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Why, and when did 15.219 originate

R

RPowers

Frequent Participant
I'm jumping from the "can part15 broadcast sports games" thread, which has drifted off topic , and into something new...

OhioMediaWatch said:
The guy actually posted here with the screen name "upnorth" way back in 2005, shortly after the FCC issued a notice to his operation: http://boards.radio-info.com/smf/index.php?topic=7079.0
He said there was a "small technicality" he had to fix, and that the FCC's district director was OK with his operation after that.
I have no evidence he's returned here since 2005, and the upnorth account shows up as "guest" since it was under the previous incarnation of this forum.
Anyone who'd like to reach him...I'm sure you can hook up through the Fox Sports Radio 1650 website, and his office address and phone are not exactly hidden.

LibertyNT said:
Hell that Flagstaff station was the #3 ranked station at one point.
Click to expand...

That's still on a chart on his website.
The small print says it was a telephone survey done by some outfit named "DSN".
Click to expand...

In reference to the link posted above, just posted by OhioMediaWatch to that archived thread .
There's something about it that captured my interest; There is only mention of 15.209, and no mention of 15.219 in neither the thread nor in the NOUO link which is provided there.

Is .219 that new? -- was it not a rule back in 2005?

Which leads to the question.. If 15.219 was only recently created, then what is it that influenced its creation?

--
adum: Obviously it must be that to the FCC; an alternative to .209 was deemed necessary, but why?
 
The link below leads to a discussion of this, including comments from John Reed, Senior Engineer in the FCC Office of Engineering and Technology, Technical Rules Branch (now retired).

Below is some text clipped from Reed's comments. The sentence in bold font is interesting.

On April 14, 1976, in Docket No. 20780, the Commission proposed several changes in Sections 15.111 and 15.113, but did not adopt any of these changes. Paragraph 16, however, made the Commission's intentions clear that it implemented the alternative power measurements in lieu of a field strength limit to make it easier for home builders, that didn't have the means to perform field strength measurements, to demonstrate that their products complied with the standards. However, this rule was never intended to provide a greater operating range than the original field strength limit.

http://www.part15.us/index.php?q=node/1746
 
R. Fry said:
The link below leads to a discussion of this, including comments from John Reed, Senior Engineer in the FCC Office of Engineering and Technology, Technical Rules Branch (now retired).

Below is some text clipped from Reed's comments. The sentence in bold font is interesting.

On April 14, 1976, in Docket No. 20780, the Commission proposed several changes in Sections 15.111 and 15.113, but did not adopt any of these changes. Paragraph 16, however, made the Commission's intentions clear that it implemented the alternative power measurements in lieu of a field strength limit to make it easier for home builders, that didn't have the means to perform field strength measurements, to demonstrate that their products complied with the standards. However, this rule was never intended to provide a greater operating range than the original field strength limit.


Where does it say in writing that this rule was never intended to either increase or decrease the potential operating range of a transmitter?
http://www.part15.us/index.php?q=node/1746
Click to expand...
 
William C. Walker said:
Where does it say in writing that this rule was never intended to either increase or decrease the potential operating range of a transmitter?
http://www.part15.us/index.php?q=node/1746
Click to expand...

It says it in writing in the content summary about the origins of Part15 which Fry posted in the link above:In this longer edit of the thread John A. Reed, Senior Engineer in the FCC Office of Engineering and Technology, Technical Rules Branch explains...

-----------------(the following is a slightly edited portion of the full text)---------------------------------

"On July 18, 1957, in Docket No. 9288, the Commission provided specific provisions for unlicensed operation in the AM band in what would be designated as Sections 15.202, and 15.204 of its regulations. Section 15.202 stated that the field strength limits shall not exceed 24000[/f(kHz)] uV/m at a distance of 100 feet.

Section 15.204 was adopted as an alternative to the field strength limit to avoid the difficulties in making field strength measurements, provided that the input power to the final stage did not exceed 100 mW and the combined length of the antenna plus connecting lead did not exceed 10 feet.

While the Commission originally proposed to permit an input power of 200 mW in the AM band (3rd Notice of Proposed Rule Making in Docket 9288 adopted November 8, 1956), the adopted limit was reduced to 100 mW to reduce the potential area of interference.

"In an Order adopted on November 12, 1974 (FCC 74-1221), the rules were again modified, redesignating 15.202 as Section 15.111 and Section 15.204 as Section 15.113.
Section 15.113 was modified to include the length of the ground lead in addition to the length of the antenna and connecting lead in the 10 feet maximum. This change was added because the earlier rules had not contemplated anyone using an extended ground plane [lead] to extend the range. The change was made to stop this practice.

"On April 14, 1976, in Docket No. 20780, the Commission proposed several changes in Sections 15.111 and 15.113, but did not adopt any of these changes. Paragraph 16, however, made the Commission's intentions clear that it implemented the alternative power measurements in lieu of a field strength limit to make it easier for home builders, that didn't have the means to perform field strength measurements, to demonstrate that their products complied with the standards. However, this rule was never intended to provide a greater operating range than the original field strength limit. The operating ranges were expected to be about equal, but improvements in efficiency were starting to result in increased range, and increased potential interference, for systems operating under Section 15.113.

"Finally, on March 30, 1989, in ET Docket 87-389, the Commission adopted the current regulations. Section 15.111 was incorporated into Section 15.209 without changing the radiated emission limits except to specify the measurement range as 30 meters instead of 100 feet. Section 15.113 was redesignated as Section 15.219 with the only change to the limit being to specify the combined length of the antenna, connection lead and ground lead as 3 meters instead of 10 feet.

--------------------------------------------------------------

The original intention of the part15 rules really are not the major factor to be considered... Even John Reed admits that improvements in efficiency of the more modern part15 transmitters result in a greater range than what they ever expected to happen.. Intention is not always the actual results..

Rules are the result of intentions, but Intentions have no bearing on the actual results of the rules.
My point being.. It doesn't really matter !


But back to my original question, part of which has already been answered,
But what hasn't been answered, is why, (see original link above) in Flagstaffs NOUO back in 2005 was there only mention of 15.209, and no mention of 15.219 .. When in fact the Rangemasters were certified under 15.219, and not subject to the restrictions of the field strength limits imposed by 15.209?

Why was their Rangemaster cited for 15.209 to start with? - The Rangemaster is not even subject to it.
 
Richard J Powers said:
...But what hasn't been answered, is why, (see original link above) in Flagstaffs NOUO back in 2005 was there only mention of 15.209, and no mention of 15.219 .. When in fact the Rangemasters were certified under 15.219, and not subject to the restrictions of the field strength limits imposed by 15.209?

Why was their Rangemaster cited for 15.209 to start with? - The Rangemaster is not even subject to it.
Click to expand...

The only legitimate answers to these questions need to originate from the FCC.
 
R. Fry said:
Richard J Powers said:
...But what hasn't been answered, is why, (see original link above) in Flagstaffs NOUO back in 2005 was there only mention of 15.209, and no mention of 15.219 .. When in fact the Rangemasters were certified under 15.219, and not subject to the restrictions of the field strength limits imposed by 15.209?

Why was their Rangemaster cited for 15.209 to start with? - The Rangemaster is not even subject to it.
Click to expand...

The only legitimate answers to these questions need to originate from the FCC.
Click to expand...

Your emphasis of "legitimate" implies "official".. which is what I think you meant. It also implies an unofficial answer is present.
It certainly doesn't appear that there could actually be legitimate reason for it.

Ok.. Since it happened about 7 years ago, and the Flagstaffs citations have apparently long been resolved; it would be rather pointless to go through the process of contacting the FCC and dredging up the matter now.. Nevertheless, I've only now became aware of this past NOUO episode, and find it puzzling, and cant help but to wonder how it could have ever happened that a unit certified specifically under 15.219, not only was improperly cited for 15.209.. but that no reference to 15.219 was ever even mentioned in the NOUO...

So then; what would be a reasonable speculative answer?

Or even possibly, the genuine 'inside' answer to this mystery.
 
Richard J Powers said:
Your emphasis of "legitimate" implies "official".. which is what I think you meant.
Click to expand...

No, I meant this.

le·git·i·mate/liˈjitəmit/
Adjective: Conforming to the law or to rules.
 
R. Fry said:
Richard J Powers said:
Your emphasis of "legitimate" implies "official".. which is what I think you meant.
Click to expand...

No, I meant this.

le·git·i·mate/liˈjitəmit/
Adjective: Conforming to the law or to rules.
Click to expand...

Perhaps I'm missing something. How can citing 15.209 against a unit specifically certified under 15.219 be a legitimate action?
 
Richard J Powers said:
R. Fry said:
Richard J Powers said:
Your emphasis of "legitimate" implies "official".. which is what I think you meant.
Click to expand...

No, I meant this.

le·git·i·mate/liˈjitəmit/
Adjective: Conforming to the law or to rules.
Click to expand...

Perhaps I'm missing something. How can citing 15.209 against a unit specifically certified under 15.219 be a legitimate action?
Click to expand...
He meant the only good answer would have to come from the FCC itself.
 
But back to my original question, part of which has already been answered,
But what hasn't been answered, is why, (see original link above) in Flagstaffs NOUO back in 2005 was there only mention of 15.209, and no mention of 15.219 .. When in fact the Rangemasters were certified under 15.219, and not subject to the restrictions of the field strength limits imposed by 15.209?

Why was their Rangemaster cited for 15.209 to start with? - The Rangemaster is not even subject to it.
------------------------------------------------------------------------------------------------------------------
From my quick reading on this topic
15.219 certification of the range master only applies if the unit is installed 100% to the specs of the certification. You must install it correctly.
Many people feel that buying a range master automatically gives them a part 15 certified transmitter.
If the unit is not installed correctly to specs, then it is not considered certified and falls under 15.209
Subject to get an NAL

[/quote]
 
just call me Ralph said:
From my quick reading on this topic
15.219 certification of the range master only applies if the unit is installed 100% to the specs of the certification. You must install it correctly.
Many people feel that buying a range master automatically gives them a part 15 certified transmitter.
If the unit is not installed correctly to specs, then it is not considered certified and falls under 15.209
Subject to get an NAL
Click to expand...

I don't see why it is my point isn't coming across clear.
True, I can clearly understand that an improper and/or altered installation voids the certification of a unit.. a certification does not supersede the 3 meter rule, or any other rule; the transmitter must adhere to the installation of which it was certified under..

However, the NOUO made no mention whatsoever on if this installation passed or failed its 15.219 certification, it only cited 15.209 against it.. You see what I'm saying??
In all the NOUOs I've seen (in reference to part15 AM) the code 15.209 is first cited, and then the alternative of 15.219 is considered and judged upon.. one or other must be met for the installation to be compliant.
In this case, the Rangemaster is specifically certified for use under 15.219, yet it was not cited for such, no reference or to 15.219 was made at all in the citation.

It's as if 15.219 did not exist at all. This event took place in 2005, which is what led to me to question when did 15.219 originate... If that code was not yet in existence 7 years ago, then it would all make sense.
But the fact is that 15.219 was already in existence and well established.

Ok.. this seems to be getting nowhere, and it happened so long ago, I guess it really doesn't matter. It probably occurred due to just in error of the inspecting agent, and it was never caught.
 
[/quote]
It probably occurred due to just in error of the inspecting agent, and it was never caught.
[/quote]

FCC inspectors make lots of errors and that's why so little is documented or made public like that 22 page booklet.
 
The "22-page booklet," the existence of which was uncovered by Bill DeFelice because of his Freedom of Information request, very likely deals, at least partially, with allowances that inspectors can make if the limits of 15.219 are measured to have been exceeded. Perhaps the comment by Ken Cartwright that the 3-meter limit may be exceeded by three feet (a bit less than one meter) is a result of of the inspector referring to the booklet while dealing with Ken's case.

It does not surprise me that the FCC would not release the booklet because that would, in effect, increase the limits of 15.219 by any allowances that may be in the booklet.
 
Ermi Roos said:
The "22-page booklet," the existence of which was uncovered by Bill DeFelice because of his Freedom of Information request, very likely deals, at least partially, with allowances that inspectors can make if the limits of 15.219 are measured to have been exceeded. Perhaps the comment by Ken Cartwright that the 3-meter limit may be exceeded by three feet (a bit less than one meter) is a result of of the inspector referring to the booklet while dealing with Ken's case.

It does not surprise me that the FCC would not release the booklet because that would, in effect, increase the limits of 15.219 by any allowances that may be in the booklet.
Click to expand...

Yes because in the cerification process, a 1 meter ground wire was attached to the EUT.
 
The industry test specificatons to be used for certification are cited in the rules, and the ground wire at the test site may or may not have been a factor in the allowance of "three feet" mentioned by Ken Cartwright.

It would be interesting to learn what other allowances there are in the booklet; such as how much input power to the final stage is really permitted under 15.219, and what field strength is allowed under 15.239. I suspect that the "real" 15.239 limit is actually 1000 uV/m at 3m, same as the Canadian FM limit, and four times the US limit. This is because in my necessarily incomplete survey of FM NOUOs, the measured field strengths appear to cut off somewhat above 1000 uV/m at 3 m.
 
I suspect you're correct about the 1000 uv. That would explain the WKID station in Clearwater passing muster with the FCC and a car radio range of about a mile with the Comet antenna at 10 feet and a Ramsey transmitter.
 
1000 uV/m at 3m wouldn't be enough for one mile range under ordinary conditions. If the station mentioned "passed muster," it was because of a waiver of the rules by the Tampa office, not because of an increase in the allowed field strength by a single-digit factor.
 
druidhillsradio: Haven't you posted (with numerous examples) on part15.us that the Tampa Office is particularly lenient when it comes to low-power FM piracy? Also about the use of full 15.219 power on 1710 kHz?
 
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