An interesting tidbit concerning NOUOs: From 2002 till about 2009, every AM notice specified the following or a variation thefeof:
"...Radio stations must be licensed by the FCC pursuant to 47 U.S.C. S 301.
The only exception to this licensing requirement is for certain
transmitters using or operating at a power level or mode of operation that
complies with the standards established in Part 15 of the Commission's
rules, 47 C.F.R. SS 15.1 et seq. The field strength of the signal on
frequency 1620 kHz was measured at 23,600 microvolts per meter (uV/m) at
75 meters, which exceeded the maximum permitted level of 250 uV/m at 3
meters for non-licensed devices. Thus, this station is operating in
violation of 47 U.S.C. S 301."
In no citation from 2002 to 2009 did any of the NOUOs investigate, or even mention the alternate opion of operating under 15.219, but in 2009 that changed, now every NOUO since includes investigation and report checking the compliance of both 15.209 or 15.219.
What prompted this change? It was the two and a half year battle of KENC AM 1650 with an inspecting FCC agent beginning back in 2009. Now all NOUOs address both options instead of just field strength.