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Author Topic: Why, and when did 15.219 originate  (Read 4658 times)
Richard J Powers
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Why, and when did 15.219 originate
« on: December 29, 2011, 02:28:07 AM »

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

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.

Hell that Flagstaff station was the #3 ranked station at one point.

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

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?




« Last Edit: December 29, 2011, 02:38:54 AM by Richard J Powers » Logged
R. Fry
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Re: Why, and when did 15.219 originate
« Reply #1 on: December 29, 2011, 07:05:09 AM »

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
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William C. Walker
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Re: Why, and when did 15.219 originate
« Reply #2 on: December 29, 2011, 07:35:22 AM »

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
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Richard J Powers
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Re: Why, and when did 15.219 originate
« Reply #3 on: December 30, 2011, 07:10:03 PM »

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

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.


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R. Fry
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Re: Why, and when did 15.219 originate
« Reply #4 on: December 31, 2011, 06:55:14 PM »

...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.

The only legitimate answers to these questions need to originate from the FCC.
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Richard J Powers
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Re: Why, and when did 15.219 originate
« Reply #5 on: December 31, 2011, 09:51:26 PM »

...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.

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

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.
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R. Fry
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Re: Why, and when did 15.219 originate
« Reply #6 on: January 02, 2012, 05:04:29 PM »

Your emphasis of "legitimate" implies "official".. which is what I think you meant.

No, I meant this.

le·git·i·mate/liˈjitəmit/
Adjective:   Conforming to the law or to rules.
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Richard J Powers
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Re: Why, and when did 15.219 originate
« Reply #7 on: January 02, 2012, 06:29:23 PM »

Your emphasis of "legitimate" implies "official".. which is what I think you meant.

No, I meant this.

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

Perhaps I'm missing something. How can citing 15.209 against a unit specifically certified under 15.219 be a legitimate action?
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LibertyNT
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Re: Why, and when did 15.219 originate
« Reply #8 on: January 03, 2012, 12:07:29 AM »

Your emphasis of "legitimate" implies "official".. which is what I think you meant.

No, I meant this.

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

Perhaps I'm missing something. How can citing 15.209 against a unit specifically certified under 15.219 be a legitimate action?
He meant the only good answer would have to come from the FCC itself.
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Through The Static. Through The Noise. There's a station somewhere.
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Re: Why, and when did 15.219 originate
« Reply #9 on: January 05, 2012, 08:06:32 AM »



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]
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