Thursday, March 16, 2017

NOUO Notices of Unlicensed Operation

NOUO stands for Notice Of Unlicensed Operation,. If you ever receive one of these as a Part 15 broadcaster, it will be because your install or power input is incorrect.. In other words, if you ever get one, it's because you were not following the rules..

Most NOUOs include the following information..
The Commission's records show that no license was issued for operation of a broadcast station on [frequency] at this location..
The only exception to this licensing requirement is for certain transmitters using or operating at a power level that complies with the standards established in Part 15 of the Commission's rules,.. ..the maximum permitted level of 15.0 uV/m at 30 meters established in Section 15.209(a) of the Rules (See 47 C.F.R. S15.209(a). Or the alternative method may be used; Section 15.219(b) of the Rules states "The total length of the transmission line, antenna, and ground lead (if used) shall not exceed 3 meters."


You can access records of everyone of them going back 10 years at the FCC website: http://transition.fcc.gov/eb/FieldNotices/  ( I only went back looking three years )

There have been only 7 instances of the FCC shutting down supposed Part 15 AM broadcasters in the past 3 years... Compare this to the estimate of 1,000's of FM broadcasters receiving NOUO's in the same time frame.

Basically, with Part 15 AM, there are only two factors you must adhere to:
1. Your antenna system can not exceed ten foot.. 
You can mount your transmitter with it's ten foot whip 50 foot in the air if you wanted too, and you'd be legal, but the problem is you can't attach a ground wire to your transmiitter, because that ground wire would in effect extend your antenna that additional 50 foot!
2. Your power input can not exceed 100mw
Below are shown every NOUO issued (in the last 3 years) to an AM broadcaster for being non-compliant with Part 15 rules and regulations. Every one of them was due to excessive power or antenna..
Avoid making the same mistake and you'll be fine
These are edited down versions, click the respective links to read each document in its entirety..

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                 1 NOUO (so far) in 2014   
  ===================================================

1710AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-325287A1.html
  January 17, 2014
   Leonid Lytvynchuk
    Everett, Washington 98204
   Case Number:  EB-FIELDWR-14-00013037
    Document Number:  W201432980001

  On December 13, 2013,
  The field strength of the signal on frequency 1710 kHz exceeded the allowable unlicensed limit of 100 uV/m at 30 meters established in section 15.223(a) for operation on 1710 kHz, 47 C.F.R §§ 15.223(a), as well as the general unlicensed limit of 30 uV/m at 30 meters established in Section 15.209(a) for operation on  1710 kHz, 47 C.F.R § 15.209(a).

  ===================================================
             6 NOUO (not 7, see note) in 2013... 
  ===================================================

1710AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-322711A1.html
   July 23, 2013
   Luis Sanchez
   Bronx, New York
   Case Number: EB-FIELDNER-13-00010214
   Document Number: W2013323800044

   On July 18, 2008,
   The field strength of the signal on frequency 1710 kHz was measured at 3,100 microvolts per meter (uV/m) at 474 meters, which exceeded the maximum permitted level of 30 uV/m at 30 meters for non-licensed devices set out in Section 15.209 of the Rules, 47 C.F.R. S 15.209.

Note: This one strikes me rather odd.. The date of the NOUO is July 23 2013, but the filed report is from July 18, 2008...???..   I suppose it's just  a mistype somehow.

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1600AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-321497A1.html
   June 4, 2013
   Edwin & Teresita Ruiz
   Oswego, Illinois
   Case Number: EB-FIELDNER-13-00008449
   Document Number: W201332320003

   On May 2, 2013,
   The field strength of the signal on frequency 1600  kHz was measured at 8400 microvolts per meter (uV/m ) at 89 meters, which exceeds the maximum permitted level of 15.0 uV/m at 30 meters established in Section 15.209(a) of the Rules (See 47 C.F.R. S15.209(a).

   In addition,.. The source of the 1600 kHz signal is a vertical whip antenna approximately 3 meters long, mounted atop a 50 foot tower in the backyard of 416 Orchard Avenue. The total length of the antenna and transmission line exceeds the 3 meter restriction in Section 15.219(b) of the Rules. See 47 C.F.R. 15.219(b).

  ===================================================   

1700AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-319885A1.html
   March 29, 2013
   Sergey Kibitskiy
   Everett, Washington
   Case Numbers: EB-FIELDWR-13-00007506
   Document Number: W201332980013

   On March 22, 2013,
   Your operation on frequency 1710 kHz was measured at 6,400 uV/m at approximately 251 meters. This exceeds the allowable unlicensed limit of 24000/1700(kHz) or 14.11 uV/m at 30 meters established in section 15.209(a) for operation on 1700 kHz, 47 C.F.R SS 15.209(a).

  ===================================================   

1710AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-319576A1.html
   March 13, 2013
   Peter Kozodoy
   Mountlake Terrace, Washington 98043
   Case Numbers: EB-FIELDWR-13-00007118
   Document Number: W201332980012

   On March 4, 2013,
   Your operation on frequency 1710 kHz was measured at 6,100 uV/m at approximately 125 meters. This exceeds the allowable unlicensed limit of 100 uV/m at 30 meters established in section 15.223(a) for operation on 1710 kHz, 47 C.F.R SS 15.223(a), as well as the general unlicensed limit of 30 uV/m at 30 meters established in Section 15.209(a) for operation on 1710 kHz, 47 C.F.R SS 15.209(a).

  ===================================================
???? - It's curious to note that in the above NOUO, there was no mention made of 15.219, which of course has no field strength limitations, and is a proper alternative method of transmitting Part 15 AM. Therefore, legally the above was clearly an improper enforcement since it lacked any presentation of evidence in the report showing 15.219 was also in violation.
  ===================================================


1700AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-319568A1.html
   March 13, 2013
   Gerald Richard Gaule
   Vancouver, Washington 98685
   Case Numbers: EB-FIELDWR-13-00006961
   Document Number: W201332920006

   On February 26, 2013,
   Your operation on frequency 1700 kHz was measured at 1,800 uV/m at approximately 175 meters. This exceeds the allowable unlicensed limit of 14.11 uV/m (24,000/1,700) at 30 meters established in section 15.209(a) for operation on 1700 kHz, see Section 47 C.F.R S 15.209(a).

  ===================================================


1700AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-319569A1.html
   March 13, 2013
   Teal Pointe Apartments
   Vancouver, Washington  98685
   Case Number: EB-FIELDWR-12-00006961
   Document Number: W201332920007

   On February 26, 2013,
   The operation on frequency 1,700 kHz  was measured at 1,800 microvolts per meter (uV/m) at  175  meters. This exceeds the allowable unlicensed limit of 14.11 uV/m (24,000/1,700) at 30 meters established in Section 15.209(a) of the Commission's Rules. Thus, this station is  operating in violation of 47 U.S.C. S 301

  =================================================== 

Note that the above two NOUOs are one in the same.. Teal Pointe Apartments are located at 10405 NE 9th, which is the same address of the Richard Gaul NOUO

  ===================================================       

1710AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-319247A1.html
   February 27, 2013
   Vladimir Kachinskiy
   Mt Vernon, Washington 98273
   Case Numbers: EB-FIELDWR-13-00006836
   Document Number: W201332980007

   On February 7, 2013,
   Your operation on frequency 1710 kHz was measured at 6,000 uV/m at approximately 217 meters. This exceeds the allowable unlicensed limit of 100 uV/m at 30 meters established in section 15.223(a) for operation on 1710 kHz, 47 C.F.R SS 15.223(a), as well as the general unlicensed limit of 30 uV/m at 30 meters established in Section 15.209(a) for operation on 1710 kHz, 47 C.F.R SS 15.209(a).

  ===================================================
                      2 NOUO in 2012   
  ===================================================

1610AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-315222A1.html
   July 11, 2012
   Desert Christian Schools
   Lancaster, CA 93534
   Case Number: EB-FIELDWR-12-00002784
   Document Number: W201232900007

   On June 13, 2012
   The field strength of the signal on frequency 1610 kHz  was measured at 2,060  microvolts per meter (uV/m) at  134  meters, which exceeded the maximum permitted level of 14.9 uV/m (24,000/1610) at 30 meters established in Section 15.209(a) of the Rules (see 47 C.F.R. S: 15.209(a)).

   The investigation by this office determined that the ground lead was longer than the length of a 2-story tall building, thereby, increasing the total length of the transmission line, antenna, and ground lead well beyond 3 meters. This installation violated Section 15.219(b) of the Rules.

  ===================================================   


1680AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-313358A1.html
   March 28, 2012
   EPI Limited Partnership
   Fullerton, CA
   Case Number: EB-FIELDWR-12-00001143
   Document Number: W201232900006

   On January 30, 2012,  agents from this office confirmed by direction finding techniques that radio signals on frequency 1680 kHz were emanating from the property at  1370 Brea Blvd., Suite 205, Fullerton, CA  92835.  On February 29, 2012, the agents re-visited the above address and confirmed that the signals were still emanating from that location.

   The  field strength of the signal  on frequency 1680 kHz was measured at 17,900  microvolts per meter (uV/m) at 60 meters, which exceeded the maximum permitted level of 14.3  uV/m  24000/1680) at 30 meters established in Section 15.209(a) of the Rules (see 47 C.F.R. S: 15.209(a)).

   During their investigation on February 29, 2012, the agents determined that the ground lead was connected to a cable that ran down the length of the antenna tower, thereby, increasing the total length of the antenna, transmission line, and ground lead well beyond 3 meters. This installation violated Section 15.219(b) of the Rules. During that inspection, the agents observed that the ground lead at a point close to the street level had been cut, leaving the line at its original length, but not physically connected to the ground. This configuration will also violate Section 15.219(b) of the Rules as the total length of the antenna,transmission line, and the lead, attached to the transmitter, exceeded 3 meters.

  ===================================================
           4 (not 7) NOUO (see notes) in 2011  
  ===================================================

1620AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-309211A1.html
(a) August 19, 2011
   Robert Mohamed
   South Richmond Hill, NY
   Case Number: EB-11-NY-0230
   Document Number: W201132380006

   On August 3, 2011,
   Your operation on frequency 1620 kHz  was measured at 900 microvolt per meter (uV/m) at  1132 meters. This exceeds the allowable unlicensed limit of 100 uV/m at 30 meters established in Section 15.223(a) for operation on 1620 kHz, 47 C.F.R. S: 15.223(a), as well as the general unlicensed limit of 30 uV/m at 30 meters established in Section 15.209(a) for operation on 1620 kHz. 47 C.F.R. S: 15.209(a).

  ===================================================

1620AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-309312A1.html
(b) August 23, 2011
   Robert Mohamed Corrected copy
   South Richmond Hill, NY
   Case Number: EB-11-NY-0230
   Document Number: W201132380006

   On August 3, 2011,
   The field strength of the signal on frequency 1620 kHz was measured at 900 microvolts per meter (uV/m) at  1132  meters, which exceeded the maximum permitted level of 14.8 uV/m (24,000/1610) at 30 meters established in Section 15.209(a) of the Rules (see 47 C.F.R. S: 15.209(a)).

  ===================================================

NOTES: The above two shown NOUOs (a) & (b) are actually the same NOUO, not two as it appears.
       It is only a correction of the same report.

  ===================================================

1610AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-309212A1.html
   August 19, 2011
   Willie Walton
   Santa Clarita, California
   Case Number: EB-11-LA-0092
   Document Number: W201132900010

   On August 11, 2011,  
The field strength of the signal on frequency 1610 kHz  was measured at 2,730  microvolts per meter (uV/m) at  145  meters, which exceeded the maximum permitted level of 14.9 uV/m (24,000/1610) at 30 meters established in Section 15.209(a) of the Rules (see 47 C.F.R. S: 15.209(a)).

   The investigation by this office determined that the ground lead was connected to a cable that ran down the length of the antenna tower, thereby, increasing the total length of the antenna, transmission line, and ground lead well beyond 3 meters. This installation violated Section 15.219(b) of the Rules.

  ===================================================

1650AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-308327A1.html
(c)July 5, 2011
   Xeng Xiong
   St. Paul, Minnesota
   Case Number: EB-11-CG-0028
   Document Number: W201132320008

   On May 15, 2011,
   the field strength of the signal on frequency 1650  kHz was measured at 550 microvolts per meter (uV/m ) at 353 meters, which exceeded the maximum permitted level of 14.5 uV/m (24,000/1650) at 30 meters established in section 15.209(a) of the Rules (See 47 C.F.R. S:15.209(a)).

   During the inspection on May 15, 2011, the agent observed the station had five  antennas mounted on the roof, each with a vertical whip approximately 3  meters long, and the ground leads totaled over 15 meters in length. This   antenna installation violated section 15.219(b) of the Rules.

  ===================================================

1620 and 1630AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-308328A1.html
(d) July 5, 2011
   Kou D. Her
   St. Paul, Minnesota
   Case Number: EB-11-CG-0129
   Document Number: W201132320009

   On May 16, 2011, an agent from this office confirmed by direction finding techniques that (1) radio signals on frequency 1620 kHz were emanating from 1146 Rice Street in St. Paul and (2) radio signals on frequency 1630 kHz were emanating from 399 East Maryland Avenue in St. Paul. .... The owners of the properties where these stations are located reported to the agent that they granted you permission to install transmitters at those locations.

   The field strength of the signal on frequency 1620  kHz (1146 Rice Street) was measured at 470 microvolts per meter (uV/m ) at 1243 meters, which exceeded the maximum permitted level of 14.8 uV/m (24,000/1620) at 30 meters established in section 15.209(a) of the Rules (See 47 C.F.R. S:15.209(a)). Similarly, the field strength of the signal on 1630 kHz (399 East Maryland Avenue) was measured at 450 uV/m at 599 meters, which also exceeded the maximum permitted level of 14.7 uV/m at 30 meters.

   During the inspection on May 16, 2011, the agent observed that the approximate length of the antenna, transmission line and the ground lead at 1146 Rice Street was approximately 26 meters.
   Similarly, the ground lead at 399 East Maryland Avenue exceeded approximately 3 meters in length. These installations violated section 15.219(b) of the Rules.

  ===================================================

NOTES: The two above violations involved what sounds to be clusters of transmitters on multiple roofs. Both (c) & (d) consist of three violations within 24 hours, in the same town and close proximity to each other, which indicates them to be a single group entity.. So for this reason these could be considered as just one NOUO, not two.

  ===================================================

1610AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-306481A1.html
(e) May  5, 2011
   Gregory C. Schuller, Sr.
   Sadie M. Schuller
   Arizona City, Arizona
   Case Number: EB-10-SD-0217
   Document Number: W201132940007

   On April 21,
   The field strength of the signal on frequency 1610 KHz was measured at 1,900  microvolts per meter (uV/m) at  130 meters, which exceeded the maximum permitted level of 14.9 uV/m
  
  During the investigation on April 21, 2011, the agents observed that the approximate length of the antenna, transmission line and the ground lead was 8 meters. This installation violated Section 15.219(b) of the Rules.

  ===================================================

1610AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-306483A1.html
(f) May  5, 2011
   Audie Ray Morrow
   Sandra Jean Morrow
   Casa Grande, Arizona
   Case Number: EB-11-SD-0086
   Document Number: W201132940008

   On April 21, 2011,
   The field strength of the signal on frequency 1610 KHz was measured at 1,200  microvolts per meter (uV/m) at  430 meters, which exceeded the maximum permitted level of 14.9 uV/m (24,000/1610) at 30 meters established in Section 15.209 of the Rules (See 47 C.F.R.  S:15.209(a)).

   During the investigation on April 21, 2011, the agents observed that the approximate length of the antenna, transmission line and the ground lead was 10 meters. This installation violated Section 15.219(b) of the Rules.

  ===================================================

NOTES: Casa Grande and Arizona city are only about 10 miles apart..add the facts that they both broadcast on the same frequency, and were both cited on the same day, one could easily conclude that they were also just one group working together to cover a larger area.. So again, these two can also be considered in essence a single NOUO.

  ===================================================

So remember, being a part 15 broadcaster means following the part 15 rules and regulations...




2 comments:

  1. You'll notice that the Kozodoy NOUO is for operation on 1710Khz. 47 CFR Part 15.219 applies to operation between 510khz and 1705khz. So this NOUO falls outside the accommodations afforded by Part 15.219.

    I notice a lot of "Part 15" operators go for 1710Khz, I guess to avoid interference, but they place themselves under a much more restrictive rule by doing so.

    ReplyDelete
  2. Good point, that didn't even occur to me at the time.
    Although several of the citations listed in this thread had broadcasted on 1710, I wouldn't go so far to say a lot of part15 broadcasters go for 1710.. I get the impression that most of those receiving NOUOs above were really just pirates attempting to operate under the guise of part 15. I don't know of many, if any of the part 15 broadcasters on the hobbybroadcaster.com, part15.us, or the alpb.com forums who choose to utilize 1710 for their broadcasts, because as you point out it is a self defeating option.
    Thanks for your input. I plan to compile another list of AM NOUOs spanning from Jan. 2014 to the present sometime in the near future.. though I don't think there's been that many of them since.

    ReplyDelete

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