Press Releases From Ken

February 4, 10 - FCC and KENC Radio

Tuesday February 2, we installed the ground filter that Hamilton Transmitters manufactured. This allows for a safe electrical ground and lightning strikes but does not allow RF to the tower. This allows us to keep our Hamilton transmitter on a 40 foot tower without breaking the 3 meter rule that the FCC mandates for low power AM Radio stations under 15.219 of the FCC code. We installed the filter and retuned. We did get some of our range back.

I sent photos of the filter installed and the retuning so the meter readings could be easily read and interpreted, to the inspector in Vancouver Washington. He emailed that he had received them but wanted to come out the next day and have me provide him with a lift truck so he could disconnect the filter and do a field strength meter reading of the transmitter without it and a comparative one with it on. I could not get a lift truck to accommodate his schedule. I notified Keith Hamilton of the intended inspection and he replied that the only way to do this was to have him check the FS readings on the ground at a distance, then remove the filter, retune the transmitter, do another FS meter reading and get a comparable reading. The inspector did not want to do it that way, so Keith suggested that the FCC in Washington give us a written sheet with instructions on how the survey or inspection is to proceed, but with Keith's suggested method. I got a call today from Inspector Bingh and he is waiting on instructions from the FCC's OET department and a written procedure. We should be ready for a lift truck and a re-inspection sometime in early March.

We have our fingers crossed that this will finally settle the issue of our NOUO complaint and if approved should set precedent for all part 15 low power AM stations. I'll post the results here when we have them.. Ken Cartwright

December 18, 09 - How the FCC action began

Here is what I think happened.. I now know of 2 engineers in Portland (NAB members) that have an issue (personal) with LPAM. They put a bug in the inspectors ear.. He in turn was referred to an article about the station in the Oregonian newspaper. I feel that he was going to come down here, scare the crap out of me, get me to shut down by invoking 15.209 and look good to both the troublemakers and his bosses.. When I asked him about the ground rule, I said, "so, if i bring the transmitter/antenna down off the 40' tower and keep it within 3 feet of the ground, that would be OK?" He said "Yes". Or, I said, "If I left it up on the tower and cut the ground off and retuned, that would be OK?" He thought about that for a minute and said "Yes". I suspected that he was thinking that if I did that, I would get no range, which was his issue.. So I called the reporter at the Oregonian that had done the original story that the inspector said had gotten his attention about us, and told her about the visit from the FCC... She couldn't believe that he would come down here 2 days after my wedding to put the hammer down, and said she would do a follow up story and called back for more information. When she called the FCC in DC, and told them what she was doing, she mentioned the advice about the disconnect on the ground as an option that I chose.

I feel strongly that this action is what prompted the change in the rule. Add in lots of letter writing, many calls to Oregon Senator Ron Wyden, his staff member Fritz Graham a strong supporter of our station and community. One of the first things out of the mouths of FCC DC staff when he inquired about this citation was, "We are very familiar with the KENC issue and we are concerned about the advice given to him about disconnecting his ground. If there was a lightning strike on the antenna, and equipment, buildings or god forbid a human injury, there could be problems". We knew then that the issue of the ground would bring the whole issue to the surface.

As for my attitude towards the inspector on all three visits: I was first surprised, then frustrated and then argumenative. He was trying to get me to comply with all of 15 part C, including 15.209, which covers cordless telephones and remote control devices. I told him I disagreed with his interpretation and would not accept it... He insisted it was the law and I asked if he had made any other part 15'ers comply with this rule? He said no... I insisted all along that I was complying completely with part 15.219 of which the Hamilton's were certified under. On his second visit, he chose to read me the entire section 15C, said he had done another field strength meter reading, and though it was much less than the first one, it still didn't comply to 14.8 Micro Volts at 30 meters. I insisted that rule did not come under part 15.219... One his third visit, he insisted that I hear him read me all of section 15.209 again and then asked me if I understood that section. I told him I heard him loud and clear but did not agree with him...

By this time Senator Wyden's staff had been making many calls to the FCC as well as Keith Hamilton on our and others behalf... the final communication I had with the inspector was by phone when he called me to say," Based on advise from their legal consul, he would suggest that I reconnect my ground, follow the three meter rule in doing so, retune the transmitter to 100 Milliwatts, send him a statement both by email and ground mail verifying that I had done that and they would dismiss the citation." There was no "Thank you, I'm sorry, or we apologize" and that's OK with me too. Just that I am free to transmit has I had been doing before the first visit.. He also added that the field strength meter ruling would not apply to part 15.219 transmitters...

That's it, in a nut shell... Keith tells me he has a filter system in the works that should take care of the grounding. As soon as I have it, I'll go back up the tower, install it and the ground, retune and go forward. I am currently operating the station with three transmitters. The one transmitter that was the issue has been running without the ground, and it did affect the range without the ground but still get good range... any other questions, you can reach me offline at kenc@wvi.com ... Ken Cartwright
PS. Thanks to all you folks for your prayers and support... let's get back to our radio stations...

Ken Cartwright

December 16, 09 - FCC notice about KENC

Ken,

I spoke with the FCC today. They said that when they took the 15.209 vs. 15 219 issue to their office of engineering and etc, they found that indeed your are correct that not all of part 15 applied and that it is acceptable to have a 3 meter ground an output of 100 MW.

And this has to be applied to al transmitters.

Take care,
Fritz Graham
Senator Ron Wyden
707 13th St., SE Suite 285
Salem, Oregon 97301
503-589-4555 fax: 503-589-4749

December 15, 09 - FCC Backs Off

I received an early Christmas gift yesterday.. The FCC inspector that caused me so much grief the past few months, called me and told me that based on advise from legal consul for the FCC, If I would send them an affidavit certifying that our transmitters were tuned to 100 milliwatts and our ground and antenna were of legal attachment (which it is and was) they would dismiss this action against KENC... It's because many of you have written to both the FCC and senator Wyden that this action has happened... I need to make a couple of little changes to our primary transmitter here at the shop when the weather gets better, but basically we're back where we started from... they also will not hold us to comply with the silly field strength meter rule of part 15.209... No Field strength meter ruling means my range for the station can be what is as long as I comply with the 100 Milliwatt part, which we have always done...

I guess the civic lesson here is when you believe that you are right and fight for it, you will prevail.. This is a precedent setting case for all low power AM stations in the United states. I know that the pressure we put on the FCC with our reactions to this abuse of power had everything to do with it. My heartfelt thanks to you all and Merry Christmas.. Ken Cartwright