I found another obscure whip and mast part 15 transmitter from the mid 1970s, it was called Metacomm Model 8008 - 10A, and the fact that it came out when it did apparently saved the 15.219 rule from elimination in the nick of time.
Now keep in mind that in 1973 any existing part 15 transmitters being utilized bye the department of the interior have been issued and experimental license with increase in power and morad antennas, and a hold was placed on ordering additional units as the FCC worked towards establishing a new license TIS service. This had caused the info systems company, which previously had been the only firm manufacturing these whip and mast transmitters to go out of business by 1974... So as far as the FCC knew there were no other businesses manufacturing these Whip and mass transmitters anymore. So the FCC took advantage of the situation to remedy the problem 15.219 had created...
In 1975 the FCC put forth requirement that all manufactured part 15 transmitters conform 15.209 field strengths and could no longer take advantage of the alternative 15.219 rule, but Metacomm objected because they had just manufactured and put on the market a new transmitter and felt got the FCC had not forwarned them about any restrictions about utilizing an additional ground lead.
The FCC's response, I have truncuated considerably to post here but if you want to read it in it's entirety it's in the
FEDERAL COMMUNICATIONS COMMISSION REPORTS
Volume 62, Second Series page 643..
.................................
F .C .C . 76 -860
BEFORE THE FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON , D . C . 20554
In Re Request by BRISTOL DIVISION OF AMERICAN CHAIN AND CABLE, INC.
For reconsideration of staff interpretation or waiver of Section 15.113(c )
September 14 , 1976
Gentlemen :
This is in reply to your letter of May 5 , 1976 , requesting on behalf of the Bristol Division of American Chain and Cable, Inc. (ACCO), reconsideration of a staff interpretation , or alternatively waiver of Section 15 .113( c) of FCC Rules, to permit the certification and marketing of a low power communication device, Metacomm Model 8008 - 10A. ....the critical deficiency, which according to your letter would make the system unusable for its intended purpose , is the requirement in Section 15.113 (c ) which limits the combined length of the antenna , transmission line and ground lead to 3 meters.
Waiver of Section 15.113 (c ), specifically waiver of the restriction on the length of the ground lead, is requested on the grounds that this requirement was added in an Order (FCC 74 - 1221) released March 7 , 1975 after the equipment had been designed and placed on the market.
You allege that the Order,.. did in fact contain a substantive change to the detriment of your client. Prior to the release of this Order, you state that the equivalent provision (formerly designated Section 15.204) limited only the combined length of the antenna plus transmission line to 3 meters...
In the case of a device operating on a frequency below 1600 kHz, the basic technical restriction (Section 15.111) is a limit on the amount of RF energy radiated into space... the Commission established , as an alternative, Section 15.113 where the primary technical restriction is power ( instead of field strength ) into a radiating element of fixed length of 3 meters for devices operating in the frequency range between 510 and 1600 kilohertz. Measurement of power into the final stage of a transmitter is a much simpler test that does not require special test equipment or expertise. Although simpler, it also does not indicate how much RF energy will actually be radiated into space.
The technical parameters in Section 15.113 were selected on the assumption that a 3 meter radiating element at frequencies below 1600 kHz makes an inefficient radiator... The original provision did not consider the possibility that the addition of an extended ground lead would increase the level of radiation from the device and thereby increase its interference potential. This was discovered in tests at our laboratory...
Inasmuch as the change in Section 15.113( c ) was merely intended to clarify our intent and not intended to cause an economic hardship to a company manufacturing under the previous rule section and since this equipment is intended to be operated in remote areas where the likelihood of interference to radio communication is small, the Commission hereby grants waiver of the ground lead limitation in Section 15 .113(c ) of the Rules for the subject equipment. Accordingly , certification of Metacomm Model 8008 - 10A is granted...
This waiver applies only to devices manufactured prior to the effective date of the rules that may be adopted in our proceeding in Docket No. 20780 which proposed to terminate the availability of the alternative provisions in Section 15.113 to persons manufacturing and marketing low power communication equipment for operation in the band 510 - 1600 kHz. After such effective date, low power communication devices operating in the band 510 - 1600 kHz which are manufactured for marketing will be required to meet the technical specifications in Section 15.111 as revised in the proceeding in Docket No. 20780.
BY DIRECTION OF THE COMMISSION,
VINCENT J . MULLINS, Secretary.
...........................................
Okay, now note that although the FCC gave them a waiver, they also concluded by saying any transmitters after 1975 would have still have to conform to 15.209 field strength. But as we all know that did not happen, and manufacturers were permitted to continue manufacturing under 15.219... Why this happened is still rather unclear, but it's interesting to note that they did make two additions to the certification rules sub parts, those being 15.135 and 15.136 which only seemed to make sense if the 15.29 rule had indeed been eliminated.
Those two sub parts remained as part of the rules for the next 10 years, until which time it was deemed obsolete and deleted. I just find this rather interesting. Below is a copy and paste of those sub parts, followed by another copy and paste official deleting of those rules in 1984. That's all for me for now, hope this didn't bore anyone.
§ 15.131 Certification required for devices that are
marketed or built in a quantity greater than 5
and not marketed .
( a ) A low power communication device manufac
tured between December 31, 1957 and October 1, 1975
which is marketed or which is built in a quantity
greater than 5 and not marketed , shall be self-certifi
cated pursuant to the provisions of 15.135–15.136.
( b ) A low power communication device manufac
tured after October 1 , 1975 which is marketed or built
in a quantity greater than 5 and not marketed shall be
certificated pursuant to Subpart B of this part.
§ 15.135 Certification procedure: Device manufac
tured between December 31, 1957 and October 1,
1975.
A low power communication device manufactured
between December 31, 1957 and October 1, 1975 shall
be self- certificated as follows :
( a ) The owner or operator need not certificate his
own low power communication device, if it has been
certificated by the manufacturer or distributor.
( b ) Where certification is based on measurement of
a prototype, a sufficient number of units shall be tested
to assure that all production units comply with the
technical requirements of this subpart.
( c ) The certificate may be executed by a technician
skilled in making and interpreting the measurements
that are required to assure compliance with the re
quirements of this part.
( d) The certificate shall contain the following
information :
( 1 ) The operating conditions under which the device
is intended to be used .
( 2 ) The antenna to be used with the device.
( 3) A statement certifying that the device can be
expected to comply with the requirements of this sub
part under the operating conditions specified in the
certificate .
(4 ) The month and year in which the device was
manufactured .
8 15.136 Location of certificate on devices manufac
tured between December 31, 1957 and October 1,
1975 .
The certificate shall be permanently attached to the
device and shall be readily visible for inspection.
.................
.................
...............
AGENCY: Federal Communications
Commission.
ACTION: Final rule.
SUMMARY: This document deletes self-
certification and labelling requirements for low power communications devices
manufactured before October 1, 1975.
These requirements have become
obsolete and are therefore being
deleted. The intended effect of this
action is to remove the subject
unnecessary requirements from the FCC
Rules.
EFFECTIVE DATE: December 3,1984.
ADDRESS: Federal Commumcations
Commission, Washington, DC
SUPPLEMENTARY INFORMATION:
List of Subjects m 47 CFR Part 15
Communications equipment labelling.
Order
In the matter of Part 15 requirements pertaining to certification and labelling of low
power communication devices produced before October 1,1975.
Adopted: October 18,1984.
Released: October 25, 1984.
By the Commission.
1. Sections 15.135 and 15.136, which
specify self-certification and labelling
requirements for low power communication devices manufactured
before October 1,1975, are obsolete.
As
of October 1, 1975, such devices were
made subject to certification by the
Commission. The old requirements had
been retained beyond 1975 so that, when
checking equipment on dealers' shelves
for compliance, it would be clear which
requirements applied.
In general, it takes
several years from the date of
manufacture for-low power
communication devices, such as toy
walkie-talkies and radio control devices,
to move through the retail distribution
chain.
It is reasonable to assume that by
now all equipment produced prior to
October 1, 1975, has been sold. To the
best of our knowledge, no enforcement
questions concerning equipment that fell
under these requirements have come up in several years. Therefore these
requirements are no longer necessary and should be deleted.
Deletion of these
requirements would not affect the
operational status of any such
equipment still in use.
§§ 15.135 and 15.136 [Removed]
2. In light of the above, notice and
comment on whether to retain these
requirements are considered
unnecessary. Accordingly, it is ordered
that § § 15.135 and 15.136 are removed in
their entirety, effective December 3,
1984.
3. For further information concerning
this Order, contact Julius P Knapp,
Office of Science and Technology, (202)
653-8247.
(Sees. 4, 303.48 Stat., as amended, 1066, 1082
47 U.S.C. 154, 303)
Federal Communications Commission.
William J. Tricarico,
Secrety.
[FR Doe. 84-29F28Fled 12-2-4: &45 am]
BILNG CODE 6712-01-M