Fortunately I am getting some good and insightful comments of the constructive nature from Part 15 members on my 15.219(b) petition.
Fortunately I am getting some good and insightful comments of the constructive nature from Part 15 members on my 15.219(b) petition.
So far I have added some changes to the petition since then due to comments mostly from here at this site.
Over at the Yahoo LPAM group however, it is more or less de constructive. With allot of off the wall comments and spin doctoring going on there. In some very long text. Allot of long winded derogatory commentary.
Anyways I have made some very good tweaks and changes in the Petition due to the members here. So thanks for the ideas. I am glad you folk are interested in reading,
I realized from the LPAM group that people can misinterpret things. So I have added a Froward page and some comments in the suggested rules to explain clearly that the suggested rules are to make no changes in the way a current Part 15 station can operate across the 530 to 1700 kHz spectrum. And that the rules apply only to the suggested application for an alternative mode of operation. And so unless that is spelled out, there can be some misunderstanding occur.
Anyways there will be another version of the Petition as a sort of evolved Petition based upon your input. And you can read it. I suppose it will have to make it’s way around the circuits and be read and debated before some folk will pick it up and sponsor it. How long that will take, I do not know.
I added a few more illustrations and two circuit diagrams also. A tunable and amplified field strength meter and a antenna resistance bridge.
And upon suggestion I left open the idea of choosing methods to use to suppress coax emissions and added illustrations of methods. And allow for any new and good method known to work well, to be used. So as suggested, I do not confine that problem to being addressed by one method only. Any good method then can be employed. And I guess that is good for innovation.
Oh, I have been studying a Petition for LPAM or low powered AM. That is sort of a hot topic and very political. Too much going on and to much pulling of factions apart. I figured those folk will be debating for ten years on that. It looks kind of dismal there. Anyways, Part 15 can be made a little better I think. And maybe a little more fun perhaps.
The LPAM folk want to suggest raising Part 15 to 1 watt. Unfortunately that would not be a Part 15 application and would be more of an intermediate class radio service that would have to fall under rules of it’s own. It would have to be written for new rules for a new service and not be suggested to be placed under Part 15. 1 watt is in the range of low power and not micro power. So it would have to be written as such.
I am only writing about how to use an alternative antenna system in Part 15 and make it comply with standards the FCC might find acceptable. And acceptable sort of along insight you would obtain from reading about the TIS radio service specs.
Anyways thanks for the good comments and emails.
As you observed, the LPAM
As you observed, the LPAM forum was the wrong place to put forward your proposal. In fact, the forum guidelines specifically indicate no discussion of Part 15 is allowed. Those people are primarily interested in starting an LPAM service similar to LPFM but for commercial purposes. Better to discuss your proposal here.
However, having read the comments on that forum I think some of the criticisms are good and justified. For example, for all the technical specs you provided you still have not given the FCC one good reason why they should even re-examine the Part 15 rules in the first place. You have to satisfy the legal aspects (that is to say, the public good aspects) of your proposal in addition to the engineering aspects. As we know, the FCC is made up of engineers AND lawyers. How does the public benefit by amending antenna requirements for Part 15 AM?
As stated on that forum and here, you’re better off filing a petition of rulemaking as an organization or in partnership with an organization. Filing a petition as an individual is usually a non-starter with the FCC. I know of a petition to raise the Part 15 FM power limit to 1 watt, filed by an individual that has been on the FCC docket for over 10 years. I doubt it will ever see the light of day. However, the FCC does respect certain organizations and will seriously consider their petitions. These groups include; Prometheus Radio Project, Public Access Project, the ARRL, to name a few. You may do better partnering with these groups.
Then there is the idea of leaving well enough alone. Do we really want the FCC to re-examine Part 15 AM requirements? Do we really want clarification on the 3 meter rule? One of the reasons the Rangemaster is such an amazing transmitter is that it pushes current Part 15 AM limits to the wall to allow community broadcasting, and does so legally. Would that opportunity go away if the FCC set new rules for Part 15 AM?
C5
Legally
C5 wrote One of the reasons the Rangemaster is such an amazing transmitter is that it pushes current Part 15 AM limits to the wall to allow community broadcasting, and does so legally.
This depends on how it is installed. Even a transmitter certified for Part 15 AM can be installed so that the system is non-compliant.
Here is a case where the FCC cited a Part 15 AM setup for using a long ground lead, for example.
Of course, everyone is free to choose the configuration they install.
http://www.fcc.gov/eb/FieldNotices/2003/DOC-273690A1.html
//
Is it just my imagination?
Or do more Part 15 enforcement actions emanate from the Langhorne office than anywhere else in the country?
Maybe they don’t have enough to do, with cross-ownership, media monopolization, satellite radio consolidation, network neutrality, must carry rules, and white space devices…
WEAK-AM
Classical Music and More!
Imagination?
WEAK-AM wrote about the FCC’s Part 15 AM enforcement practices Maybe they don’t have enough to do, with cross-ownership, media monopolization, satellite radio consolidation, network neutrality, must carry rules, and white space devices.
Your frustration is noted, but isn’t this a natural legacy of the general actions and budgetary priorities of law enforcement agencies?
If so, probably murder would be at the top of your list. But does that mean that lesser infractions should be ignored?
In the opinion of some, the legitimacy of all legal enforcement actions may depend on whose ox is being gored.
But in a larger sense, enforcement agencies are obliged to provide at least a modicum of attention to all infractions of written law, no matter how inconsequential they may be viewed by those who hope to escape such attention.
RF
Proposed AM rule making
Dan,
You are very kind in expressing your appreciation for the help you have received from the members of this board and thanks for taking time to express this.
You are among friends with similar interests here but you will get comments which may not agree with yours. Just take them as friendly advice and food for thought.
Now, maybe you can help me a bit. I read your original proposal once through and it seems that what you want to codify in a rule change is an antenna system (namely with a resonator coil) which is already permitted in the 15.219 rules. You have extended this to transmission lines and feed systems, but other than that there seems to be nothing which will improve the radiation efficiency beyond what can already be done within the rules. I miss things all the time so this is your chance to educate me.
Neil