PART 15 Call Letters

I think I have commented about this before, but after Mark posted a couple YouTube videos today in response to the thread https://www.part15.org/community/regulations-law/part-15-am-has-always-been-fast-and-loose/#post-61542 it led to this topic again..

I had seen both videos before, but this time I read some of the YouTube comments of the first video and there were a few people strongly advised not to use any call letters because the FCC strongly frowns upon it.

Well, I was compelled to correct them and thought it'd be a good idea to post a copy of what I said here too...

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That's actually a misconception, the FCC is quite clear on the matter, they don't care what you call it, but curiously this is specified not in the part 15 rules themselves, but found within the Part 73 rules:
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§ 73.3550
[L]Users of nonlicensed, low-power devices operating under part 15 of this chapter may use whatever identification is currently desired, so long as propriety is observed and no confusion results with a station for which the FCC issues a license.
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I can explain how and why that rule managed to find itself oddly nestled in within the Part 73 rules..
This "call sign" specification had been added to the rules in 1971, it was not a modification, but rather a clarification (much like the 15.219 "ground lead" specification added in 1974 was not a modification of existing rules, but a clarification of what the existing 10ft antenna length limit entailed).

Anyway, this clarification had been prompted by a huge surge of Part 15 AM use in the early 1970s by the NPS as well as several Highway departments (particularly in Montana and California).. which also corresponds with (and directly led to) the initial studies, experimentations and proposals for creating a new higher powered licenced radio service to serve the same purposes, which at the same time would put the FCC in a position to regulate where it could be used, as well the content of its broadcast (this is what eventually became TIS in 1977).

The higher powered information stations were to require licensing and call letters under part 73, this then caused the question to arise; 'So what are to be the requirements these existing low powered unlicensed transmitters to be identified? - to which the FCC responded: call them anything you want but don't use any existing call signs. The reason it ended up in the part 73 rules is because that's where the question had stemmed from when it had been written, and simply because that's where the rules concerning call signs (whether licenced or unlicensed) reside.

Also of note, of all the NOUOs that have been issued to part 15 AM stations over the last 20 years, citing long ground leads, many of those stations used made up call signs, the letters of which are often specified in the citation itself -- but only as an identification, it's not cited - there has never been a single instance of the FCC expressing any issue with part 15 call sign use.

And lastly, an apparently a little known fact is the FCC from 1941 till about 1953 actually were reserving call letters for unlicensed part 15 AM college stations! On a regular basis! This practice eventually came to a stop when the FCC informed the colleges that they would no longer reserve call letters for the part 15 stations because it was causing them "undue embarrassment" when licenced stations applied for a call sign that had already been reserved for a unlicensed part 15 college station.

Bottom line:
§ 73.3550
[L]Users of nonlicensed, low-power devices operating under part 15 of this chapter may use whatever identification is currently desired, so long as propriety is observed and no confusion results with a station for which the FCC issues a license.