The Unsorted BBS Collection/thegreatunsorted.tar/thegreatunsorted/texts/pirate_radio/430

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            Articles in this issue include:

An interesting pirate station and Re: AM Broadcast Ques    (Harold    Hallikainen)

------------------------------
Subject: An interesting pirate station and Re: AM Broadcast Question
From: [e-mail] (Harold Hallikainen)
Organization: California Polytechnic State University, San Luis Obispo

In article <2a845u$[e-mail]> [e-mail] (Thomas A. Hahn) writes:
>    I am looking for any information as to why we would not be allowed
>to broadcast over-the-air instead of through carrier-current.  So far, I have
>not found any information regarding our problem.  Of course, we would love
>to go FM but that is way out of reach for the time being.  AM broadcast would
>solve many of our problems because we are a commercial station that is NOT
>funded by the University.  Therefore, we need an improved signal to reach our
>intended audience.
>
>    Any information at all on this topic will be of great help!  Is there
>a reason we cannot broadcast to the campus instead of re-wiring the old carrier-
>current system in place now?


    Part 15 of the FCC rules makes a special provision allowing
    broadcasting on AM on educational campuses with no limitation on
    radiated field or power IF the station does not cause interference to
    any licensed station (in the protected contour of that station, as I
    recall) AND the radiated field at the CAMPUS BOUNDARY meets the normal
    intentional radiator limits of part 15.  It would appear that this can
    provide good coverage of a campus.  I wrote a couple Radio World
    articles that discuss this.  They are reprinted below.

                             Insight On Rules #37

                                7 November 1990


     All Things Considered broadcast a story about "Zoom Black
Magic Radio" on 6 October.  This story gave considerable detail
on the operation of a 0.4 watt unlicensed FM station.  Unlicensed
pirate radio has quite a mistique.  A licensed Los Angeles FM
station uses the pirate radio image to differentiate itself from
the competition.  While in London in 1985, I had the opportunity
to hear Laser Radio and Radio Caroline, broadcasting from the
North Sea.  Even Tracy Ullman did a skit on pirate radio!
Reviewing the stack of information I recently received from the
FCC, I found an interesting unlicensed station in Hawaii.
     This "public radio" group appears to have done just about
everything right but get a station license.  The group was
incorporated in Delaware in 1987.  The group applied as a
501(c)(3) tax exempt organization with the IRS.  The tax exempt
purpose of the corporation was to "provide the public with
quality listening entertainment and information."  The area to be
served by the station was a "remote and sparsely populated
district on the island of Hawaii."  That area received no FM
signals.
     It appears that the station manager sent a letter to the FCC
in Hawaii regarding starting an FM station in 1986.  The letter
asks how to start a low power (under 100 watt) FM station.  In
its reply, the FCC Field Office said "Unfortunately, there are no
provisions in our rules to operate the kind of station you
propose."  Station licenses are only granted on allotted
channels.  One is free to petition the Commission to allocate a
channel to the community.  The letter also points out the minimum
operating schedule and minimum operating power requirements.
     Eventually, the station went on the air without the benefit
of a station license.  The equipment was purchased from a company
that advertised in Rolling Stone (another competitor for RW?).
It consisted of a stereo generator, an exciter, a ten watt power
amplifier and an omnidirectional antenna on a 20 foot pole.  The
equipment supplier catalog includes a disclaimer: "The plans &
kits in this catalog are offered for your information only.  You,
as the purchaser and user, assume all legal and financial
responsibility which results from the ultimate use of your
purchase."
     After about three years operation, a Hilo public relations
firm called the FCC to find out the "ownership situation" of the
station.  After the FCC could not find any record of the station,
the PR firm sent a copy of the station's "Station Profile", which
provided various details about the station (frequency, coveage,
format, operating schedule, etc.).
     The station was inspected by the FCC on 24 October 1989.  On
26 October, the FCC issued a Notice of Apparent Liability for
$750 for willful violation of the Communications Act of 1934 by
operating an unlicensed broadcast station.  The NAL also ordered
the station to cease and desist all operations immediately.
     On 30 October, the station advised the FCC that the station
was off the air and would remain so until it could obtain an NCE
license.  The station operator pointed out that the station
provided a public service, being the only receivable FM station
in the area.  Further, the station did not have the assets
required to pay the fine.  For these reasons, it was requested
the fine be reduced.
     On 9 November, the FCC phoned the station with a compromise:
turn in the transmitter.  The station operator said the other
board members (remember, this is a corporation) wanted to hold on
to the transmitter.  The FCC then suggested each of the six board
members pay $50 (reducing the fine from $750 to $300).  The
station operator said no, but he'd like to discuss it with the
other board members.  He also said he'd like a court hearing.
The FCC advised him that if he refused to pay, the forfeiture
would go to court for the full $750.
     On 13 November, the station operator said the board felt
they should not pay the $300.
     On 14 November, the FCC issued a forfeiture order for $750.
The order details why the fine was not reduced.  The FCC pointed
out that discontinuance of a violation after notification to
cease does not excuse the violation (in this case, unlicensed
transmissions).  Further, the FCC records showed that the
violation was done willfully, as the operator had full knowledge
that a radio license was required to legally broadcast (the FCC
still had the 1986 correspondence where the operator asked how to
get a license).
     The FCC dismissed the community service justification by
saying that the potential of unlicensed stations to cause
interference to other radio users, the undermining of the FCC
administrative procedures to properly obtain a license, and the
encouragement to other unlicensed operations far exceeds any
community benefits provided.
     The FCC stated the purpose of issuing a forfeiture is to
penalize in order to prevent future violations and to discourage
other potential violators.  If the violator could readily afford
the forfeiture, it would not serve its purpose.  In telephone
conversations, the FCC and the station operator were unable to
come to a compromise, and the station did not provide any
detailed financial information demonstrating that it could not
afford the $750 fine.
     On 24 November, the station sent financial information (a
bank statement) showing no account activity and an account
balance of $20.29.  Based on this, on 30 November, the FCC
reduced the fine to $100, payable in two installments.  The
second payment was made 17 February 1990, closing the case.
     So, what unlicensed radio broadcasting is allowed?  Many
people assume anything is permitted if the transmitter power is
under 100 mW.
     15.219 allows unlicensed operation between 510 KHz and 1706
KHz if the final amplifier input power is 100 mW or under
(excluding filament power) and the total of the antenna,
transmission line and ground lead lengths is 3 meters or less.
This is the current regulation that the old Knight Kit
transmitter I build in fourth grade operated under (it cost
$12.95, had 2 50C5s and a 12AX7).  That transmitter replaced the
old spark gap transmitter I'd built out of a toy buzzer.
     15.221 authorizes "carrier current" transmission on an
educationcal campus.  This section, along with the section
covering "tunnel radio" (real underground radio) pretty much put
the conducted and radiation limits at the campus or tunnel
boundary.  Inside the campus or tunnel, the owner is pretty much
free to do whatever, as long as it does not interfere with the
protected contour of a licensed station.
     15.239 covers unlicensed operation in the FM broadcast band.
Transmitters must be FCC certified.  The radiated field is
limited to 250 uV/meter, measured 3 meters from the radiator.
There is no 100 milliwatt exemption for operation in the FM band.
     So, it appears that unless you own a campus or a tunnel,
you're limited to use of that FCC certified "Mr. Microphone"
without a station license.  Next month we'll deal with licensed
broadcast stations (I promise!).  I'll look forward to your
comments.


_________________

Harold Hallikainen is president of Hallikainen and Friends, a
manufacturer of transmitter control and telemetry systems.  He
also teaches electronics at Cuesta College, San Luis Obispo.  He
can be reached at 805 541 0200.



                             Insight On Rules #43

                                  8 May 1991


     We've recently been discussing what a station chief operator
should do to insure compliance with the FCC and ANSI
specifications for human exposure to RF fields.  Last month I
suggested a report be prepared based on predicted and measured
fields.  This report would show what areas are safe for human
exposure for unlimited periods of time, those areas safe for
limited exposure times, and those areas where a transmitter power
reduction is required.  The report would contain sufficient
measurement and calculation detail to fully justify its
conclusions (such as, how much must the transmitter power be
reduced when a climber is a certain height on the tower).
     I received a call from Richard Tell of Richard Tell
Associates, Inc.  (phone [phone]).  His company specializes
in RF radiation consulting.  Prior to that, he spend 18 years
with the Environmental Protection Agency studying the potentially
hazardous effects of electromagnetic fields.  In the call, we
discussed "RF hot spots" and RF contact currents.  He also sent
me a copy of a paper on this subject from the NAB 1990
Engineering Conference Proceedings.
     The study of human exposure to RF fields appears to be a
very interesting and controversial subject.  The ANSI guideline
the FCC is currently using is being revised to include various
new ideas.  The FCC may or may not adopt the new specifications
(it'd appear that to adopt the new specifications, the FCC would
have to go through the notice of proposed rulemaking, comment and
report and order process, which can be slow).


Hot Spots & Contact Current

     Hot spots are small areas of high RF field in areas of much
lower RF fields.  They are generally caused by reradiation.  For
the NAB paper, Richard Tell measured hot spots generated by
reradiation from a mail box on a metal post, a metal window frame
and a guy wire.  In each case, the field close to the metal
object was substantially more than the "ambient" field.  "Surface
fields" were measured about 5 cm from the surface.  The "E
squared" and "H squared" fields were increased to 5.9 to 15.8
times ambient.  If these fields are above the ANSI limit, is
exposure to these fields allowed?


Ideal Transducers

     Ideally, a transducer or measurement instrument does not
affect or "load" the parameter being measured.  For example, an
ideal voltmeter draws no current, an ideal ammeter has no voltage
drop, an ideal pressure gauge introduces no volume displacement,
etc.  An ideal EM field meter does not change the field at the
point of measurement (which it might do, due to "loading").
However, when a person enters this area, the radiator is
substantially loaded, possibly decreasing the radiated field to
within the ANSI limits.  When the person actually touches the
radiator, the radiated field drops substantially, but a contact
current flows.  A limitation on contact current is being
considered for "hot spot" exposure, instead of specifying the
undisturbed field be measured some arbitrary distance from the
reradiator.


Wrist Currents

     Since mailboxes and window frames are generally touched by
hands, and the hand is connected to the remainder of the body by
a relatively small diameter wrist, it would appear that the
highest heat dissipation due to RF contact would be in the wrist.
Using the specific conductance of the various tissues in the
wrist and the density of those tissues, a total wrist current can
be determined to give a Specific Absorbtion Rate in watts per
kilogram of tissue.  The SAR can then be tied back to how much
temperature rise would be expected in the tissue due to the RF
current.  The current ANSI standard limits SAR to 0.4 watts per
kilogram for the whole body, but allows 8 watts per kilogram in
any one gram of tissue, allowing for varying fields, such as
those generated by a hand held radio transmitter.  Mr. Tell's
paper shows a contact current of 75.1 mA in the AM band and 87.3
mA in the FM band for an SAR of 8 watts per kilogram in the
wrist.  Further, since wrists seem to be able to survive elevated
temperatures (if not, I won't wash dishes any more!), an SAR of
20 watts per kilogram has been suggested.  This would limit AM
contact current to 119 mA and FM to 138 mA.


Lots of Study

     Mr. Tell's paper lists 19 references from a wide variety of
organizations and publications.  A lot of research is being
conducted in this field.  The current ANSI limits are based on
the heating effects of RF exposure.  There is also study being
conducted into other effects.  It might be interesting to see how
computed peak SARs (possibly at the tip of a finger) compare with
those expected by contact current as the finger approaches a
reradiating object.  The tip of the finger is very close to the
object, resulting in a potentially high field and high SAR, but
the reradiator is also "loaded" by the presence of the finger,
decreasing the generated field.  It would be interesting to see a
graph of peak SAR, SAR in the wrist and whole body SAR as a
function of the distance between the tip of the finger and the
reradiator.  The actual field at various places on the finger and
wrist would have to be measured to take into account the loading
as well as the attenuation due to distance from the radiator.
Does the peak SAR approach a limit as the finger approaches the
reradiator?  How does this peak SAR compare with that expected by
contact current (I squared R)?
     This is a very interesting field deserving additional study.
There may be a safety advantage to the proposed DAB and digital
HDTV systems, since they generally use lower power.


Unlicensed College Radio

     I got another call from a college FM station operating
without the benefit of a license.  Various intentional and
unintentional unlicensed radiators are discussed in part 15 of
the Rules. 15.211 and 15.221 are quite interesting.  15.211
allows any frequency or power to be used IN A TUNNEL, provided
any emissions escaping the tunnel meet the various specifications
of part 15.  These systems are allowed when the radiator and all
connecting wires are contained within the "tunnel, mine or other
structure that provides attenuation to the radiated signal due to
the presence of naturally surrounding earth and/or water."
     15.221 similarly allows educational institutions to use AM
frequencies on a noninterference basis with any power or radiated
field as long as the field meets the general limitations of part
15 at the campus boundary.
     Note that 15.221 permits such operation on AM only.  It
appears that operation on FM would only be permitted at an
"underground university".
     We've always assumed that radio required federal regulation
because it does not "stop at property lines".  These two
sections, however, seem to define the word "stop" and, with some
extension, could allow radio use on any frequency and power as
long as the field at all points on the property line (and perhaps
a certain distance above the property) met certain field
limitations.  Instead of setting a limitation on the field 30
meters from some box that radiates, the field would be set 30
meters from the property line (the property itself becomes a
large "box").  I've heard of this reasoning being used to
transmit an FM signal in a concrete sports complex.  Radiation
outside the complex was well below the part 15 limits.
     But, as I read the rules, unlicensed operation in the FM
band is limited to 250 microvolts per meter measured at 3 meters
(15.239(b)).


Continuing Education

     Barry Mishkind recently wrote in RW about continuing
education.  I'd like to suggest RW readers be learners.  Too
often people cram through four years of college, graduate, and
never return to an intense learning environment (of course, we
hope we learn on the job and through life in general).  I'd like
to suggest taking one class a semester or quarter in any field of
interest at a local college or university (conflict of interest
warning:  I teach at a community college).  The flexible hours of
contract engineers often allow a few hours a week to be set aside
for continuing education.  Over the years, I've taken many
business and computer language courses.  I am now relearning
calculus (after a 20 year break).  It's much more interesting
when you don't have to deal with lots of other classes, or,
perhaps, when you're a bit older.  Many colleges also offer
tutoring to students.  Working as a tutor (either volunteer or
minimal wage) is a very good way of reviewing subjects.  I'm
currently tutoring algebra and calculus, Basic, Cobol, assembly
and C languages, and accounting.  The students and the
instructors provide a very stimulating environment.  Give it a
try!

[Moderator's Note:  With all of the talk about micro radio and
the factor of interference, why is it that the Canadian government has
seen fit to license many 1 watt community stations throughout the
country?  The above example is testimony to the fact that the FCC is
less interested in interference as they are in administering a set of
inflexible rules designed to keep 'non-standard' broadcasting off the
<so-called> public airwaves.  Clearly, this 10 watt station in Hawaii
posed no threat to anyone, since there were NO other signals receivable there
on FM.  Yet, they were fined and ordered off-the-air.  Of course, if
they were a mega-corporate entity which wished to place a 50kw
repeater of some Satellite format there, I am sure they would have no
problem.  C'mon people, Geesh...   Great article Harold.  Can't wait
for your next installment.   Bill]

 _________________

Harold Hallikainen is president of Hallikainen and Friends, a
manufacturer of transmitter control and telemetry systems.  He
also teaches electronics at Cuesta College, San Luis Obispo.  He
can be reached at 805 541 0200.  He can also be reached on  Internet
at [e-mail] or [e-mail]



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