Interesting day yesterday. My boss at the "real" radio station where I work told me about an email he received from another "real" station about 100 miles away inquiring if the "guy in Bovey running the pirate radio station was still working for him". This gentleman informed him that I was selling advertising, which is not allowed on hobby radio stations. My boss, not being an ass, asked me about it all. I again informed him that there are NO limitations on what a Part 15 station can broadcast and the only FCC rules apply to technical parameters. I offered to respond to the email from the other guy, be professional and businesslike, and school him a bit on Part 15. So I did. they guy basically replied "Thanks for the info. I received some bad information". But again, my boss inquired how I can be broadcasting with no rules on programming, and again why my station can be heard for blocks, even a mile during the day, when the FCC says it can only go 200 feet. I explained (again) to him that there is no specific distance limit for AM Part 15 stations. He pointed me to this link (which comes up right at the top when you Google "FCC Part 15 coverage"):
http://www.fcc.gov/guides/low-power-broadcast-radio-stations
Which says " On the AM broadcast band, these devices are limited to an effective service range of approximately 200 feet (61 meters). See 47 CFR Sections 15.207, 15.209, 15.219, and 15.221. These devices must accept any interference caused by any other operation, which may further limit the effective service range."
Anyone only getting 200 feet on their compliant installed AM station, where they are actually intending to be heard? Futher, under 15.209 it implies that once you're under 30/uV at 30 (200 feet) meters you signal won't be heard. I've taken field strength readings with a certified accurate Field Intensity Meter and at 13/uV still have a clear solid listenable signal in the car, on a boom box and on a $5 portable transistor radio. Maybe it's just because I live where there is a very minimal noise floor so a weak signal can easily be heard.
But really, an effective service range of 200 feet? I'm suspecting this FCC page is just wrong, as the exact same sentance is written above this, stating the exact same thing for FM, and we know that it's clearly not the same. I think somewhere along the way the FCC page writer copied and pasted the wrong sentance in twice.
Anyway, opportunity to school my boss (again) and some other station owner who clearly gets excited about "radio pirates".
Here's part of my reply to the station owner who contacted my boss:
Tim here from KOZY/KMFY in Grand Rapids & "Iron Range Country Radio" in Bovey.
Had a chat with Jim this morning about your note and my "pirate" radio station, thought I'd clear up some things for you.
A Part 15 radio station is not a pirate radio station. Part 15 stations operate fully under FCC Part 15 rules. Part 15 stations operate legally and very out in the open, we're not pirates. There are thousands of Part 15 broadcasters in the US. There are several organizations representing Part 15 stations, we're above board and good, positive community minded people.
I'm a bit bewildered about your statement that "hobby broadcasters are not allowed to sell advertising". Yes, actually, we are. In fact there are no FCC rules whatsoever restricting anything that a Part 15 station may broadcast. None. Perhaps you were mis-informed
or have us confused with LPFM stations, who operate as non-profits. Heck, there are even ad agencies that cater to selling ads on Part 15 stations. The ONLY rules the FCC has for Part 15 stations are the technical limitations. I'd be delighted if you could point me
to an actual FCC rule that applies to advertising on a Part 15 radio station.
As you can see by the newspaper article from last year, my little station is 100% out in the open and above board. I use an FCC certified Part 15 transmitter so I'm assured it's fully legal (many hobby or micro broadcasters build their own). Yes, the FCC actually
certifies transmitters for Part 15 Hobby Broadcasting! I am also licensed by BMI, ASCAP and SEASAC for the rights to broadcast music.
Our coverage area is Bovey and generally Coleraine, the adjacent town. Our coverage area goes out maybe a mile. A bit more a nice day, and maybe 6 blocks at night (if we're lucky). I don't stream the station because I promised Jim I wouldn't stream while I was still working for KOZY and the music licensing costs for streaming are quite high for a station charging 30 cents a spot! I would be amazed if someone who ran across us started randomly contacting radio stations in Northern Minnesota trying to figure out where we were when a quick queery to me would get all the answers in moments.
I have been involved in broadcasting for 42 years. I've been at KOZY/KMFY for 27 and continue to host the morning show on KOZY every day and am also the Chief Engineer, and have been a chief engineer in total for over 35 years. I'm intimately familiar with FCC rules and regulations as pertain to commercial broadcasting in addition to Part 15 broadcasting, and have also been a ham radio operator since 1969 (I got my license when I was 11). I operate my Part 15 station as a "real" radio station following every rule and legal technicality to the letter.
Nothing gets a Part 15 broadcaster more fired up than to be called a "Pirate". Pirates operate illegally. Part 15 broadcasters do not.
I'd be more than happy to answer any questions for you. In the meantime if you have the time and desire you can find a ton of information at some Part 15 broadcasting websites:
https://www.hobbybroadcaster.net/
Although more geared for the operators, there's a ton of information there. There are many other sites dedicated to the art of micro or hobby broadcasting.
Whether it's commercial AM or FM, LPFM, Part 15 or even Public Radio I consider us all to be...
Brothers in Broadcasting,
Tim
Tim in Bovey
Little gossip chats can start forest fires.
Tim, you did an excellent job of handling the matter in a diplomatic friendly way, there isn't anything more you could have done, except perhaps hand the inquisitive guy a suitcase full of dollar bills.
People do have their poorly informed beliefs and ignorance can start battles.
Moving right in with a friendly confrontation is a very civilized thing to do.
As a backup plan in case embers re-ignite, sue the (other) station for something... defamation? Character assassination? False claims?
Right at this moment he might be following the links in your letter and seeing what I'm saying.
Hi! We're legit. Let me put my mother on.
First I'll be silly. If your audience has two-hundred feet, it will amount to one-hundred listeners!
Now to get serious. Tim is right when he expects that the FCC document linked above contains word-editing error...
"...these devices are limited to an effective service range of approximately 200 feet (61 meters)."
For FM with the ultra-low power allowance, yes... 200-feet is about right.
But AM does better, although using a part 15 AM transmitter indoors with a 3-meter wire will, in fact, get about 200-feet. But outdoor placement is not prohibited nor is using a ground-system, which achieves far better than 200-feet while complying with the rules.
But the wording is wrong by stating that "these devices are LIMITED to an effective service range of approximately 200-feet." There is nothing in the actual part 15 rules that limits the distance! The rules only express various technical conditions that must be met... not a word about distance.
even on fm it goes a little further than 200ft. i have a completely part 15 certified, straight from the factory fresh, unmodified Waio Inc/Broadcast Vision BR8000 (Waio Claims 25,000 sq/ft. range) and to my portable it goes about 300ft radious, to a car it goes a little over double that. if i was able to put it on our 3 story high roof i'm sure those ranges might increase slightly. right now it is about 8ft off ground mounted in the rafters (in a weather proof box) supporting the porch for apartment above our apartment.
i'm sure if i could get it on the roof i would cover half the complex to my portable.
keep in mind it is a radio shack shortwave reciever and a grundig shortwave receiver. also my friend who is on a 3rd story about 400ft away can pick me up on his older sony home stereo with a 1/2 wave wire inside his apartment. i can't even get it on my shortwave inside his apartment if i hold the radio in the right position and location. he however can't pick me up on his boombox which has very crappy sensitivity and selectivity and can't pick me up on any of his other radios. so if you are using a good radio for FM then FM can be pretty viable in an apartment complex type scenario. for the average city property you might get 2 or 3 homes away from the transmitter.
Waio Inc / Broadcast Vision have been around longer (since early 80's) than the Talking Housetransmitters and have never had any fcc troubles for manufacture and sale of illegal transmitters or out of spec transmitters.
also my friend at krocks radio one who is also cheif engineer for a major broadcast chain ran some calculations in NEC and overlaid it on a google maps and the range i am getting is in line with his NEC to google maps overlays.
i also run a chez procaster on am. it is also mounted horizontally about 8ft off the ground under the porch above me.
you can see pic's of my station and transmitters here....
Dropbox File (Private or Invalid)
It really is confusing to suggest that Part 15 FM in the U.S. is limited to 200 feet. The range is totally dependent on the receiving equipment (receiver and antenna). The sensitivity and selectivity of the receiver determine what level of field strength it can receive without adjacent channel interference. And the length of the antenna matters as well - a longer antenna or a gain antenna will increase range considerably.
I suppose it's something to use as a rule of thumb (if you're getting, say, 1000 feet to an ordinary radio, you're probably not legal) but that's about it. If you're getting that kind of range to a very sensitive car radio with a good antenna, then it is certainly possible that you are legal. Ditto is you're indoors, using a sensitive vintage FM tuner and an outside gain antenna.
My feelings on their suggested operating range is they must base that on what they consider to be a usable signal, not simply a receivable signal.
Their projected coverage area radius for my LPFM 60 db contour at 18 watts ERP is only a couple miles. However, it certainly has a much larger usable area than that. Emperical testing with the usual car radio takes our signal out at least 10 miles.
So maybe when they state a usable coverage area of 200 feet they are expecting a strong signal. Anything less, not usable.
By the way, I was told by someone in commercial broadcasting my LPFM sounds like a "Pirate" station because it doesn't fit one of the commercial "formats". My reply was "Thanks, just what I was shootin' for, a format that's different."