call letters for part 15

1. FCC won't issue call letters if they don't issue a license. They don't want to identify and track what they don't have to.

2. Making up call letters is a gray area. FCC probably won't cry if you make up call letters in a format they don't use for any licensed service, or at least are not used by any particular licensed station. However, you may be better advised to use a phrase identifier like Praize Radio.

by MRAM 1500 kHz

Here is a cut from the FCC rules:

TITLE 47--TELECOMMUNICATION

CHAPTER I--FEDERAL COMMUNICATIONS COMMISSION

PART 73_RADIO BROADCAST SERVICES

Sec. 73.3550 Requests for new or modified call sign assignments.

(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.

I think that makes it pretty clear! Just don't use your local stations call sign or make statements that would make it seem you are a station licensed by the FCC.

What if I'm not using call letters from a local station, but it is a coincidence that there is a station from Baltimore with the same calls? Would I need to change mine to keep from causing any hogwash?
Travis Allred B-1600/Real Country
www.geocities.com/wbgrradio/index

I would say don't use call letters that start with K or W, in the three or four letter format. Lot's of stations do, but MRAM's note points out an important caution:

"so long as propriety is observed and no confusion results with a station for which the FCC issues a license."

One interpretation of that sentence is that using KXXX or WNN, even if those calls are not in use by any station any where, might be construed to imply that you *have* been licensed by the FCC. That has important implications in a lot of areas - press passes, free CDs, concert tickets, public gathering permits, banner displays in communities that regulate signage, the list goes on and on.

If the FCC chooses to do so, you can be issued an NAL for that - I know 'cause I got one for using "KFIR" in Seattle WA. in July of 1997, and the specific charge was "posing as a licensed radio station when no license was issued by the commission," $75,000 fine and 10 years in Federal prision. Notice there was no mention of field strength in uV/M 🙂

Experimental broadcasting for a better tomorrow!

Glad to hear every ones thoughts. What I use for my radio station call sign is just simply " Your listening to am 1610 under dog radio." We also some funny ones like "Your listening to under dog radio were the little guy always get a leg up."followed by the sound of water trickling.
Brian Bethke

by MRAM 1500 kHz

So, like, are you still in the pen?

Not to make lite of the situation or to offend but I find it difficult to believe since your time is not up yet.

Granted it would take some research to find a call not already assigned somewhere by the FCC, their rule makes it clear that you shall not use the call sign of a currently licensed station and other than that they grant permission to use whatever identification you so choose per their rule. Of course, if you are pretending to be a known licensed station that's a different story. As part 15 stations, we are "real radio stations" granted the authority to operate without license by the FCC.

As for the "implications in a lot of areas", as an unlicensed part 15 station, FCC regulatory actions pertain to mitigating interference to licensed services. I'll have to check and see if rules pertaining to "payola", etc. apply to part 15 operation as I don't know.

I started a thread quite some time ago requesting information from anyone that had FCC intervention but got none. So please, I'm very interested in the details about your situation as the rule here seems very straight-forward and clear regarding the use of station identification.

P.S. Here is a current listing from the FCC AM Query for KFIR:

KFIR AM 720 kHz ND2 Daytime D B LIC SWEET HOME OR US BL-19951006AA 1.0 kW 23024 SHAE ENTERPRISES, INC.
KFIR AM 720 kHz ND2 Nighttime D B LIC SWEET HOME OR US BL-19951006AA 0.184 kW 23024 SHAE ENTERPRISES, INC.
KFIR AM 720 kHz ND2 Daytime D B APP SWEET HOME OR US BP-20051213ABD 10.0 kW 23024 SHAE ENTERPRISES, INC.
KFIR AM 720 kHz ND2 Nighttime D B APP SWEET HOME OR US BP-20051213ABD 0.184 kW 23024 SHAE ENTERPRISES, INC.
KFIR AM 720 kHz ND2 Daytime D B APP SWEET HOME OR US BP-20051213ABD 10.0 kW 23024 SHAE ENTERPRISES, INC.
KFIR AM 720 kHz ND2 Nighttime D B APP SWEET HOME OR US BP-20051213ABD 0.184 kW 23024 SHAE ENTERPRISES, INC.

That's why we use XSUR for all documentation that needs them. Just as long as the Mexican government doesn't come knocking at my door-lol

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Happy to say that by responding immediatley to the NAL, agreeing to immediately cease all activities and after sending some very apologetic letters the commission dropped the matter.

There was, and still is, a profoundly nasty pirate operation in the same general area operating under the banner of FUCC, and the FCC thought I was part of that. When I was able to convince them I wasn't that helped a lot.

The fine and prision sentence noted in the NAL were the max if the issue went that far, which of course it didn't. The complaint that led to the NAL wasn't based on another KFIR, it was from other licensed stations who saw my ads in the Belltown Dispatch newspaper (eight page neighborhood monthly) and didn't like my operation (imagine that!).

Poor judgement on my part, really, because the studio and offices of KIRO Radio & TV were 5 blocks away on 3rd, the studios and offices of KOMO Radio & TV were 8 blocks away on 5th, and the old KISW FM Radio offices were right down the road on Dexter at the base of Queen Anne. I was on 2nd and Virginia at the time. I imagine they all read the Dispatch and probably spit their lattes all over themselves when they saw my ads.

I didn't respond to your earlier post 'cause this was FM, not AM, and although I wasn't NAL'd for power levels, I wasn't really shooting for part 15 compliance at that time.

The searchable electronic records don't go back to 1997 yet, but I'll dig up my citation number and field engineer's name and maybe we can still find the info.

"Now give me a yard out ya dirty screw!"

Experimental broadcasting for a better tomorrow!

by MRAM 1500 kHz

Thanks for the info on that situation. I'm really interested in what trips their trigger. Seems to be mostly big money.

In your case an innocent victim of circumstance which would tend to make one a bit gun-shy.

Reminds me of the little kid that had a lemonade stand. Local paper did an article about it. Next thing you know he was hit with the tax man, the health department, business license bureau and others. He was told he had to file, comply, apply and whatever... Geez, I hope he never tries raking leaves or mowing lawns lest OSHA may step in.

I grew up in the '50s, raked leaves, mowed lawns, worked regularly in a bicycle shop, sold lemonade, and even began work in a factory at age 17 without anyone's permission or anyone caring.

But that is not the world today. Too many today get wrapped around the axle about everything!

Back to the thread, don't use call signs that you have not been licensed for or assigned. Simple isn't it.

Neil

I must clarify "the under dog were the little guy gets a leg up" followed by the water trickle. Since my radio station is playing unsigned an local music its my way of saying piss on big radio were the same crappy songs are so over played
so keep you stations original.
Brian Bethke
Under dog Radio

Decades ago the FCC rules called using a false call sign or set of call letters "superfluous communication". Superfluous communication was an offense, possibly endying in a fine or worse.

And by the way, I have actually engineered for KFIR AM in Sweet Home and knew the gentleman (Dennis Celori(sp), very well, who orginally built it. Today, its on a different frequency that the one orginally authorized. Anybody have any idea where Sweet Home is?

Anyway, the use of call letters fall under the sections of FCC rules involving station identification. And that has been well documented here. It is logical if a person is listening to a station using call letters that the station would idenitify within 4-5 minutes, plus or minus, the top of the hour or as close as possible in a break in programming. These are the rules for licensed station idenitifying. When you uise call letters and don't identify as expected, you will cause closer scrutiny by an FCC inspector (you might be a pirate station). However, the FCC's main rub with the use of call letters for unlicensed stations is the possibility of misleading the public. That is why many long time low power community broadcasters air a disclaimer frequently explaining their station is authorized to operate legally under Part 15 of the FCC rules and regulations. And the stations websites proclaim they are legal unlicensed low power community radio stations. Some even invite public to comment and publish their web address or P.O. box.

Bottom line: tell people who you are, what you are doing, how you're doing it and how they should respond...and surprise they probably will. Sort of like being the only flash light in a dark room. Its pretty hard to hide or convince people you don't exist. Most folks aren't that stupid, plus would you give any credibility to anyone who you might listen to trying these kind of tactics. If your yardcasting, hide all you want. If you have a purpose for your station that other folks can get behind and support, why hide. Its counter productive. Under Dog has the right idea, just never tinkle into the wind. Just take it a step further and tell your audience you're a legal unlicensed Part 15 community radio station and push why people should listen to you (what makes your station worth the time?)....and forget the call letters.

Marshall Johnson, Sr.
Senior Pastor, President
Rhema Christian Fellowship, Inc.

Rhema Radio - The Word In Worship
AM 1660 - FM 101.3
http://www.rhemaradio.org

I heard that Sweet Home is in Alabama.

🙂

I heard that Sweet Home is in Alabama.

🙂

Or so sez Lynyrd....

Frank