Monday, July 31, 2017

Part 15 in 1960

I was born in 1960, not that it has anything to do with anything, but here's a look at what Part 15 was doing back then. It's nothing exciting (except maybe the race track transmitters thing), but it is an interesting read in a historic sense. The following are a few excerpts from: https://www.fcc.gov/reports-research/reports/annual-reports-congress/26th-annual-report-congress-1960

26th ANNUAL REPORT
FEDERAL COMMUNICATIONS COMMISSION
FOR THE FISCAL YEAR 1960
(With notation or subsequent important developments)

INVESTIGATION

Low Power Communication Devices
Local interference problems are aggravated by persons who operate low-power communication devices which exceed the radiation limits prescribed in part 15 of the Commission's rules. Unlicensed use of wireless microphones, phonograph oscillators, electronic "baby sitters," home intercommunication systems, remote control of model airplanes, etc., is permitted on certain frequencies but under strict limitations as to power, antenna length and radiation. But many of these operations exceed the limits and interfere with licensed radio services. This is especially true of juveniles using mail order kits of home-assembled equipment to "broadcast" voice and records to a neighborhood. Besides taking action against violators, the Commission continues to seek the cooperation of manufacturers, sellers, and users of such devices to see that they ate certified as meeting technical requirements.

Carrier Current Broadcast Systems
There is continued interest on the part of colleges, churches, and individuals to establish carrier current broadcast systems or to increase the power of existing systems. However, to avoid interference to licensed broadcast stations, section 15.7 of the rules limits radiation so that associated receivers must either be connected directly to the distribution cable or in close proximity. Sampling investigations over the years have consistently indicated a tendency to exceed the allowable radiation limits. Operators have been warned of the consequences that could result from excessive radiation, but there is particular difficulty with colleges because of changing student bodies in charge of so-called "campus" broadcast systems. Lack of personnel has made it impossible to investigate the carrier current systems at all colleges. The Commission is studying proposals in docket 9288 for possible amendments to the existing regulations.

Unlicensed Transmissions at Race Tracks
The apprehension of operators of illegal transmitters at race tracks for "beating the bookies" is becoming increasingly difficult because "f the trend toward miniaturizing of transmitters and the fact that a concealed low-power transmitter may send a hundred feet or so to a confederate. Track officials cooperate by advising FCC investigates the most opportune times to cover the raee tracks when illegal radio operation is suspected.

Incidental radiation devices
The part 15 regulations were originally promulgated in 1938 as the low power rules to regulate the use of certain radio-operated control devices. Their coverage was extended through the years to include other devices such as carrier current systems and receiver radiation. Today these rules embrace all devices which generate radio-frequency energy either deliberately, as in receiver oscillators, or fortuitously, as in automobile ignition systems.... FCC regulations merely require that these devices be operated so that no interference is caused. If interference results, the operator is required to take corrective action..
Due to the increasing number of foreign receivers being imported, the Commission, through the Department of State, notifies foreign manufacturers of its receiver regulations, advising them of the need to measure radiation and certify receivers intended to be used in this country. This program is bearing fruit.... Being unable to proceed against the manufacturer, the Commission finds itself in the difficult position of trying to control interference from devices in actual use rather than at the place of manufacture.

Radio Frequency Bandwidth and Spectrum Utilization
The Commission continues to encourage the nse of all available techniques for efficient spectrum utilization. Such techniqnes include improved frequency stability, single sideband transmission, reduction of spurious emissions and use of modulation systems giving improved spectrum efficiency. Regulatory progress in this matter includes rule changes to provide more stringent requirements for reduction of spurious emissions in the aural broadcast services...

Type Acceptance of Transmitters
The Commission's type-acceptance program is designed to evaluate the technical adequacy of transmitters used in most of the radio services. Type acceptance is based upon evaluation of descriptive and measurement data usually furnished by the manufacturer, or occasionally by the applicant for license. If such data show that the transmitter is capable of meeting the technical specifications of the rules governing the class of station for which the transmitter is designed, type acceptance is granted. If circumstances warrant, the Commission may require that type-accepted equipment be submitted to its laboratory for inspection and test to substantiate its capability of compliance with applicable rules. The Commission's type-acceptance data and other information on equipment filed for application reference purposes are not open to the public but are useful to the Commission in determining the technical characteristics and capability of transmitters. Applicants who have once filed such data can iudicate on subsequent applications that the infonnation is already "on file."

Studies of New Systems and Devices
...There were continued studies of multiplex and stereophonic systems for AM and FM broadcasting. Tests of several FM receivers of recent manufacture indicated no significant improvements which might allow the use of closer spacings between FM broadcast stations using the same or nearby channels. The laboratory participated in a field survey to evaluate the possibilities of use of an on-channel booster to fill in areas of deficient TV signal reception, in an experimental operation by stationWTEN,Channel 10, atAlbany,N.Y.

Sunday, March 26, 2017

A Couple More Cool Free Gadgets

As you've probably noticed by now, I tend to focus a lot on freeware offerings, and although an apparent disdain exist for the Windows operating system, which is essentially the only one I use, here's a couple more of the same...

This first one is an offering from the UK based website RadioTools. besides sporting a handsome clock interface it also is acts a functional indicator display for any number of alerts you decide to implement into it (examples described below).
In my opinion, this would be best used wall mounted, maybe dedicate an old pc you might have laying around for it.. Of course I there's nothing wrong with it being used on the same pc as your automation operates on (I assume most do) and maximizing its widow when you're not on the pc.
Studio Clock for Windows
A studio clock application for use around your station including a customisable logo, studio name, station strapline or RadioText banners, automatic status indicators for silence and overload which can be triggered from the PC sound card and many other on-screen alerts and alarms (such as telephone, door, Major News Story and RDS Traffic active) which can be set and reset via a network connection. The screen includes an updatable text field that can be used to show the station's RadioText or "now playing" details and various other indicators that were originally designed for our in-house broadcast management platform. This application can be used with both traditional 4:3 monitors (1024x768 screen resolution) and widescreen 16:9 monitors (1280x768) by changing a setting in the configuration file and can run as a "stand-alone" clock or as part of a management platform. We recommend installing TimeSyncTool on the same PC rather than Windows built in network time client, to ensure the exact time is always maintained.
Get your for free now:
http://www.radiotools.uk/index.html



Another free studio gadget:
VUMeter
I happen to like analog VU meters - particularly those having vintage appearance, there are numerous vst plugin offering this which are more attractive, but this one functions as a stand alone, run on even the oldest Windows pc, non buggy and doesn't use up resources. It's pretty basic, function accurately. I can't give comparison since this is about the only software analog meter I've ever used (from time to time) with any kind of consistency, but I always liked it and it can be useful. And of course it's free.
Softronic Review:
VUMETER is an analog audio meter old - fashioned used to visually monitor sound levels of your PC. VUMETER is an application which measures all the sounds that are occurring on the PC with what is useful regardless of the player used. The options of VUMeter three: the option "always visible", the adjustment of the sensitivity scale and the selection of the input device. To access the options you must right click on the program. This vumeter is monophonic and stereo. measure the output signals, not the input signals.


http://www.vuplayer.com
















Friday, March 24, 2017

ESSENTIAL PART 15 TIP

In the midst of discussion the discussion discussed detoured on how to best attain AM coverage range.. I'm not going to link you to the Part15.us forum thread because it's besides the point, except for a single line that really stood out to me and it is indeed the best Part 15 piece of advice you'll ever get...




ALLERT!: IMPORTANT!: ESSENTIAL PART 15 TIP:
"To reach your target area with a part 15 AM system you must locate the transmitter and antenna at the target location."
ESSENTIAL PART 15 TIP IS QUOTE OF CARL BLAIR




That quote illustrates the secret of a successful Part 15 installation. If you can do that, then you've got it made. "Think small, cause that's all you got, and once you perfect it, it might be a lot." -- Doctor Seuss ...Ok, the doctor didn't say that but he would have if he were here.

Tuesday, March 21, 2017

Thanks Philco for Part 15 Broadcasting

Here we look at the original creation of the rules in 1938, which in it's inception was not #15 but #24. The law was created to provide "substantive" rules specifically providing a right for anyone to utilize it's capabilities.


(The dictionary states that Substantive law refers to the body of rules that determine the rights and obligations of individuals and collective bodies.).


The rules itself had been created to allow a open means to broadcast, but within them included the "exception" that it must not exceed certain limits so not to interfere with licensed broadcasters.
So the way I see it, the law was created specifically to allow unlicensed broadcasting but to be maintained in respect to not causing interference to licensed broadcasters.
The primary objective was to permit free unlicensed broadcasting for the public
The only stipulation was to not cause interference to those who are licensed.


Shown here are the Part 24 Rules in it's entirety, extracted from page 2999 of the original 1938 Federal Register or page 85 of the linked document.
After locating this, I set out to locate any related documents which preceded this to determine what arguments had led to these rules being created to begin with.. I haven't found them yet, however I did come across a very interesting QST Amateur Radio magazine article April 1942 (via this reprint at  rfcafe.com) which explains what actually had prompted the rule to be created; below is a brief excerpt which applies directly to the topic at hand.

"...Until 1938, that is. In that year Philco engineers, seeking a remote-control tuning system without the inconvenient multi-wire cables and accompanying complexities, evolved the idea of using an inductively coupled r.f. transformer with its primary and secondary spaced as much as 75 feet. The primary of this transformer was supplied from a small battery-powered oscillator, and the voltage induced in the secondary fed a supplementary amplifier in the b.c. set.

Naturally, because of its resemblance to a conventional transmitter and receiver, questions arose concerning the legality of the device. After considerable debate pro and con and a hearing or two, the FCC finally handed down rules cov­ering the subject. For the record, those rules are reproduced here in their entirety:..."

It then continues from there quoting the Part 24 Rules which is shown above.

So there you have it, evidently we have Philco to thank for setting the ball in motion which ultimately led to the Part 15 broadcasting we have today!

Thanks Philco!

Thursday, March 16, 2017

NOUO Notices of Unlicensed Operation

NOUO stands for Notice Of Unlicensed Operation,. If you ever receive one of these as a Part 15 broadcaster, it will be because your install or power input is incorrect.. In other words, if you ever get one, it's because you were not following the rules..

Most NOUOs include the following information..
The Commission's records show that no license was issued for operation of a broadcast station on [frequency] at this location..
The only exception to this licensing requirement is for certain transmitters using or operating at a power level that complies with the standards established in Part 15 of the Commission's rules,.. ..the maximum permitted level of 15.0 uV/m at 30 meters established in Section 15.209(a) of the Rules (See 47 C.F.R. S15.209(a). Or the alternative method may be used; Section 15.219(b) of the Rules states "The total length of the transmission line, antenna, and ground lead (if used) shall not exceed 3 meters."


You can access records of everyone of them going back 10 years at the FCC website: http://transition.fcc.gov/eb/FieldNotices/  ( I only went back looking three years )

There have been only 7 instances of the FCC shutting down supposed Part 15 AM broadcasters in the past 3 years... Compare this to the estimate of 1,000's of FM broadcasters receiving NOUO's in the same time frame.

Basically, with Part 15 AM, there are only two factors you must adhere to:
1. Your antenna system can not exceed ten foot.. 
You can mount your transmitter with it's ten foot whip 50 foot in the air if you wanted too, and you'd be legal, but the problem is you can't attach a ground wire to your transmiitter, because that ground wire would in effect extend your antenna that additional 50 foot!
2. Your power input can not exceed 100mw
Below are shown every NOUO issued (in the last 3 years) to an AM broadcaster for being non-compliant with Part 15 rules and regulations. Every one of them was due to excessive power or antenna..
Avoid making the same mistake and you'll be fine
These are edited down versions, click the respective links to read each document in its entirety..

===================================================
                 1 NOUO (so far) in 2014   
  ===================================================

1710AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-325287A1.html
  January 17, 2014
   Leonid Lytvynchuk
    Everett, Washington 98204
   Case Number:  EB-FIELDWR-14-00013037
    Document Number:  W201432980001

  On December 13, 2013,
  The field strength of the signal on frequency 1710 kHz exceeded the allowable unlicensed limit of 100 uV/m at 30 meters established in section 15.223(a) for operation on 1710 kHz, 47 C.F.R §§ 15.223(a), as well as the general unlicensed limit of 30 uV/m at 30 meters established in Section 15.209(a) for operation on  1710 kHz, 47 C.F.R § 15.209(a).

  ===================================================
             6 NOUO (not 7, see note) in 2013... 
  ===================================================

1710AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-322711A1.html
   July 23, 2013
   Luis Sanchez
   Bronx, New York
   Case Number: EB-FIELDNER-13-00010214
   Document Number: W2013323800044

   On July 18, 2008,
   The field strength of the signal on frequency 1710 kHz was measured at 3,100 microvolts per meter (uV/m) at 474 meters, which exceeded the maximum permitted level of 30 uV/m at 30 meters for non-licensed devices set out in Section 15.209 of the Rules, 47 C.F.R. S 15.209.

Note: This one strikes me rather odd.. The date of the NOUO is July 23 2013, but the filed report is from July 18, 2008...???..   I suppose it's just  a mistype somehow.

===================================================                                    
                              
1600AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-321497A1.html
   June 4, 2013
   Edwin & Teresita Ruiz
   Oswego, Illinois
   Case Number: EB-FIELDNER-13-00008449
   Document Number: W201332320003

   On May 2, 2013,
   The field strength of the signal on frequency 1600  kHz was measured at 8400 microvolts per meter (uV/m ) at 89 meters, which exceeds the maximum permitted level of 15.0 uV/m at 30 meters established in Section 15.209(a) of the Rules (See 47 C.F.R. S15.209(a).

   In addition,.. The source of the 1600 kHz signal is a vertical whip antenna approximately 3 meters long, mounted atop a 50 foot tower in the backyard of 416 Orchard Avenue. The total length of the antenna and transmission line exceeds the 3 meter restriction in Section 15.219(b) of the Rules. See 47 C.F.R. 15.219(b).

  ===================================================   

1700AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-319885A1.html
   March 29, 2013
   Sergey Kibitskiy
   Everett, Washington
   Case Numbers: EB-FIELDWR-13-00007506
   Document Number: W201332980013

   On March 22, 2013,
   Your operation on frequency 1710 kHz was measured at 6,400 uV/m at approximately 251 meters. This exceeds the allowable unlicensed limit of 24000/1700(kHz) or 14.11 uV/m at 30 meters established in section 15.209(a) for operation on 1700 kHz, 47 C.F.R SS 15.209(a).

  ===================================================   

1710AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-319576A1.html
   March 13, 2013
   Peter Kozodoy
   Mountlake Terrace, Washington 98043
   Case Numbers: EB-FIELDWR-13-00007118
   Document Number: W201332980012

   On March 4, 2013,
   Your operation on frequency 1710 kHz was measured at 6,100 uV/m at approximately 125 meters. This exceeds the allowable unlicensed limit of 100 uV/m at 30 meters established in section 15.223(a) for operation on 1710 kHz, 47 C.F.R SS 15.223(a), as well as the general unlicensed limit of 30 uV/m at 30 meters established in Section 15.209(a) for operation on 1710 kHz, 47 C.F.R SS 15.209(a).

  ===================================================
???? - It's curious to note that in the above NOUO, there was no mention made of 15.219, which of course has no field strength limitations, and is a proper alternative method of transmitting Part 15 AM. Therefore, legally the above was clearly an improper enforcement since it lacked any presentation of evidence in the report showing 15.219 was also in violation.
  ===================================================


1700AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-319568A1.html
   March 13, 2013
   Gerald Richard Gaule
   Vancouver, Washington 98685
   Case Numbers: EB-FIELDWR-13-00006961
   Document Number: W201332920006

   On February 26, 2013,
   Your operation on frequency 1700 kHz was measured at 1,800 uV/m at approximately 175 meters. This exceeds the allowable unlicensed limit of 14.11 uV/m (24,000/1,700) at 30 meters established in section 15.209(a) for operation on 1700 kHz, see Section 47 C.F.R S 15.209(a).

  ===================================================


1700AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-319569A1.html
   March 13, 2013
   Teal Pointe Apartments
   Vancouver, Washington  98685
   Case Number: EB-FIELDWR-12-00006961
   Document Number: W201332920007

   On February 26, 2013,
   The operation on frequency 1,700 kHz  was measured at 1,800 microvolts per meter (uV/m) at  175  meters. This exceeds the allowable unlicensed limit of 14.11 uV/m (24,000/1,700) at 30 meters established in Section 15.209(a) of the Commission's Rules. Thus, this station is  operating in violation of 47 U.S.C. S 301

  =================================================== 

Note that the above two NOUOs are one in the same.. Teal Pointe Apartments are located at 10405 NE 9th, which is the same address of the Richard Gaul NOUO

  ===================================================       

1710AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-319247A1.html
   February 27, 2013
   Vladimir Kachinskiy
   Mt Vernon, Washington 98273
   Case Numbers: EB-FIELDWR-13-00006836
   Document Number: W201332980007

   On February 7, 2013,
   Your operation on frequency 1710 kHz was measured at 6,000 uV/m at approximately 217 meters. This exceeds the allowable unlicensed limit of 100 uV/m at 30 meters established in section 15.223(a) for operation on 1710 kHz, 47 C.F.R SS 15.223(a), as well as the general unlicensed limit of 30 uV/m at 30 meters established in Section 15.209(a) for operation on 1710 kHz, 47 C.F.R SS 15.209(a).

  ===================================================
                      2 NOUO in 2012   
  ===================================================

1610AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-315222A1.html
   July 11, 2012
   Desert Christian Schools
   Lancaster, CA 93534
   Case Number: EB-FIELDWR-12-00002784
   Document Number: W201232900007

   On June 13, 2012
   The field strength of the signal on frequency 1610 kHz  was measured at 2,060  microvolts per meter (uV/m) at  134  meters, which exceeded the maximum permitted level of 14.9 uV/m (24,000/1610) at 30 meters established in Section 15.209(a) of the Rules (see 47 C.F.R. S: 15.209(a)).

   The investigation by this office determined that the ground lead was longer than the length of a 2-story tall building, thereby, increasing the total length of the transmission line, antenna, and ground lead well beyond 3 meters. This installation violated Section 15.219(b) of the Rules.

  ===================================================   


1680AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-313358A1.html
   March 28, 2012
   EPI Limited Partnership
   Fullerton, CA
   Case Number: EB-FIELDWR-12-00001143
   Document Number: W201232900006

   On January 30, 2012,  agents from this office confirmed by direction finding techniques that radio signals on frequency 1680 kHz were emanating from the property at  1370 Brea Blvd., Suite 205, Fullerton, CA  92835.  On February 29, 2012, the agents re-visited the above address and confirmed that the signals were still emanating from that location.

   The  field strength of the signal  on frequency 1680 kHz was measured at 17,900  microvolts per meter (uV/m) at 60 meters, which exceeded the maximum permitted level of 14.3  uV/m  24000/1680) at 30 meters established in Section 15.209(a) of the Rules (see 47 C.F.R. S: 15.209(a)).

   During their investigation on February 29, 2012, the agents determined that the ground lead was connected to a cable that ran down the length of the antenna tower, thereby, increasing the total length of the antenna, transmission line, and ground lead well beyond 3 meters. This installation violated Section 15.219(b) of the Rules. During that inspection, the agents observed that the ground lead at a point close to the street level had been cut, leaving the line at its original length, but not physically connected to the ground. This configuration will also violate Section 15.219(b) of the Rules as the total length of the antenna,transmission line, and the lead, attached to the transmitter, exceeded 3 meters.

  ===================================================
           4 (not 7) NOUO (see notes) in 2011  
  ===================================================

1620AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-309211A1.html
(a) August 19, 2011
   Robert Mohamed
   South Richmond Hill, NY
   Case Number: EB-11-NY-0230
   Document Number: W201132380006

   On August 3, 2011,
   Your operation on frequency 1620 kHz  was measured at 900 microvolt per meter (uV/m) at  1132 meters. This exceeds the allowable unlicensed limit of 100 uV/m at 30 meters established in Section 15.223(a) for operation on 1620 kHz, 47 C.F.R. S: 15.223(a), as well as the general unlicensed limit of 30 uV/m at 30 meters established in Section 15.209(a) for operation on 1620 kHz. 47 C.F.R. S: 15.209(a).

  ===================================================

1620AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-309312A1.html
(b) August 23, 2011
   Robert Mohamed Corrected copy
   South Richmond Hill, NY
   Case Number: EB-11-NY-0230
   Document Number: W201132380006

   On August 3, 2011,
   The field strength of the signal on frequency 1620 kHz was measured at 900 microvolts per meter (uV/m) at  1132  meters, which exceeded the maximum permitted level of 14.8 uV/m (24,000/1610) at 30 meters established in Section 15.209(a) of the Rules (see 47 C.F.R. S: 15.209(a)).

  ===================================================

NOTES: The above two shown NOUOs (a) & (b) are actually the same NOUO, not two as it appears.
       It is only a correction of the same report.

  ===================================================

1610AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-309212A1.html
   August 19, 2011
   Willie Walton
   Santa Clarita, California
   Case Number: EB-11-LA-0092
   Document Number: W201132900010

   On August 11, 2011,  
The field strength of the signal on frequency 1610 kHz  was measured at 2,730  microvolts per meter (uV/m) at  145  meters, which exceeded the maximum permitted level of 14.9 uV/m (24,000/1610) at 30 meters established in Section 15.209(a) of the Rules (see 47 C.F.R. S: 15.209(a)).

   The investigation by this office determined that the ground lead was connected to a cable that ran down the length of the antenna tower, thereby, increasing the total length of the antenna, transmission line, and ground lead well beyond 3 meters. This installation violated Section 15.219(b) of the Rules.

  ===================================================

1650AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-308327A1.html
(c)July 5, 2011
   Xeng Xiong
   St. Paul, Minnesota
   Case Number: EB-11-CG-0028
   Document Number: W201132320008

   On May 15, 2011,
   the field strength of the signal on frequency 1650  kHz was measured at 550 microvolts per meter (uV/m ) at 353 meters, which exceeded the maximum permitted level of 14.5 uV/m (24,000/1650) at 30 meters established in section 15.209(a) of the Rules (See 47 C.F.R. S:15.209(a)).

   During the inspection on May 15, 2011, the agent observed the station had five  antennas mounted on the roof, each with a vertical whip approximately 3  meters long, and the ground leads totaled over 15 meters in length. This   antenna installation violated section 15.219(b) of the Rules.

  ===================================================

1620 and 1630AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-308328A1.html
(d) July 5, 2011
   Kou D. Her
   St. Paul, Minnesota
   Case Number: EB-11-CG-0129
   Document Number: W201132320009

   On May 16, 2011, an agent from this office confirmed by direction finding techniques that (1) radio signals on frequency 1620 kHz were emanating from 1146 Rice Street in St. Paul and (2) radio signals on frequency 1630 kHz were emanating from 399 East Maryland Avenue in St. Paul. .... The owners of the properties where these stations are located reported to the agent that they granted you permission to install transmitters at those locations.

   The field strength of the signal on frequency 1620  kHz (1146 Rice Street) was measured at 470 microvolts per meter (uV/m ) at 1243 meters, which exceeded the maximum permitted level of 14.8 uV/m (24,000/1620) at 30 meters established in section 15.209(a) of the Rules (See 47 C.F.R. S:15.209(a)). Similarly, the field strength of the signal on 1630 kHz (399 East Maryland Avenue) was measured at 450 uV/m at 599 meters, which also exceeded the maximum permitted level of 14.7 uV/m at 30 meters.

   During the inspection on May 16, 2011, the agent observed that the approximate length of the antenna, transmission line and the ground lead at 1146 Rice Street was approximately 26 meters.
   Similarly, the ground lead at 399 East Maryland Avenue exceeded approximately 3 meters in length. These installations violated section 15.219(b) of the Rules.

  ===================================================

NOTES: The two above violations involved what sounds to be clusters of transmitters on multiple roofs. Both (c) & (d) consist of three violations within 24 hours, in the same town and close proximity to each other, which indicates them to be a single group entity.. So for this reason these could be considered as just one NOUO, not two.

  ===================================================

1610AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-306481A1.html
(e) May  5, 2011
   Gregory C. Schuller, Sr.
   Sadie M. Schuller
   Arizona City, Arizona
   Case Number: EB-10-SD-0217
   Document Number: W201132940007

   On April 21,
   The field strength of the signal on frequency 1610 KHz was measured at 1,900  microvolts per meter (uV/m) at  130 meters, which exceeded the maximum permitted level of 14.9 uV/m
  
  During the investigation on April 21, 2011, the agents observed that the approximate length of the antenna, transmission line and the ground lead was 8 meters. This installation violated Section 15.219(b) of the Rules.

  ===================================================

1610AM
http://transition.fcc.gov/eb/FieldNotices/2003/DOC-306483A1.html
(f) May  5, 2011
   Audie Ray Morrow
   Sandra Jean Morrow
   Casa Grande, Arizona
   Case Number: EB-11-SD-0086
   Document Number: W201132940008

   On April 21, 2011,
   The field strength of the signal on frequency 1610 KHz was measured at 1,200  microvolts per meter (uV/m) at  430 meters, which exceeded the maximum permitted level of 14.9 uV/m (24,000/1610) at 30 meters established in Section 15.209 of the Rules (See 47 C.F.R.  S:15.209(a)).

   During the investigation on April 21, 2011, the agents observed that the approximate length of the antenna, transmission line and the ground lead was 10 meters. This installation violated Section 15.219(b) of the Rules.

  ===================================================

NOTES: Casa Grande and Arizona city are only about 10 miles apart..add the facts that they both broadcast on the same frequency, and were both cited on the same day, one could easily conclude that they were also just one group working together to cover a larger area.. So again, these two can also be considered in essence a single NOUO.

  ===================================================

So remember, being a part 15 broadcaster means following the part 15 rules and regulations...