FCC Beefs Up Piracy Sweeps
A follow up by the wannaby agent we all know. Why doesn't he apply for FCC agent as they are hiring according to the above post.
Notice he thinks you go after the users trying to be legal and buying a transmitter with a certification sticker and not the certification process if indeed there is question to a certification. The user is not supposed to know any more than the product has been tested and approved.
Apparently he has driven around with a FIM and actually going to the homes to investigate!
With no authority to do this.
I think Artisan mentioned this back at Christmas but actually setting the FIM up and taking readings and going up to the house? Nuff said.
The article/letter exposes the hypocrisy of that website and Forum.
It's they themselves that are the purveyors of misinformation about Part 15 FM broadcasting. They have an inherent bias against it, and don't hesitate to use fear to manipulate their readers (why do you think they keep mentioning the potential million dollar fine for operating a pirate station).
The true pirate stations, the ones that the FCC wants to shut down, operate with many watts of power. They aren't the little guys who attempt to be legal by using FM transmitters that carry FCC Part 15 certification stickers, even though some of those transmitters might be questionable.
If these guys really wanted to get rid of even the well intentioned pirates, they need to go after the FCC to clean up the certification process. Canada has done it, so there's no reason why it can't be done in the U.S. And it states right in the FCC rules that certified equipment compliance with the rules is the responsibility of the manufacturer who obtained the certification, not the end user (who, in the case of Part 15 FM, would need thousands of dollars of test equipment).
Meanwhile, these guys don't go near the various ways that Part 15 AM broadcasters can go astray of the rules, the most common being long ground leads. To put it simply, any elevated AM installation breaks the rules because of the long ground lead.
Their website has a section on station profiles, virtually all of which are AM. Back in the day there were quite a few photos of obviously illegal elevated stations in those profiles. I revisited them the other day, and lo and behold, there are absolutely no photos remaining of transmitters and installations - all the current photos focus on station studios. That's because it's highly unlikely that any of these stations have ground mounted installations with antenna, ground lead and feedline less than 3 meters. I.e., to use their terminology, they're likely pirates too. But they're AM pirates, which is OK in their eyes.
In fact, it's very rare to hear of any ground mounted AM transmitters. Some elevate their transmitters and don't connect a wire to the ground lug on the transmitter. That's fine, but if the transmitter works at all, there's something acting a path to ground, either the power or audio cables.
That's similar to FM transmitters, which are certified without audio cables connected (dead carrier, no modulation). Out in the field, audio cables and power cables can act as antennas, and take that certified transmitter well over the field strength limit for Part 15.
My take is this. First of all, it's only a field FCC/ISED officer who can determine whether a given transmitter, AM or FM, is compliant within the rules. Not vigilantes driving around with FIMs.
Second, these field officers understand that in the field, FM field strength is going to be greater than 250uv/m at 3 meters, just because of the added audio cables, perhaps extended power cables (nowhere does it say you can't use an extension cord), and even height. But there's a certain field strength that they will allow through before taking action. Certification under lab conditions ensures that that field strength isn't too high.
Similarly with AM. Richard Powers, a member of this site (although absent for a while), theorized that there was also a maximum field strength for AM that the agents would allow - anything above that, and they would step in.
As an example, they stopped KENC broadcasting from the top of metal signposts, where the transmitter was grounded to the metal. Obviously the post was acting as a radiator, which is why they were getting 5 miles range with a Hamilton Rangemaster.
It wasn't the grounding per say that was the issue. At least, I don't think it was. Many other Part 15 AM broadcasters have had elevated installations that passed inspection. It was the range. I suspect that if they were only getting a mile or two range with the same setup, they would have been OK. The reason for limiting the antenna/ground length for AM is to limit range, just as the reason for limiting field strength for FM is to again limit range.
Whew. Quite a long post, sorry. The moral is, ignore the vigilantes. They usually have ulterior motives.
Attempt to follow the rules by using certified transmitters. Keep documentation on what you are doing for any FCC or ISED agents who happen to drop by. Comply with what they say, because they, and only they, have the authority, and the last word.
Any vigilantes dropping by my door would be sent packing in a hurry.
Yes very important to have all the documents pertaining to the rules, your transmitter's certification, in Canada the issue number the transmitter was certified with and rules for that issue as rules sometimes change in later issues that were allowed before as in RSS-210 especially. I have a folder of everything to show anyone who may unlikely show up. Printed everything from the computer that's relevant. Problem arises when an agent is not too knowledgeable as with some of the people you talk to at ISED(Canada) as Artisan and I found out are not that educated with license free use. So you need the documentation.
As for the transmitter in question in the article by the other forum owner the certification info is plainly available online. The lab in China, the company name and address in China and the signature of the lab owner that granted the acceptance. Instead of vigilantism, why not go to the FCC or even contact the lab in China that granted the certification or the company that submitted the item for certification.
They aren't hiding.
I guess the fines aren't collected because you can't get millions $$ if the person doesn't have it and even if you take it from their income it would never be enough to ever pay it.
Unrealistic fines isn't much of a deterrent. In fact, the higher the FCC makes the fine per day the less of a deterrent it can be.
"The moral is, ignore the vigilantes. They usually have ulterior motives"
Yes especially this one guy.
Not only beefing up piracy sweeps, also on licensed broadcasters shenanigans. Some pretty hefty fines have been handed out lately...