[Lowfer] 'CO' medfer will continue on 1704.8

[lowfer@mailman.qth.net]

Hi Eric,
   Thanks Eric, but be prepared to turn off your receiver if you want to
be a purist.  No Medfer or Lowfer stations that I am aware comly with Part
15.  I  prefer to obey law and regulations, but more than that, I prefer
to be honest.  Any honest interpretation of regulation 15 makes it clear
that for a medfer station may use 3 meters of wire any way you want to,
but 3 meters period.  For a lowfer station it would be 15 meters.  Here's
my reply to another who was critical of my transmission line to the
antenna-



> Hi ,
>  I have to take exception to what you say below.  Before writing you,
> I've reread Part 15 Subpart C of the Code of Federal Regulations,
> especially Section 15.217 and 15.219 which definitely applies and
> Section  15.209 which I think applies.  I will not comment on section
> 15.209 except  to say that any Lowfer or Medfer system that can be
> received 25 miles or  more away is most probably in violation.
> After rereading Part 15, it seems very clear that my 45 meter
> transmission line is the least significant violation.  Section 15.219
> b  (which applies to the Medfer band antennas) states that "the total
> legth  of the transmission line, antenna, and ground lead (if any)
> shall not  exceed 3 meters."  My ground lead (ie. radials) are approx
> 600 meters; my  loading coil more than 10 meters, my tophat about 20
> meters.  Only the  vertical part of my antenna is compliant.  Also my
> power level is probably  compliant with 60 mw output- although I did
> not measure the total power  input... (section 15.217 a).
> No Medfer or Lowfer station that I have heard of is anywhere close to
> being compliant with the Part 15 Code of Federal Regulations.
> Ironically,  loops, which have been most often been criticized as
> noncompliant, come  closest to compliance.  They are in violation by
> only a factor of four  (ie. 12 meters for medfer and 60 meters for
> lowfer).  My vertical system  is in violation by a factor of 210 with
> the amplifier at the base of the  antenna and by a factor of 215 with
> my exciter in the house, using the  transmission line.  I think the
> latter is representative of any of the  efficient Lowfer or Medfer
> antenna systems that I have read about.

If anyone should think that the Park 15 rules allow wiggle room, the
following makes it perfectly clear that Part 15 means what it says-

> ___________________________________

In the August 2, 2000 edition of Radio World magazine, there was an
interesting response from the   FCC to a letter questioning the legality of
some equipment being sold that supposedly conforms to the 100 mw/3 meter
requirements of Part 15 for unlicensed operation in the AM broadcast band.
It may be of interest to the LF community. The original letter was from
Robert Ladd, of WNRR(FM) in Bellevue, Ohio. Here is the response:
------------------------------------------------------------
Mr. Ladd:

Your inquiry was referred to me for reply. Before responding, I ran your
question by our lab people who are responsible for issuing the required
grant of certification on the AM transmitters before they can be marketed
or
used.

Under Section 15.219 of our rules, the maximum power is limited to 100 mW
input to the final RF stage and the total length of the antenna plus the
connecting lead plus the ground lead may not exceed three meters.

The antenna is part of the package that is certified. If a loading coil is
used in the antenna design, we count the electrical length of the coil
toward the three meters. In other words, this rule is designed to keep the
practical transmission range no greater than about 250 feet.

If the installer/user places the transmitter atop a metal pole or other
conducting structure and grounds the transmitter to that structure, the
height of that structure also is counted toward the three meters maximum
length.

You did not mention the FCC ID number on the transmitter, so I am not able
to identify the responsible party. If you can supply that number to us, I
would be happy to provide it to our laboratory staff. If no FCC ID number
exists, the equipment may not be legally imported, sold or used.

Let me know if you need additional information on this issue.

John A. Reed, Senior Engineer, Technical Rules Branch
FCC Office of Engineering and Technology, Washington.

>
>
>>
> <<Doug...
Most MedFERs seem to try pretty hard to meet the rules, with the
>> possible exception of the so-called "free broadcasters."  Some of them
>> believe that because they're using certified commercial units, the
>> transmission line rule doesn't apply, and their "ground connections"
>> can be dozens or hundreds of feet long.  A few of them even *claim* to
>> have been visited by FCC inspectors and OKed.>>



> EXCELLENT work, Doug.  Glad to hear you are going to do this!  I was
> *very* excited to see you get those signal reports -- gave me hope
> until  you reported that you were outside the part-15 limits :(  My
> receiver was  just getting warmed up real well when you told us that.
>
> Great job and good luck!!  I'll listen for it when you get it going
> again.
>
> 73
> Eric