In April of 2010 Bill Defelice of HobbyBroadcaster.net filed a Freedom of Information (FOIA request) for "FCC field operations manuals, field directives and bulletins directly related to field inspectors dealing with operators using Part 15 devices in the AM and FM broadcast bands."
Michael Moffit, Regional Director of the Northeast Region Enforcement Bureau in Illinois:
responded (excerpt): "...We have searched our records and located one responsive document that contains twenty-two pages. We are witholding this document pursuant to.. [several FOIA exemptions].. These exemptions permit non-discloser would risk circumvention of the law..."
That basically means, 'We've got it, but you can't have it.'
You can read a pdf of the FCC's entire response, along with the reaction to their reply in discussion at https://www.hobbybroadcaster.net/community/index.php?topic=656.0
Then again, sometime around June of 2012 Robert Chrysafis (kc8gpd) of Classic Hits 1630am in Denver Colorado submitted another FOIA request , and urged other members of the Part15.us forums to do the same, by seeking information on the following, and for the following reasons:
- "...FCC field operations manuals, field directives and bulletins directly related to field inspectors dealing with operators using Part 15 devices in the AM and FM broadcast bands..
- ...field manual used as a guide when dealing with low power unlicensed part 15 stations on the am medium wave and fm vhf broadcast bands..
- ..'will be used as a guide to aid in better complying with the rules and regulations contained within CFR 47 part(s)15.219(a)(b), 15.239, 15.221, 15.209, 15.217, 15.225.."
In the months to follow, John Mouw of Druid Hills Radio in Dade City Florida, as well as a few other part 15 enthusiast followed suit by submitting additional FOIA requests for the same information, and eventually the FCC responded by providing the requested documents.
Although much of the information in the documents was deemed necessary by the FCC to censor, there was a bit, which, while it was already known information, became officially confirmed as a clear fact, and cut through any "grey area" questions there may have been concerning the field strength requirements of 15.219..
Once upon a time, the vagueness of the term "ground lead" in the three meter rule was considered a "grey area", because there was no definitive definition as to just what it meant..
Was a ground lead the terminal which you connected the ground to? - Sounds right, so lets all raise the transmitter high in the air and attach a 30 foot wire to it for the grounding, cause it's within the regulations..
It flew for years, but eventually the FCC put a stop to it, because the reality was that this caused the antenna systems to far exceeding the 3 meter rule.
Now we all know better.
Excuse me, allow me to get back on topic;
No, we aren't talking about ground leads here, I simply drifted the point..
Now where were we?...
This time, Rebecca Dorch Regional Director of the the FCC Western Region Enforcement Bureau in Lakewood Colorado, responded by providing portions of the requested manual(s), and before long, both of the primary Part 15 hobbyist websites on the net ( Part15.us and HobbyBroadcaster.net ) made it public by posted the following snippet of the actual document highlighting a particular bit of information, and discussed it further in their forums (links to the specific pages forthcoming so check back).
The FCC's Inspectors field operations manual states as follows:
"..For suspected unlicensed operation in the 510 to 1705 KHz (AM Broadcast) band, there are similar requirements. Section 15.209(a) establishes that intentional radiators in this band need not be licensed if they generate a field strength of less than 240001F microvolts /meter, where F is in Kilohertz, at a distance of 30 meters. As an example, a station near the middle ofthe AM band (1000 Kilohertz) would be allowed 24 microvolts/meter at 30 meters from the antenna. There are two exceptions to this rule (15.219 and 15.221) and because there is no field strength limitation associated with operation under 15.219, an inspection is generally required to determine with absolute certainty that an AM broadcaster is in violation of Part 15.1, and therefore unauthorized..."
The key phrase being referred to, and quoted in context is: "there is no field strength limitation associated with operation under 15.219"
Now, yes, granted; we all already knew that broadcasting under part 15.219 was the alternative method to skirt past the field strength limitations set forth in 15.209, however, there was not anything (other than the rule itself) which emphasized so clearly and specifically that 15.219 had no field strength limitations imposed on it at all.. That is, until this documentation was made public.
So does that really help us?.. eh, maybe not, the limit of 100mw input and 3 meter total antenna system length is still the true limiting power to our range, but for those fortunate enough to be located in prime ground conductivity and atmospheric conditions, our signals do stand a reasonable chance of traveling a mile or perhaps more. And in such cases, providing our install is within the FCC Part 15 regulations, we can rest assured that we haven't drifted into pirate territory.
Well Lets take a closer look at the rest of FCC Field Operations Manual ...
Robert C. was gracious enough to supply me a copy of what he received from the FCC to supply here in this blog. You can download it in it's entirety HERE (or at least the parts the FCC didn't redact), but I'm going to present the highlights partially edited...
We have searched our records and copies of 16 pages are enclosed. We are withholding 16 pages pursuant to.. ..FOIA Exemption 7(E) and Section 0.457(g)(5) of the Commission's Rules permit nondisclosure of investigatory records compiled for law enforcement purposes, to the extant that production of such records would disclose investigative techniques or procedures. We have also redacted portions of the documents we are releasing pursuant to FOIA Exemption.. ..of the Commission's Rules, which protect personal privacy interests.
Rebecca L. Dorch
NON-PUBLIC FOR INTERNAL USE ONLY
Unlicensed Radio Operation
Version Date: 5/21/08
On page 3 begins a general overview of the documents with the following topics all being blacked out.: Goal, Objectives, Resources, Measurement Tools, Agent Safety, Transmitters, Databases, and Articles.
ABOUT THIS MODULE
This module introduces the FCC agent to cases involving unlicensed radio operations. These cases are often
referred to as "pirate radio" operations. The word "pirate" is derived from the word "piracy," which is what the subjects in these cases are conducting. This module explains the
steps and administrative sanctions that FCC agents will apply to operators of pirate radio stations. Please note that pirates and unlicensed radio will be used interchangeably.
Page 4 highlights:
OVERVIEW OF UNLICENSED RADIO STATIONS ("PIRATE RADIO")
Agents have the authority under Section 303(n) of the Communications Act to inspect all radio installations of any radio transmitting equipment regulated by the FCC, including unlicensed stations. Unlicensed radio stations is any use of an AM or FM transmitter that exceeds Part 15 of the Commission' s Rules 47 C.F.R. §§ 15.1 et seq....
.. Section 15.1 of the rules, in conjunction with Section 15.239 of the rules, permits non-licensed operation of certain very low power radio transmitters on the FM Band (88-108 MHz) without issuance of an individual license provided the field strength of such operation does not exceed at three meters. Such non-licensed operation is an authorized operation without an individual license...
For suspected unlicensed operation in the 510 to 1705 KHz (AM Broadcast) band, there are similar requirements. Section 15.209(a) establishes that intentional radiators in this band need not be licensed if they generate a field strength of less than 240001F microvolts /meter, where F is in Kilohertz, at a distance of 30 meters. As an example, a station near the middle of the AM band (1000 Kilohertz) would be allowed 24 microvolts/meter at 30 meters from the antenna. There are two exceptions to this rule (15.219 and 15.221) and because there is no field strength limitation associated with operation under 15.219, an inspection is generally required to determine with absolute certainty that an AM broadcaster is in violation of Part 15.1, and therefore unauthorized.
Florida and New Jersey are the only states which have made unlicensed radio operation a criminal offense. The New York, Tampa and Miami Field Offices have worked on several criminal cases with law enforcement agencies.
The New York and Florida State Statutes are below:...
Page 22 & 23:
(note the "Transmitters commonly used for Pirate radio stations" is blacked out)
EXAMPLES OF PIRATE ANTENNAS AND TRANSMITTERS
Antennas commonly used for Pirate radio stations.
Antennas used for Pirate Broadcast Stations have been found atop commercial buildings, clubs, residences, trees, power poles, vehicles, condos, apartment buildings, etc. There are various types of antennas that are used, but below are the more commonly used antennas:
Here is page 3 from another document which the FCC provided, focusing specifically on the Part 15 Low Power Devices:
ABOUT THIS MODULE
This module introduces the agent to Part 15 of the Commission' s Rules, which sets out the rules and regulations under which radio frequency devices may be operated without an individual license. The module also explains the various categories of Part 15 devices, including the rules applicable to each category, a sampling of Part 15 devices, and an introduction to the protocols for investigating a Part 15 device.
Agents will be introduced to the administrative and technical rules for Part 15 devices and the procedures for the investigation of such devices.
.:. Be familiar with the difference between intentional, unintentional, and incidental radiators.
•:. Be familiar with the labeling requirements for Part 15 devices.
•:. Be able to perform a Part 15 device inspection using the appropriate protocols....
The PREREQUISITES, RESOURCES, and EQUIPMENT NEEDED is mostly all blacked out
Part 15 of the FCC Rules permits the operation of a radio frequency device without an individual license.. ..
Part 15 is titled "Radio Frequency Devices," however, the radio emissions of devices operating under this section are limited to a low field strength, and/or or low power level. Thus, the name
"Low Power Devices" has become synonymous with "Part 15".
There are numerous restrictions imposed on devices operating under Part 15. For example, the device must not cause interference to a licensed radio station, and users of Part 15 devices must accept interference caused by licensed stations. No fundamental emissions are allowed in certain frequency bands. Equipment authorizations and FCC labeling are required for most devices. There are various rules applicable only to certain radiators.
The Rules for Low Power Devices are discussed in 47 C.F.R. §§ 15.1-15.61 5, titled "Part 15 Radio Frequency Devices." Equipment authorization procedures for radio frequency equipment, including Part 15 devices, are in Part 2, Subpart J.
ED Specific Rules
.:. Look up and skim Part 15 in the C.F.R.
•:. Look up and skim Part 2, Subpart J in the C.F.R. ED Specific Rules
Page 6: The FCC seldom directly mentions a micro-radio station as one of the 'Intentional radiator' examples. I guess they just don't want to acknowledge us.
An intentional radiator is a device that intentionally generates and emits radio frequency energy by radiation or induction. This is the type of radiator most commonly referred to when discussing Part 15 devices.
EXAMPLES of intentional radiators:
.:. Cordless Phones
.:. Garage Door Openers
.:. Baby Monitors
.:. Wireless Cameras
.:. Keyless Automobile Entry Systems
And lastly, their redaction I find most curious, is what they blacked out under the Public Safety section.. I wonder what's there we aren't allowed to see?
HERE (minus the 16 pages they withheld)