Saturday, December 15, 2018

A Wild Goose Chase Through the FCC


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NOTE:
The following post has been sitting in my draft folder since May 2017. For a better part of that year I'd been in the middle of research which eventually uncovered an absolutely fascinating story about Part 15 which apparently few are aware of - I never heard this story discussed or even mentioned in my 15+ years of being in the hobby. It concerns the rise of 15.219 intentional radiation activity which quite rapidly escalated to becoming the Part 15AM broadcasting as we all know it today...
 
What the hell am I talking about?

Well, if you've been following my progress in the forums (particularly at Hobbybroadcaster.netbeginning in January of last year and thereafter, then you pretty much already know. If not, then follow me now and I'll show you the way I found it. There were a lot of loops and flips during the course, which are conveyed below, and though you may not have the patience to endure it, I chose to leave the post as it is.. mainly because I'm finding it rather difficult to edit! It's soooo long, and awkward.. I had kind of written it as I went along over the course of several months, and it's just a total mess.. but I couldn't bring myself to delete it and start over. So, after some debate and hesitation, I've decided what the hell, go ahead and post this mess. At least it's got some good historic information.

I wrote the following in March 2017 and then came back to it and tweaked it a little sometime in May, and it's just been sitting in my draft folder since.. disjointed and unfinished.

I'll tell you what, all I had been looking for was information on some specific (though unspecified), vintage, manufactured part 15 transmitters; What I found was something never expected. So consider the following long-overdue posting as the prelude to a much more fascinating story, which will be featured in my next post; soon to come...

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A Wild Goose Chase Through the FCC

Back in January [2017] I embarked on an exploratory tour, and wound up on a wild goose chase down the halls of the FCC.
This is how it all began..

In a previous post: history of Part 15  was a compilation of research by others with a specific focus on 15.219. But this time I set out to do some research of my own..

The previous 'history' post revolved around a letter from former FFC Chief Engineer John Reed who had provided a complete history of the Part 15 rules we broadcast under, beginning at it's inception in 1936, then all the way up to the present day. Within his presentation Reed provided the following bit of info:

"In an Order adopted on November 12, 1974 (FCC 74-1221), ..Section 15.113 (now 15.219) 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."

I found this particularly interesting because as many know, about 12 or more years ago there was a big debate going on within radio forums on the actual definition of the term "ground lead". The argument stemmed from the fact that most Part15AM installs utilized radiating grounds to achieve excessive ranges, some reporting as far as 10 miles with a single transmitter. The consensus amongst the hobby community was it conformed to the rules, and the instruction manuals of certified transmitters emphasized elevated installs using long grounds, and even displayed illustrations and examples as a guide. So it's not surprising that most, myself included, employed these methods...

However, there was a naysayer who arose insisting "ground lead" was not just the connecting lead itself, but also the entire run of wire connecting to ground.. Thus; our installs were exceeding 3 meters. Over time the argument got nasty, and continued for nearly a year, maybe more. It shined a spotlight which seemed to incite the FCCs attention to take action. So ultimately, many hobbyist felt they had no choice but to eliminate the radiating gw or discontinue operation entirely. This all coincided during the time of KENC... (which for those unfamiliar, is another story for another post)...

It wasn't until years later I realized it was an old song and dance which had played before. In hindsight, all things considered, it should have been obvious that a single transmitter reaching the 3 to 10 mile ranges boasted could not  possibly be legal without a license. Nevertheless, the rule does only vaguely describe the "ground lead (if used)"..
It's a debate that never ends.

What is best taken away from this is that a ground mounted install is the most prudent method, although not as common, nor practical, and space to do so is not always available.. but it complies the with 3 meter rule by 100%.

But anyway, let's get back to the point.. Reed explained that radiating grounds had not been permissible since 1974, the research showed it, and that was that...

Now, this post really isn't about ground leads, but...
That's when the wild goose chases began...

Reed had had explained the "ground lead" became part of the three meter length in 1974 to prevent the capability of exceeding a specified field strength, but in spite of it, became evident that greater ranges than intended were still legally being achieved.

Well, that must of pissed someone off; Next thing you know someone, somewhere, somehow, expressed concern about it, which led to, a year and a half later, a proposal which went before the commission to disallow alternate rules for manufacturers so to completely eliminate any possibility of extended range.
 Submitted April 1976, FCC Docket 20780, excerpt below:

(Note that the 15.111 rule was what is now 15.209 and 15.113 was what is now 15.219)


Basically what this document concluded is that all manufactured part 15 transmitters would have to be designed to conform to the limited field strength of 15.209, without the option of utilizing the alternative 15.219.

Fortunately, for reasons which remain elusive, the FCC commission voted against the proposed change. If the amendment had gone through then none of the FCC Certified Part 15 transmitters from the last 35 years, like the Rangemaster, Procaster, The IAM, Grain, LPB, Realty Radio, Talking House, Talking Sign and others, with most still in production; none of these would ever had existed, nor is it as likely many compliant kits like SStrans and similar models would be around.
But most importantly, had that rule gone through most of us would have never bothered to enter this hobby. Surely the more technically minded hobbyist would still have been designing and constructing their own transmitters, and would of had the option of utilizing the 15.219 rule - having the capability of range, but the plug-n-play crowd would be out of luck.

There was something odd about this story, and I couldn't help but see a puzzle in it.. Why did they vote it down? I mean I'm glad they did, but why?
 
.. It has come to our attention, that manufacturers are taking advantage of the alternate provisions to market devices.. ." -Docket 20780

During the 1970's the FCC had been concerned when manufacturers defeated the limitation the rule had intended to impose.. yet they voted to not change the rule, they let it be. Why? Doesn't make sense. Speculation suggest there must have been some kind of lobbying going on to prevent detrimental effects to some business model or something.. or maybe they just didn't want to deter innovation..

( By the way, just of note, interestingly, this "no field strength limit" concern surfaced again in 1987 during some proposed Part 15 changes in FCC Docket No. 87-389, and it was again specifically concluded that: "..The existing Part 15 frequency "windows's within which higher field strength limits are permitted would be retained.." But this isn't about the 1980s, let's return to the 1970s..)

Who was manufacturing part 15 transmitters
in the 1970s?..
Monitoring Times Feb 1984
Another missing piece of the puzzle is what were these part 15 transmitters models that were being manufactured 40 years ago which had prompted the FCC to consider amending the rules to begin with??.. I wanted to know;

My first thought was it must have been the ever popular and plentiful Talking Houses, but it couldn't be, because both they and their predecessor Realtor Radio had not even come into existence until the early 1980s.. This surprised me because I have distinct memories (excuse my digress..) during the mid 1970s. In Colorado, my sister and I would ride our bikes around brand new uninhabited subdivision developments, where on every block would be a sign in front of one of the houses instructing what frequency to tune and listen to amenities of that particular model home. The signals were weak and we needed to be within a half block for reception on our handheld portable radio, so they probably were some kind of part 15 broadcasts, but I could find no reference about any realty companies using portable transmitters In the 1970s...

For that matter, I couldn't find any examples of Part15.219 type transmitters being manufactured during the 1970s at all..

PE1972
First tried the FCC database but got nowhere with that, Goolged to all ends to no avail. Browsed page by page though countless electronics magazines from early 1970s mostly from those available at the American Radio History archive, but also Boys Life magazines as they were into radio. Asked in the forums, but initially could still find no indication of any specific manufactured part 15 transmitters from that time period... Well, actually there were indications; besides the 1974 FCCs document saying they existed, a 1972 issue of Popular Electronics (click image at left) also described a example of a probable part15 AM broadcast though there was not details. But other than that, everything I've came across, researched, or ever heard about, part 15 broadcasting, as we know and use it today, didn't even begin to gain any popularity until the mid 1980s when the FCC certified Talking House transmitters began getting popular as turn-key, ready to transmit units suitable for a business and hobby station installations.

But the 1970s??.. no example of any transmitter that fits the bill, nothing at all. ...

Then something hit me!.. I had been at it for days when it suddenly occurred to me that results for the model RC airplanes had kept turning up during my searches.. Could it be the concern wasn't an audio delivery device at all?...
retrospace.org
The model radio control airplanes underwent a huge surge of popularity in the late 60s and early 70s, these hobbyist would probably do all they could to optimize flight range. I was able to confirm at least some of them were operated by AM modulation, but saw no specifics of what frequencies.. For a moment it all seemed to fit, after all they were manufactured unlicensed transmitters.. But was it part 15? I did not find a readily available reference to indicate which rule they were governed under back then. In the present day they operate under 97.215, but not in 1974 -view Back then 97.215 was for something else entirely..
But wait a minute, I finally realized.. no, these can't be them.. I had just been grasping at straws; The governing rule in question is 15.219, why would model planes utilize the AM radio broadcast bands?,
They wouldn't.
Besides, It's not even reasonable for them to use ground leads, nor is there any indications that those remote controlled transmitters would be tethered to ground with a long lead as they flew their planes. No, it was a ridiculous thought which took me a half a day to realize, but I eventually came to my senses and abandoned looking further. Indeed it was just a wild goose, so that goose went by without further chase..

There had also been passing thoughts of electric garage doors as a candidate, but that was just as silly a notion, so were baby monitors.
But these were the kind of unlicensed transmitters being manufactured at that time, yet none of them fit the quest. -There was really no doubt about it; the part15 devices which the FCC had been concerned about had to be portable AM transmitters, probably outdoor, something very similar of what we use today.
None of these were any of that.

So a few more wild geese go by without chase, and I was back where I started..  Again;

"Nov.1974 ..Section 15.113 (now 15.219) was modified .. had not contemplated anyone using an extended ground plane to extend the range. The change was made to stop this practice.." -John Reed

So the radiating ground got cut by the FCC... and then:

.. It has come to our attention, that manufacturers are taking advantage of the alternate provisions to market devices.. ." -April 1976 Docket 20780

What manufactures? What devices?... Yes I know I'm repeating myself. But that's where I started and this is where I ended up. Going in circles. What kind of wild goose is this?

I sat there dumbfounded; and right about then, as if to distract me, another discrepancy crosses my path; Over at the ALPB forums 'Druid Hills Radio' had posted a new thread titled:
 "OCE 12 An interesting read.." - no comment was made, just the link: apps.fcc.gov/edocs_public/attachmatch/DOC-335623A1.pdf
Naturally I gave it a click and it pulled up a dirty March 1973 copy of OCE 12 that looked like it came from an old Xerox machine that needed it's drum cleaned. I had seen this before, no big deal. I went ahead and casually scrolled the page down a few swipes not really paying much attention - until I spotted this.. 
What?.. that shouldn't be there!...
As soon as I read that paragraph I was flabbergasted, as this early 1973 document clearly states the ground lead as part of the 3 meters: --Whereas John Reed reported that rule had not been amended to include the ground lead until November 1974 !
 
Big deal you say?... Well it was to me, because I wanted the facts straight.
 
So I went to review 74-1221 in hopes of making sense of this discrepancy, but as so often happens with trying to locate copies of  FCC documentations; Docket 74-1221 is nowhere to be found anywhere on the FCCs website! - I hate it when that happens, and it happens more than you might think.
So I googled for hours to all ends but was still unable to turn up a copy of it anywhere, although there were numerous references to it being made within other documents, but not the docket itself. However, I was at least able to turn up a "snippet view" which really provided absolutely nothing, but did confirm the document indeed existed and that it had not been just a miss-type performed by Reed...
 
I was quite frustrated and expressed it in the forum.. Fortunately HB member TomTom managed to locate a complete copy of 74-1221 at the University of Texas Digital Library - Adopted November 12 1974, Released March 7, 1975. Here is shown an excerpt of  74-1221 found at the bottom of page 498 thru the top of page 429:
 
(Note that the 15.113 was what is now 15.219, and 15.111 was what is now 15.209 )
When you observe the rest of the document it's clear the addition of the ground lead was definitely one of the amendments, so Reed was correct after all. But why was the ground lead addition specified a year earlier in OCE 12 ??
 
 -- Well,  you guessed it --
It was just another wild goose chase; one which wouldn't have occurred if only I had just bothered to read the entire OCE 12 document to begin with, and understood exactly what an OCE document was..
An OCE document is basically a report on research done, which also may make proposals.. In other words it does not impose regulations, but only propositions for consideration.
Dammit, I suck at research but obsessed in figuring this all out, and was at least finding some interesting things along the way.
 
For example, it's interesting to note that in the above docket 74-1221:
  • Certification was not mandatory for manufactured part 15 devices until after April 1, 1975.
  • Equally interesting is that a "Special Temporary Authority" option was created to provide a means of operating in a manner inconsistent with part 15 if it could be shown that the operation was in the public interest and "that it is for a unique type station or for a type of operation which is incapable of establishment as a regular service, and that the proposed operation cannot feasibly be conducted under this part [part 15]
  • .. And that's but a few, there were more changes and other new clarifications applied within as well.. But, getting back to the point; it all had to do with new transmitters which were hitting the market...
 
So yeah, something particular was definitely happening concerning Part 15 during the early-mid 1970s.
But what? Within just a 2 year time period part 15 AM was being scrutinized harder than it ever had been in during its 80 year history..
What was the fuss? - Mystery transmitters.
Anyway, Reed was indeed correct; the ground lead wasn't written into the rule until 1974 even though it had actually been a documented concern for at least a few years prior to that.
 
But dammit, this quest isn't about ground leads, it's about some mysterious certified transmitters from the early 70's that all the sudden caused some very notable changes to Part 15 regulations to take place.  
 
So now what? Ok, so maybe we need to go back farther, a couple more years, maybe these mysterious transmitters were manufactured earlier and became a problem later, thus corresponding with the time frame scenario of when the FCCs concerns arose. No, it didn't seem to add up, but not knowing what else to do, decided to take a look anyway...

Ok, what have we got?
I did some more digging around but was getting nowhere. I had also inquired with the members over at the HobbyBroadcaster forums; Some had suggested the RadioShack Talking Microphone kits, which were from the 1970s but they didn't even have any ground connection option for them...
Other suggestions from the 1960s were the part 15 Knight Kits or those found in the Lafayette line of kits, and also the popular little Remco Caravelles, but most of those were either way too early or too toy-like in my opinion, no, my impression told me that none of those suggestions really fit...

By the way, Speaking of the Remco Carravelle, (how about a break?) here's a bit of trivia; Rush Limbaugh begun his career on one! Here an excerpt from: Rush Limbaugh: An Army of One which describes the event..


William Shatner and Rush with a Remco


"..."Even when I was a little boy, I dreamed of being on the radio"... At first his parents encouraged him. At fourteen they bought him a Remco Caravelle radio set that allowed him to broadcast on any AM channel within the confines of his house. He played records and did DJ chatter, usually to an audience consisting of his mother. It was such a thrilling experience that Limbaugh never forgot it and sometimes talked with nostalgia about the lost Remco Caravelle of his boyhood. One day a listener sent Rush his own Remco. Limbaugh established his cyber-museum in 2008, and the Remco Caravelle is one of it's featured icons.."
similar story at: www.smecc.org/remco_caravelle.htm)
 

Rush also talked about this with William Shatner during an episode of "Shatner’s Raw Nerve" that aired on the Biography Channel, here's a brief transcript of that discussion...
 
SHATNER: You brought something with you here you wanted to show me to discuss.
RUSH: I did. My parents, despite what I told you earlier about being frightened of my being on the radio, gave me this for Christmas when I was nine years old. This is a Remco Caravelle, and it actually transmits —
SHATNER: It transmits?
RUSH: It transmits on an AM frequency of your choice for 500 feet. And I would take this up to my bedroom and play records and play deejay —
SHATNER: To the house.
RUSH: — to the house, and my mother and dad would sit down and listen to me. It sounded like — the quality was horrible, but I was on the radio.
SHATNER: And did they indulge you?
RUSH: They gave me this for Christmas.
SHATNER: Isn’t that something. Let’s give little Rushie a prize which he’ll grow out of and go on to college. We know that he will.
RUSH: I had quit the Boy Scouts and the Cub Scouts. I was a quitter. I’d quit everything conformist I was supposed to do. This is the one thing I didn’t quit, radio, so they indulged me, “At least he’s showing some stick-to-itiveness.” 


Could the reason be that the FCC was altering the part 15 rules was an attempt to keep Rush off the air?..


But seriously folks.. What transmitters had the FCC been referring to?

Ok, getting back on track.. Within a midst of discussion about this ongoing quest, HB member TomTom made an interesting observation I'd not previously considered:

"Taking a different approach, is it possible the FCC found themselves besieged with complaints that involved various manufactured units that were being used by individuals who had connected an illegally-long antenna or ground, or had installed an external matching network to boost efficiency?
True, this modification would have had nothing to do with the manufacturer, but supposing this didn't immediately filter back to the Commissioners, who assumed the longer distances being achieved resulted from the greater efficiency of the transistorized circuitry. If this were the case, their concerns may have been eased once more complete information became available... 

...so it's possible a resurgence of the popularity of unlicensed AM transmitters had the FCC concerned, rather than it being a single product that caught their attention. Their worry seems to have been the increasing number of units in use, which would mean more complaints and more requests for leniency."

For a moment that sounded quiet plausible; after all, the docket did actually say "manufactures are taking advantage.." plural.. hmmm... Also it could explain why they had backed off from making the proposed rule change.. hmmm again... Although I did continue to ponder that scenario further, it still somehow just didn't click right with what the FCCs expressed concerns had been. The docket seemed to have an air of reference to something more specific, so I continued the quest on what transmitters might have created the problem...

The late 60s did provide some other possibilities, for example the Graymark transmitters appeared to have been the most popular and plentiful and had been used by schools and hobbyist alike:


Graymark 505 Broadcast Transmitter
Industrial Arts & Vocational Education, 1968 Vol. 57 Page 144:
"transmitter project From Graymark Enterprises, Inc., an easy-to-construct effective teaching aid, the Greymark 505 Broadcast Band Transmitter. Designed as a modulated unit (FCC 15.204), the transmitter will broadcast through any AM radio. Simply operated, it is only necessary for the operator to plug in a microphone or a crystal tuner to be "on the air." Construction provides the ..."
https://books.google.com/books?id=BQciAQAAMAAJ&q=fcc+%2215.204%22&dq=fcc+%2215.204%22&hl=en&sa=X&ved=0ahUKEwjXm9n4g7TSAhXEOSYKHd6MAyIQ6AEIHDAA

Graymark 515 Transmitter
 The Graymark 515 was also popular during the late 1960's, it was another of their tube type transmitter models. The schematic and layout for this unit is available at:  https://www.smecc.org/graymark_transmiter.htm

Graymark 533 SS Transmitter
 Later the Graymark 533 was a solid-state follow-up to their tube transmitter models. But these models were manufactured in 1977, and too late to be a candidate to consider.
Here's a few pages of original manual from a screen grab: https://part15lab.blogspot.com/2014/04/blog-post.html .  


But I still didn't think any of these 1960s transmitters could have been the problem. Besides the dates not matching up, all of them were just kits, plus they were manufactured under 15.204 (or 15.209 today) which further rules them out as the culprits since ground leads would not have been an issue...

So I continued digging around..


Well, my searches often take me on detours, which is seldom good a good thing, but this particular detour looked like it might prove fruitful. Evidently there was something else going on at the FCC during that same time, and I had a sneaking suspicion it was directly related..
This might very well be a key..

Yes, my search had been extensive, everywhere, using every key word or phrase I could muster which might render up results corresponding with the time frame of the early 1970s.. and eventually landed where I didn't expect to go; that being into the world of Federal Highway Advisory Radio System...
Another wild goose chase you say?
Well it would seem,
but this goose laid a golden egg...

In 1971, research had began and ultimately led to the FCC establishing TIS in 1977. As described in the "Highway Advisory Radio Operational Site Survey and Broadcast Equipment Guide" (1979) by the Federal Highway Administration Offices of Research and Development Traffic Systems Division,(this same info is also available in later highway documentations as well) a historic overview of what was going on with TIS in the early 1970s is provided: 
 

"The current Federal Communications Commission (FCC) Rules and Regulations (FCC, Part 90) covering the TIS were initiated by the Federal Highway Administration (FHWA) and other interested Government agencies in the early 1970's...  
...This resulted in the July 1975 FCC proposed rulemaking, Docket 20509, that would establish a TIS. Under this docket, HAR stations became recognized as TIS by the FCC. ...
...In June 1977, the FCC adopted a revised version of Docket 20509. Prior to this rulemaking, HAR operated either within the limited power requirements of part 15, section 15.113 (monopole antennas) and section 15.111 (cable antennas),.."

Holy Crap!!

I didn't know much about licensed TIS, but certainly didn't know prior to 1977 all TIS stations operated under part 15..
That was a shocking revelation!


Of course this lead me to look deeper into the creation of TIS/HAR..

The FCC calls it TIS -Travelers Information System, and the Federal Highway Department calls it HAR -Highway Advisory Radio - both terminologies are correct and mean exactly the same thing.

Actually not all TIS/HAR stations were part 15 prior to 1977.. There had been at least three installs through the years which had operated at higher power under temporary licenses. It wasn't until 1971 that the Federal Highway Departments had regularly began the practice of radio broadcasting to motorist, and the method they employed was Part 15AM, and they continued as such until 1977 when official TIS came in to creation. A brief overview is described in the following excerpt:

(You can read further discussion about this at https://www.hobbybroadcaster.net/community/index.php?topic=5688 )

So then, revelation #1 was that the original Travelers Information Systems (TIS) was an unlicensed broadcast operation under Part 15 regulations, and that the more powerful licensed TIS as we know today did not even exist until 1977.


Another revelation occurred to coincide with that find; As mentioned, an ongoing discussion concerning this "mysterious transmitter quest" was consistently underway as my search went along - especially at hobbybroadcaster.net, and one day while browsing through past unread topics I fell across an old post from back in 2013 which included pictures of two part 15 transmitters manufactured in the early 70s, of which almost no information was available. Could these be the transmitters I'd been searching for?:
The DTI and TSI transmitters, the oldest part 15 AM whip and mast transmitters known to exist:
 https://www.hobbybroadcaster.net/community/index.php?topic=2175.0


From 1973 mystery transmitter
DTI 71A by Info Systems
DTI Model 71A
Serial # 043-96 by Info Systems; it's accompanying paperwork says this particular transmitter was manufactured 5-2-1973 and operates under FCC Part 15.204

Early 1970s mystery transmitter
TSI 71A-T Technical Systems Inc


 
TSI Model 71A-T
Model 30-1-2 71A-T
Serial # 043-126
Technical Systems Inc.
Bozeman Montana 
 


From 1996  FCC: DPD624TA100
LPB AM-2000 by Ultra Sensors Inc
.

Both transmitters, though different companies, have similar model and serial numbers, they're also similar in appearance. Some pointed out they looked much like the LPB AM-2000 (aka TS-100 Trans-AM) transmitters, which came out in the mid 1990's... But the above extremely rare transmitters were from over 20 years prior, and their history is unknown.
 For larger more detailed pictures of the DTI and TSI xmtrs plus some schematics visit the following HB thread:
 hobbybroadcaster.net/community/index.php?topic=2175.0

Oh yeah, here I should point out before I go on; Somewhere along the way I also experienced yet a third revelation!..

All during this quest, as mentioned previously in this post, and as I had also brought up numerous times in the forums; For months I had been dismissing transmitter after transmitter, including even the DTI and TSI models above as

not qualified to be a potential culprit to the FCC's concerns since they were manufactured under 15.204 - the equivalent of 15.209 today.. and nobody caught the discrepancy...

I had started out with a short circuit, a brain fart, a miss-crossed reference, and continued on half cocked with it for months, and it might actually be fortunate that it was, otherwise I may not have come this far and discovered what was to come.

Let's review the numbers as explained in the History of Part 15 post:
1938 - was the creation of Part 15 and was known as 25.02.
1939 - renumbered to 2.102.
1948 - then renumbered 15.02.
1955 - renumbered again  to 15.7.
1956 - a 200mw input limit for 15.7 was proposed, but 100mw was ruled.
1957 - 15.7 became 15.202, and the alternate rule 15.204 was created.
1974 - rules renumbered to 15.111 and 15.113, and the "ground lead" added.
1976 - proposed to disallow alternate rule for manufactured units, but did not.
1989 - renumbered to 15.209 and 15.219, and a new rule 15.221 for campuses.
1990 - 15.221 modified for carrier current to operate under alternative limits.
There have been no changes since.

You see? I had been wrong from the start. Somehow I had the rule numbers crossed all along!; 15.204 was never what 15.209 is today, 15.204 was the original created alternative rule equivalent to what the 15.219 rule is now!

If I had realized that to be the case, I might have simply chalked up the Graymark line of transmitters to be the incitement for the rule change, and never bothered to go forth discovering that TIS originated under Part 15, nor find out those 1970's Part 15 whip and mast transmitters existed.

I guess that had been a wise goose which I chased all the way down through that particular alley.

So thanks to the gooses golden egg and some clumsy footwork, I finally had two excellent leads to work with..
1. It appears obvious that the manufactured Part 15 transmitters the FCC had been concerned about in the 1974 must have been those which the Highway Departments began utilizing in 1971 for Highway Advisory Radio..

2. The Highway Departments transmitters probably were the above early 1970s DTI and TSI 71 transmitters (it also seems likely that the "model 71" refers to the year which manufacturing had began)..

Now just to confirm those theories...

Finally this search is nearly over!..

I continued taking a closer look at early TIS/HAR systems and their background...


FCC-77-414A1 from Jun 17, 1975 is a very interesting read, it is the official proposal to create a new TIS classification. From what I gather from an initial read; numerous TIS stations during the time of this 1975 proposal were already operating, some were of the under experimental licenses and others operating under Part 15.
There was a great amount of resistance to establishing a TIS classification, a lot of broadcasting organizations were strongly opposed. It details many like the NAB and others arguments against enacting this proposal, and concludes with a letter from a Commissioner Quells, who also expressed his view against it. It's a 21 page document: https://apps.fcc.gov/edocs_public/attachmatch/FCC-77-414A1.pdf

The above along with numerous other TIS documentation also indirectly illustrated the similarities and differences between Part 15 and TIS:


~. Part 15 is actually a official option available for the classification of TIS. The biggest difference is that more powerful TIS stations requires licensing, whereas the Part 15 option does not.

~. TIS stations are generally portable self contained outdoor units, same goes for most Certified Part 15 units.

~. Both have power and antenna system length limitations, with TIS a 10w and 30ft (I think), and Part 15 at .01w and 10ft.

~. Both Part 15 and TIS stations are operated only on a sufferance basis, in that they may not cause interference, and must accept any interference. If interference is  caused then operations must cease immediately until the problem is resolved.

~. TIS stations generally have a range of 3 to 5 miles. A certified Part 15 station generally have a range of 1/4 to a mile.

~. The greatest use of TIS stations has always been by the Department of the Interior (Parks and Recreation and Forestry Services). The same goes for Part 15 broadcasting, the greatest use of it has always been by the parks and recreational entities. 


Ok, Ok, Ok.. Getting back to those 1970's DTI and TSI Part 15 transmitters..
Searches on the model numbers weren't turning up anything, but I was turning up a few results using googles advance search for "Info Systems Inc.".. unfortunately they were only snippets.. but very intriguing snippets:

Three snippets from a 1971 National Parks and Recreation publication providing pricing:
 
 
TEXT SNIPPET: More information on the Info Systems transmitters can be obtained by contacting Terry Fox at the company, PO Box 1252, Bozcman, Montana 59715 [406-587-0451]. lntemational Telephone and Telegraph C0rp., Industrial Products Division, ...
 

And these 4 snippets from some 1972 Highway Beautification hearing transcripts:

 
TEXT SNIPPET: How far do the transmitters transmit? MR. MATSON. ... Is that the sort of transmitter that doesn't interfere with anything? MR. MATSON. Yes. ... We feel the INFO Systems concept creates yet another media through the element of localized radio.
 



 


Under these snippets was a link that said: "Where's the rest of this book", which took me to a page explaining that the publication had not been reviewed for full view release, and provided an option to request that it be released...  So I submitted a request to Google books to release more of the two publications above. I didn't know what to expect, nor if it would cost anything because I had never tried it before.. Almost imeadiatly I received the following automated email response:
-------------
Thank you for contacting us. This book was provided to us via the Library Project. There are many reasons why a Library Project book might not be fully visible. For books that enter Google Books through the Library Project, what you see depends on the book's copyright status. For more information on why some books aren't available in full-text, please visit our help center.

We have begun the review process for this book to determine if we can make it available for you to view in full. Please be aware that it may take some time to fully determine the correct legal status. Additionally, copyright law varies by country so please let us know if you are outside of The United States.

I appreciate your patience with this request. I will let you know when we have further information to share.

Sincerely,

Will
 The Google Books Team

------------------

It took less than a week for them to release both publications and make it fully viewable on the web, and no, it didn't cost me a cent!

Now this is when it got real interesting: HEARINGS Before The COMMISSION ON HIGHWAYS BEAUTIFICATION April 17, 1972  There two notable hearings on pages 547 through 555 where the FCC meets with the Highway Department, and the other is on pages 575 to 586 when the 'Info Systems' company demonstrates their part 15 transmitter, You can download and read it in it's entirety (which I suggest you do), but I've selected the highlights in these excerpts that I found most interesting to display here:

First excerpts from the FCC meeting:


....

....




 
And from a later hearing here are excerpts from the Info System Inc. meeting:
 
 









~~~~~~~~ . ~~~~~~~~~~~
 
 
Ok, that's it.. or at least that's where this post draft left off, there's actually more to the highway department story which I'll probably address later. But the highway department use was not where these Info Systems transmitters had actually first been utilized.. They actually pioneered in Yellowstone beginning in 1968, and it's successful and highly publicized use there and by other parks is what caught the Highway Departments attention to begin with.
To me, the Yellowstone story is the most fascinating one, and is where the first ever outdoor whip and mast part 15 transmitters ever used, and set the stage for our certified part 15 transmitters today.
I'll be posting that story soon in an upcoming post.



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