transmitter chassis at the top of the mast probably is mechanically/electrically connected to the grounded metal tube (mast), which would mean that a "ground wire" inside that tube is redundant to the system.

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

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Then the field test was flawed.

If, for otherwise equal conditions, the radiation from a long ground wire didn't significantly improve the coverage area of an unlicensed AM setup, then why would installations using one be so popular, and so staunchly promoted and defended by such users, and even the manufacturers of Part 15 AM transmitters? And no, it is not because the 3-m whip is higher above the surface of the earth.

It the radiation from a long ground conductor makes no difference in coverage from an outdoor installation, it would be far simpler and cheaper simply to mount a Part 15 AM transmitter system a few inches above the earth -- which would eliminate all the controversy about the long ground conductor.

//

SANITY CHECK!

Following is a duplicate of my post on another forum. My comments apply equally to this thread.

Wow, this thread is whacked!

On a scale of 1 to 10, avoiding NOUOs for part 15 AM operation is as follows:

1 Don't transmit any signal.
1.1 Operate any 100 mW transmitter with the antenna at ground level
1.5 Be bold and install an elaborate ground and put your antenna up about 50 ft or so.
.
.
.
9 Pick a frequency that is sure to cause interference, broadcast offensive or just strange stuff likely to be offensive to a busybody, or compete with a local broadcast station.
10 Transmit at pirate power levels (or alternatively, switch to FM)

If you care, look at the tediously long list of violations at http://www.fcc.gov/eb/FieldNotices/. Then, if you don't fall asleep first, try to find the part 15 AM violations.

Rich likes to poison the waters. He doesn't actually operate a part 15 AM station. Is he a plant for the FCC or NAB? Who knows? If he isn't, he needs to find something more important to do with his life.

PhilB

PhilB said:

Rich likes to poison the waters. (etc)

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Please explain how my posting of factual information, which accuracy you do not dispute, can poison the waters.

BTW, I have no connection with the FCC, NAB, or any other business entity. Repeating some of my earlier post in this thread...

My only agenda is to learn 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?

//

Hi Rich,
This is really getting whacked as the other poster said.

“You think it is enough, and you think it was released about a year ago. That doesn't really show a very high level of authenticity, don't you think -- especially from you as a Part 15 AM transmitter manufacturer who reasonably should be expected to be certain of the regulatory environment applying to such equipment.”

No,No, I know exactly when it was released, by whom, I just choose not to spend the time to look it all up or mention it to you just because you feel you need it.

“I've checked it out. There I have seen illustrations of your Rangemaster 1000 mounted on a rooftop, using a long conductor to a ground rod near the building -- and with no indication there that any steps must be taken in the installation to prevent radiation from that long ground conductor.

Do you automatically supply/install the accessories needed to prevent radiation from the "lightning ground" conductor to every purchaser of your Rangemaster 1000? How about for the other conductors connected to the transmitter, such as the DC power lines and the progam lines?”

Not all ground situations will radiate, the last part of your question is a long detailed response, call for the long answer, but in short that is addressed.

“You have mentioned this before, and I have sent you NEC data showing that such a ground wire running through, and insulated from a grounded metal tube radiates nearly the same as that ground wire without the tube. The r-f coupling between the tube and the ground wire in this scenario is very high. Not to mention that the Part 15 transmitter chassis at the top of the mast probably is mechanically/electrically connected to the grounded metal tube (mast), which would mean that a "ground wire" inside that tube is redundant to the system.”

Our transmitter, has a fiberglass chassis, A ground wire inside a mast is not redundant.

“If, for otherwise equal conditions, the radiation from a long ground wire didn't significantly improve the coverage area of an unlicensed AM setup, then why would installations using one be so popular, and so staunchly promoted and defended by such users, and even the manufacturers of Part 15 AM transmitters? And no, it is not because the 3-m whip is higher above the surface of the earth.

It the radiation from a long ground conductor makes no difference in coverage from an outdoor installation, it would be far simpler and cheaper simply to mount a Part 15 AM transmitter system a few inches above the earth -- which would eliminate all the controversy about the long ground conductor.”

That is crazy, (here we go, back to mounting it in the garden again) nobody wants to mount their Part 15 in their front yard, they need to go up on the roof, out of the way. These units need to be mounted where practical, above surrounding obstructions is best. People need to have the freedom to mount these things where practical, inside units inside, rooftop units on the roof, ect.

“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, I think it is ironic that you so against trying to get range with Part 15 when you have never even tried it yourself, you actually have no practical knowledge of what can be done, only Theoretical, It is amazing what people can do that know what they are doing. You swear it can’t be done, but you have never tried it. (I mean a real effort) We don’t tell people 5 or 10 square miles, I tell people 1-2 miles radius, 1 mile radius is 1 square mile, even a 2 mile radius (which is difficult) is just 4 square miles.

You have worked in the big radio business all your life, correct? If you are not totally pro NAB, I suspect you are just “programmed” that way. I think you will admit you are not a “radio rebel”?

This is seemingly useless Rich, I am pretty busy, I’m done.


Another thing

“The FCC's intent with the original part 15 rules regarding AM transmitters was to allow people to use devices for personal use while at the same time preventing interference to other radio services.”

I have heard that many places, & I question, actually what was the FCC intent of the original Part 15 service? I have often heard that people these days break the “spirit” of the original intent, but I question: How can we be absolutely sure of that?

Is this “original intent” down in writing somewhere, or is it assumed?
(Not a trick question, I don’t know)
Part 15 has no restrictions on content, I would think that it would have been a good idea to add a content rules to the original law if the FCC never wanted Part used for any kind of a neighborhood radio station. The law is the law, “original intent” is heresay.

Actually most of the units we sell go for parking lot information or similar use.

Small towns and minority people groups are crying out for low power radio to bring them together today. We need LPAM, LPFM and Part 15 to help do this. Big money radio is not filling this gap.

When Part 15 was written there were a whole lot more small town stations (with local programming) on the air then there are today.

Hamilton said:

Hi Rich, This is really getting whacked as the other poster said.

Hamilton quoting Rich "You think it is enough, and you think it was released about a year ago. That doesn't really show a very high level of authenticity, don't you think -- especially from you as a Part 15 AM transmitter manufacturer who reasonably should be expected to be certain of the regulatory environment applying to such equipment."

No No, I know exactly when it was released, by whom, I just choose not to spend the time to look it all up or mention it to you just because you feel you need it.

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Very well, Keith. But if you knew about the FCC's position on internal / external loading coils and radiating ground leads about a year ago, then why has your Rangemaster 1000 continued since then to include an internal loading coil for the antenna system, and why does your Rangemaster website continue to show / suggest an installation that almost certainly will result in a long, radiating ground lead that is non-compliant with 15.219 ?

Our transmitter, has a fiberglass chassis, A ground wire inside a mast is not redundant.

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If a "ground wire" within / without a mast, or a metal mast or other conductor(s) not decoupled for r-f such as the DC power and program lines are connected to the printed-circuit ground plane of the fiberglass circuit board within your Rangemaster 1000 -- then all such elevated configurations will produce more radiation than is legally permitted under Part 15 when used with a ~3-m "antenna."

Certainly this should be apparent to you as the stated designer and supplier of the Rangemaster 1000 Part 15 AM transmitter.

We don’t tell people 5 or 10 square miles, I tell people 1-2 miles radius, 1 mile radius is 1 square mile, even a 2 mile radius (which is difficult) is just 4 square miles.

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Keith -- maybe you should refresh your grade school math skills. A uniform coverage radius of X linear miles equates to a a coverage area of X^2 x pi miles. So a uniform coverage radius of 1 mile will produce a coverage area of 3.14+ miles, not 1 mile as you posted.

This is seemingly useless Rich, I am pretty busy, I’m done.

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So be it, but your statements above will not remove the judgments that apply.

//

“Very well, Keith. But if you knew about the FCC's position on internal / external loading coils and radiating ground leads about a year ago, then why has your Rangemaster 1000 continued since then to include an internal loading coil for the antenna system, and why does your Rangemaster website continue to show / suggest an installation that almost certainly will result in a long, radiating ground lead that is non-compliant with 15.219 ?”

Of course our website was updated to help folks comply with the new policy, there is no internal loading coil.

“If a "ground wire" within / without a mast, or a metal mast or other conductor(s) not decoupled for r-f such as the DC power and program lines are connected to the printed-circuit ground plane of the fiberglass circuit board within your Rangemaster 1000 -- then all such elevated configurations will produce more radiation than is legally permitted under Part 15 when used with a ~3-m "antenna."”

I’m sure you are familiar how shielding works.

“Keith -- maybe you should refresh your grade school math skills. A uniform coverage radius of X linear miles equates to a a coverage area of X^2 x pi miles. So a uniform coverage radius of 1 mile will produce a coverage area of 3.14+ miles, not 1 mile as you posted.”
Oops, it appears I messed up that, however I am happy to admit I made a mistake. So 1 mile radius would be 3.14 square miles, 2 miles radius range would be a whopping 12.56 square miles.

So it sounds like you consider it complete fantasy that a part 15 compliant system can even get one mile radius range legally

I am happy to admit my mistakes, I have never seen you admit any mistake anywhere Rich. While physics and math are not usually flawed people are.
Like I have said, I think harping on the ground thing, resulting in the FCC coming up with policy on the vague Part 15.219(b) law was a mistake, FCC policy will always bias to the most restrictive bounds possible, leaving less options to operate under.

This basically has been my entire point to you, Rich all along, since the beginning.

My concern is further harping will only lead to more restrictive interpretations. Please could you think about that.

Rich,

As a Part 15 hobbyist and engineer (civil, not radio), I appreciate your comments. Here's how I view it - and this is based on years of experience with state and federal regulators and how they typically approach difficult interpretations like this. Whether a "ground wire" on an elevated installation radiates may be an academic question only. From an administrative standpoint, the question the FCC has to answer is whether that wire is defined as a "ground lead," regardless of its radiation profile. At some point, perhaps the FCC will simply declare that if the thing radiates, it's a "ground lead," but I don't think that has been officially established.

Reality and the rules don't always line up. For example, consider the contour protection rules. They are only an approximation of reality - in some cases a gross approximation - but are established as a useful tool for administrative purposes. You could find any number of cases where the "actual" interference based on true signal propagation will be greater than predicted by the rules.

The second truth to keep in mind is that the engineering staff of the agency will not always be in sympathy with the administrators who make the decisions.

Assuming a person wanted to be extra safe and ensure that the ground wire did not radiate, what type of wire from the transmitter to the ground rod would you recommend? How about double-shielded coaxial cable?

Chuck

cgbrock said:

Rich,

As a Part 15 hobbyist and engineer (civil, not radio), I appreciate your comments. Here's how I view it - and this is based on years of experience with state and federal regulators and how they typically approach difficult interpretations like this. Whether a "ground wire" on an elevated installation radiates may be an academic question only. From an administrative standpoint, the question the FCC has to answer is whether that wire is defined as a "ground lead," regardless of its radiation profile. At some point, perhaps the FCC will simply declare that if the thing radiates, it's a "ground lead," but I don't think that has been officially established.

Reality and the rules don't always line up. For example, consider the contour protection rules. They are only an approximation of reality - in some cases a gross approximation - but are established as a useful tool for administrative purposes. You could find any number of cases where the "actual" interference based on true signal propagation will be greater than predicted by the rules.

The second truth to keep in mind is that the engineering staff of the agency will not always be in sympathy with the administrators who make the decisions.

Assuming a person wanted to be extra safe and ensure that the ground wire did not radiate, what type of wire from the transmitter to the ground rod would you recommend? How about double-shielded coaxial cable?

Chuck

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I went over this very same subject about the definition of a ground with him more than once in the past. He chooses not to listen.

Yes, I think that would be a positive, helpful and interesting discussion, how to prevent a grounding wire , leading to a true RF ground (I guess it would be leading to the earth dirt preferably) from radiating.

I understand if a tech or engineer for a particular installation feels the radiator is limited to 3 meters, the FCC would allow it unless his engineering seems outlandish.

Also, if someone has an indoor transmitter, using an electrical socket ground, how could they stop radiation from traveling down the power cord to the house box ground, turning the whole house wiring into a radiator?

I don’t think people care much about any added radiation from any ground wire/pole/currents. It is all about being practical, actually being able to install these things where the possibility exists. I think people are happy to limit the radiation from any grounding situation, should their ground be radiating.

http://www.am1000rangemaster.com/coaxground.pdf

Above is a link, we suggest using the outer braid of some RG/8U for example as a Faraday shield.

Rich I challenge you to come up with some ideas that are workable. That actually would be really helpful to me also.

Also all transmitters shipped recently have the option to have the “lighting ground” separated from the radiating RF tank ground simply by cutting a wire on the board, I haven’t had time to make a how to document yet, but I tell people how to do it on the phone should they need to.

cgbrock said:

At some point, perhaps the FCC will simply declare that if the thing radiates, it's a "ground lead," but I don't think that has been officially established.

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Or maybe it has, per the latest FCC policy Keith mentioned. Has this been recorded in a memo or some other official document?

I plan to try the coaxial cable and determine the effect on range, if any.

Chuck

If anyone is interested, I replaced the wire from my elevated transmitter to ground with a shielded coax cable. I did not notice any appreciable difference in signal quality or range.

Chuck
www.geocities.com/victory1610am

cgbrock said:

I replaced the wire from my elevated transmitter to ground with a shielded coax cable. I did not notice any appreciable difference in signal quality or range.Chuck

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Interesting experiment, Chuck.

To some your result may mean that neither the shielded nor the unshielded ground conductor radiated. But really all that can be drawn logically from the result is that there is little difference between the radiation from the two configurations.

Physics and practical experience show that there is considerable radiation from the ground conductor of an elevated Part 15 AM setup. A NEC analysis of this is available as paper 3 at http://rfry.org/Software & Misc Papers.htm .

//

Rich,
I disagree, like I have said before, physics is a starting point for how things work in the practical world.

I have bounds of practical experience with these transmitters, and most ground systems add very little to the overall field strength.

Rich says that physics and “practice experience “ show that there is “considerable” radiation, who knows how he defines “considerable” but seems like I have heard claims that the ground radiation doubles or triples the radiated signal, that just is not the case.

Also I would like to know where the “practical experience” comes from since Rich has never operated a Part 15 system. Part 15 and full power are different arenas.

First of all it just depends on the ground. Some ground system will radiate none at all, some a little, but most will not significantly add to the overall signal.

In testing the biggest difference I could get between a radiating ground and a non-radiating ground, was about 3 db (a fairly significant difference)
However, this was with a wire in the air not up against any structure, suspended at the top and bottom, like an antenna. In practical installations folks shouldn’t get this much difference between shielded/unshielded ground runs because the unshielded grounds are usually wrapped around a pole, up against metal siding, up against a building, ect, keeping it from radiating significantly.

A piece of metal like a building I-beam, water pipe, pole, or such just isn’t a great radiator, when going into dirt at the bottom.

So all the hype about “ground radiation, I think is just entertainment for some, it doesn’t really amount to a hill of beans.

Hamilton said:

Rich says that physics and “practice" (sic) show that there is “considerable” radiation, who knows how he defines “considerable” but seems like I have heard claims that the ground radiation doubles or triples the radiated signal, that just is not the case. Also I would like to know where the “practical experience” comes from since Rich has never operated a Part 15 system. Part 15 and full power are different arenas.

Click to expand...

The same physics applies to unlicensed Part 15 AM systems as applies to licensed AM broadcast stations. And please note that I have operated a legal Part 15 system for my personal use to my personal receivers.

Also, by FCC written and formal examination I was awarded an FCC First Class Radiotelephone Operator License (1959), and have been technically responsible for the operation of a 50 kW Class 1-A (clear channel) AM broadcast station.

Following that I was employed for about 35 years total by the two largest US manufacturers of AM/FM/TV broadcast transmitters and antenna systems, namely RCA and Harris. Also I hold lifetime status as a Certified Professional Broadcast Engineer (CPBE) awarded by the Society of Broadcast Engineers (SBE). Many of my technical papers have been published in the trade paper titled Radio World, and technical software I have written and offered for sale has been commercially successful.

So in summary, my comments are not made without the required technical background, industry experience, and professional recognition.

To Keith Hamilton particularly -- as to what I mean by the "considerable" benefit appying to an elevated Part 15 AM setup with a long, radiating path to a real r-f ground, and by what factor that can multiply the field strength of a truly compliant Part 15 AM setup, please download and read the PDF paper from the link I quoted earlier in this thread.

//

The Real Bottom Line on all this

I have been an interested reader of the Community Radio board for 2 or 3 years now, and have never made a comment until now. This discussion seems to have stretched into a territory any realistic, practical person could call ridiculous. First off, I am a 35 year commercial radio programmer and air personality. I'm also a licensed Ham operator and have done some experimenting with Part 15 equipment. I've gone through an FCC inspection at a station I was working for. I've also spent many brain-liquifying hours reading through hundreds and hundreds of NOUO's and NAL's issued by the Commission. Here are my logical conclusions:
1. Almost ALL of the NOUO's are for the FM band. Almost ALL involve field strengths that would indicate power outputs of at least a few watts, usually more. They DON'T CARE about your C-Crane modulator with 2 AA batteries that will go 100 feet instead of 50 if you turn up the output. They are going after pirates that often interfere with licensed stations, and these people SHOULD be arrested!
2. I've only ever seen a small handful of NOUO's issued for the AM band, and again these few have all seemed to involve someone with significant power. A recent one resulted from a complaint by a licensed TIS station that was being interfered with. THEY DON'T CARE ABOUT THE 20-FOOT MAST YOUR 100-MILLIWATT HAMILTON RANGEMASTER IS MOUNTED ON! They have better things to do, bigger fish to fry!
3. As long as Part 15 operators run an honest 100 milliwatts, stay on AM, don't cause interference and don't try to compete with commercial stations, the FCC's own NOUO list indicates to me that there is nothing to worry about. The ground lead issue is subject to interpretation and will hopefully remain that way. Lets all have fun with Part 15 and quit splitting hairs and agonizing over nothing.

Y'know Rich.. You of all people are one where I have never seen reason to doubt your technical acumen or credentials. I'll go so far as to say that you remind me of my old physics teacher. That comparison is intended as a compliment, since if I had to make a list of the people by whose example I learned to think for myself, he'd be at the top of the list.

I do find myself wondering why you spend so much time and effort on part15 matters, though. Speaking realistically, anyone with even half your education and background experience would be among the wildest fantasies of any LPFM station or rf tech tutorial group.

No this is not a "Rich must be a secret agent for the NAB or FCC!" post. LOL I think that sort of thing tends to come up any time people are confused or disagree with something you say.. But in calmer times many of the very same people will say "Hey Rich, what would this work out to?" and etc.

I think some of the negative reaction comes from people not understanding your motivations. I know that even though I very much appreciate the times you've explained a technical matter to me, I sometimes wonder why you do it.

Is it out of concern for the broadcast airwaves in general? That would make some sense in view of your background. Broadcast engineering has been your life's work. But on the other hand it seems unlikely that you'd see a part15 AM transmitter as any substantial threat to the contour of any licensed station. Simple math, .1 watts vs 1 kw (for example) would be no contest. Even *IF* part15 AM rules allowed an actually somewhat optimal antenna like 1/4 wavelength, the disadvantage in power is still a matter of magnitudes and as such it doesn't seem logical that the "threat" to contours of licensed stations would be the reason.

Even if it *did* ever happen, it would then simply be "causing interference" and would be shut down on that grounds no matter how closely it adhered to any other rules.

Ok, so is it the worry that people might be mislead by things like (just for one example) the assorted 200 milliwatt alleged "part 15 FM" transmitters for sale in assorted places on the net and might inadvertently operate illegally and be hit with fines? That doesn't seem to fit either, since I've never seen your posts as particularly sympathetic with the people who get fined. FCC actions as well as what sort of units are most in demand (FM, which is why I used it as an example) and the simple fact that it being far easier and smaller to make an efficient FM station that is way too high in ERP to be part15 compliant would tend to indicate that the FM band is where most piracy *and* most attempts by people being fined because they *think* they are doing part 15 occur. Now, while you do sometimes talk about FM, it does seem that you talk about possible part15 AM issues far more often. So, since you're an imminently logical person, the issues you tend to focus on wouldn't make sense to me as simply trying to keep people from getting in trouble or them having to pay fines.

Ok, next possibility.. You perhaps object to people having the temerity to feel they can or should try and do anything "community" oriented? That doesn't make any sense, since you yourself donate a large amount of time and work to educating and explaining technical matter in assorted part 15 forums. If you weren't a community-spirited sort of individual yourself, you wouldn't spend this many hours a week explaining technical matters.

For as often as the accusations come up that you're somehow trying to "spoil" part 15, that makes even less sense. One does not "spoil" something by spending a lot of time explaining technical points to interested parties. Heck, if you for some reason wanted part 15 on the broadcast bands to simply not be allowed at all, you could spending your time and money on getting together a lobby group and writing articles showing it as interfering with necessary communications and you'd be using your reputation as a resource to get such articles published and get on talk shows and etc to gather support for that point of view. Patiently explaining technical points and principles of RF and physics time and again for people who ask or express an interest in the more technical threads just doesn't fit with the "spoiler" picture. If you were trying to somehow eliminate part 15 on the BCBs, you'd have no reason to spend time talking with the hobbyists at all.

In any case, to my point. I don't think anyone is actually silly enough to honestly believe that you don't have the necessary technical understanding or expertise to be "allowed" to have a point of view about part 15 technical matters. If anything, it's more confusing why you'd *bother* with it, when you could obviously be spending that time and effort with very appreciative licensed stations or in the vanguard of RF research projects.

Don't get me wrong. I appreciate the time and effort you put in, and I can definitely say that I personally have benefited from being able to ask questions and get explanations from you. I try to remember to thank you when you help me to understand some technical point I'm not getting, but if I've ever missed saying it, allow me to say, "Thanks again, Rich!"..

But I don't understand why you do it, and I don't think others do either. And when arguments get heated, it results in some ill-considered allegations getting tossed around sometimes.

Why *do* you do it, Rich? If it's some personal reason and none of my business, that's fine and well. But for example Traniotti (sp?) is also an expert in the field and while he answered some questions Ermi posed, it was nothing like the amount of thought and effort you put in. Keith, Krimles and Phil all put out commercial equipment and as such have an economic reason as well as any hobby interest they might have, and they answer some questions, sure.. But even if we added Traniotti, Keith, Krimles and Phil all together, I doubt they put in nearly as much time on the boards as you do.

I'm not complaining, obviously, but could you clarify your reasons and motivations a bit? Obviously it's important to you, but I've often wondered why too.

Daniel

Re: The Real Bottom Line on all this

RayThomas said:

I have been an interested reader of the Community Radio board for 2 or 3 years now, and have never made a comment until now. This discussion seems to have stretched into a territory any realistic, practical person could call ridiculous. First off, I am a 35 year commercial radio programmer and air personality. I'm also a licensed Ham operator and have done some experimenting with Part 15 equipment. I've gone through an FCC inspection at a station I was working for. I've also spent many brain-liquifying hours reading through hundreds and hundreds of NOUO's and NAL's issued by the Commission. Here are my logical conclusions:
1. Almost ALL of the NOUO's are for the FM band. Almost ALL involve field strengths that would indicate power outputs of at least a few watts, usually more. They DON'T CARE about your C-Crane modulator with 2 AA batteries that will go 100 feet instead of 50 if you turn up the output. They are going after pirates that often interfere with licensed stations, and these people SHOULD be arrested!
2. I've only ever seen a small handful of NOUO's issued for the AM band, and again these few have all seemed to involve someone with significant power. A recent one resulted from a complaint by a licensed TIS station that was being interfered with. THEY DON'T CARE ABOUT THE 20-FOOT MAST YOUR 100-MILLIWATT HAMILTON RANGEMASTER IS MOUNTED ON! They have better things to do, bigger fish to fry!
3. As long as Part 15 operators run an honest 100 milliwatts, stay on AM, don't cause interference and don't try to compete with commercial stations, the FCC's own NOUO list indicates to me that there is nothing to worry about. The ground lead issue is subject to interpretation and will hopefully remain that way. Lets all have fun with Part 15 and quit splitting hairs and agonizing over nothing.

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On target, well written and to the point. Thanks, Ray!

I hope the nit-pickers like Fry read your post. That's absolutely on target.

Rattan said:

... Don't get me wrong. I appreciate the time and effort you put in, ... But I don't understand why you do it, and I don't think others do either.

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Part of my responsibilities before I retired involved serving as a liason between the engineering resources of the company I worked for and its sales/marketing groups, and also with customers and engineering consultants -- sort of an "impedance matcher," if you like. So my Part 15 posts are rather following the same path.

In my posts I strive to give only factual information, and to show why it is true. I am not against Part 15 (AM or FM), I just see a need to provide accurate information about how it really works with respect to the FCC rules that permit it. My old work ethic of continuing with a task until it is finished has kept me going on these boards until now.

I do admit that it is no pleasure having negative comments and personal attacks posted about me from time to time, but I guess I can stand it in hopes that at least a few people, such as you, Daniel, are getting some benefit from what I post.

BTW, I do follow and contribute to broadcast- and antenna-engineering boards and websites, also.
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