March 29, 2016
FCC “Pirate” Advisory Flawed
The FCC has launched a campaign asking the public to turn in Pirate radio stations. Included in their information are handy resources, which can be used to determine if a station is licensed, or not. At least two states have enacted laws against unlicensed radio stations.
The Association of Low Power Broadcasters is troubled by this action as license free, low power broadcasting is permitted by FCC Part 15 rules in the AM, FM, Short Wave and Long Wave frequency bands.
Legal Part 15 stations will not appear as licensed stations in the handy resources provided. The general public and local authorities will likely consider legal Part 15 stations as Pirate stations.
With a zero tolerance, strong-arm tactic applied by this action, legal Part 15 stations will be considered guilty without due process. They will be subject to stress and humiliation, as they are held high as examples until the situation has been sorted out. Defending ones self in a court of law will likely be an expensive task.
With regard to legal Part 15 stations, the ALPB feels the FCC should first educate the general public and local authorities called upon to assist this with this enforcement action. Hopefully this will reduce the number of legal Part 15 stations snared by the dragnet.

Posting this here is of course of no help.
It is in times like these the ALPB need a long, complete, accurate membership roster.
All such members need to be writing and calling their local law enforcement. Letters should be sent to the necessary politicians. Official letters, on behalf of the ALPB which note the number of members, members who vote for local officials. A nice printed piece that starts with "The 3,466 members of the ALBP, who operate legal, FCC authorized, unlicensed broadcast stations throughout the USA... etc... etc...
Talking about it here doesn't help.
I sent my letter and all related information to the same mailing list the FCC sent to.
How 'bout the rest of you?
Who has contacted the two states that have outlawed unlicensed broadcasting? They need to be taken to task for making a legal activity illegal, and need to be educated that this is not acceptable. Who among the ALPB is in a position to, on behalf of the membership, issue such letters?
TIB
I can't think of a BETTER way to put it.
There is one thing I should mention, though...
There are LPFMs and translators that are
new or just coming on the air in the Hartford, CT
area. PIRATES ARE ALREADY OPERATING on many
of the frequencies that these LICENSED STATIONS
are supposed to be on! Or the pirates are on the
next channel over from the licensed stations.
This REALLY bugs me! Where is the FCC??
The Part 15 thing - yeah - I LOVE Part 15.
I really concerned about that issue.
But I never thought this pirate thing would
happen.
Then on the other hand again... If local
government starts fooling around with this...
It will be a mess.
The only thing that is constant is change.
Gotta go.
It's a mess HERE (in my house, I mean.)
Very best wishes
Brooce, Part 15 experiments and
other stuff
P.S. I just reread this post - I hope it's
OK. I don't want to stir things up here.
With good intentions and respect to all
of you guys...
Brooce
BTW, I have written to ALL the FCC Commissioners AND the Chairman. Emails first. Then will follow up with actual written letters -- there's a certain extra importance to a real written and signed letter, that's relatively short and to the point, and respectfully written without a lot of ranting!
TIB
I think in order for the ALPB to be taken seriously it would have to change its stance from a passive aggressive group to somewhat of an activist group.
I don't think my post belongs here.
You can take it out if you want.
I just vented at the wrong time.
Best wishes and with respect to all.
Brooce
It should benefit the operators of unlicensed systems using the AM/FM broadcast bands in the U.S. to ensure that they accurately understand and comply with FCC Part 15, if they hope either to avoid or successfully defend citations/actions that result -- no matter which enforcement agency produced them.
If it can accurately be shown/proven that such unlicensed AM/FM systems don't comply with Part 15, then by definition aren't those operators "pirates?"
But that said, probably no enforcement agency in any State has the technical training, test equipment, and field experience needed to make an accurate determination of compliance or non-compliance with Part 15.
The FCC apparently has not considered this or has shrugged it off, possibly to meet its current manpower and budgetary restraints, and/or in reaction to political pressure.
Unfortunate for us all, if so.
YMMV.
Rich lamented: "...Unfortunate for us all, if so."
Who is "us"?
Also, in as much as everyone on this website complies with part 15 rules, who are the alleged "pirates" you incessantly lecture?
True, if part 15 goes down the tubes you would no longer have your lessers for finger-wagging exercise.
here is where I see things happening in the near future. part 15 stations May have to fill out an application that shows where they Live and they're intended frequency of use.
Keeping this in mind and if this happens rather not if but when I propose some extra Power For this service and the extra power would be relevant to their location.
I urge real hobbyist who are very passionate about their Hobby and want to keep it legal to start a major petition campaign to right that of which is about to go very wrong and can be detrimental against your precious Hobby to stop sitting down and stand attention like a soldier and fight to the death if necessary for your rights. There are already two initiative sites get involved and participate. if not and your legal Hobby becomes outlawed you have no one else to blame but yourself.
The ALPB was never intended to be an activist group. I would not be interested if it was.
I think this is a political ploy on the part of the FCC. They are going to get many more pirate reports, erroneous or otherwise, far more than they can handle. There will be many more erroneous reports than real pirates - from Part 15 broadcasters and just plain mistakes (the databases are not entirely accurate). They are then going to go to the well for more budget to combat the spiralling out of control pirate problem.
I do not think that Part 15 will change in the manner described by Thelegacy. There is no way that the FCC is going to do anything that resembles a licensed service to Part 15 broadcasters, as it will only create more work.
There is also no way they can get rid of Part 15 entirely - it is not just broadcasters. They could restrict it more, or get rid of intentional radiators in the AM or FM broadcast bands, but then that will REALLY increase the pirate problem (as opposed to just making it look like it is bad). And what will happen to the millions upon millions of people using Part 15 transmitters for housecasting or car casting - the Part 15 FM signals are barely enough for that as it is.
In an election year the FCC is whining about what... budget? Overwork? Too many "pirates"?
Pirates are a scapegoat or strawman, as it were.
A very important statement was made on the current "This Week in Radio Tech" by one of their radio engineers... "The FCC ought to do it's real work of cleaning up the unintentional radiator interference that is wrecking AM". The "revitalization" talk by the FCC avoids mention of the real interference problem.
We are obeying rules made by political gamesmen.
I receive the Information Station Specialist news letter. The article about the FCC advisory was included in subject news letter.
I emailed Mr. Baker of ISS and voiced my concern for the reasons stated in my above post. He inturn requested that I pen my concerns and send to his news letter editor. I'll assume he wants to put my response in the news letter.
My opening post is the result of his request and has been sent to him. His company works closely with the FCC as his company is a major player regarding AM TIS equipment. It was with his work that the FCC has relaxed some of the restrictions on AM TIS stations. His may be a door to the FCC.
It's a small step but then again that news letter reaches quite a few users. And yes to Artisan, The ALPB is not an activist group pushing for regulatory change. Our focus is on developing quality broadcasts by assisting member stations with technical and programming issues.
Rich, as for your comment: "If it can accurately be shown/proven that such unlicensed AM/FM systems don't comply with Part 15, then by definition aren't those operators "pirates?",
I take exception to that statement.
A "Pirate" operator has shown willfull disregard for the FCC rules. The "Pirate" operator is fully aware of their illegal operation.
Any station; licensed, unlicensed, commercial, non-commercial, public safety, public service, etc. can have a situation develop resulting in non-compliance. This does not make them by definition a "Pirate". It only makes them the operator of a system which has a problem. There was no willfull intent for the situation to occur.
The FCC levies forfeitures for thousands of dollars for just such occurrances to licensed, commercial stations annually. Those stations are not branded "Pirate" stations by definition. They are not stripped of their equipment. In many cases the forfeitures are paid or reduced to a fraction of the request, the problem corrected and life goes on as though nothing happend.
How you can make such a statement simply reinforces the perception many have that you have an agenda to discredit our Part 15 activities. This goes beyond your simply providing "guidance" to prevent non-compliance.
I just see a lot of these private 'investigations' ending badly.
The only way to tell if a station operating under Part 15.219 is compliant is to inspect it. No private individual or organization has the right to come onto private property for that.
And, as Rich pointed out, it's highly unlikely that a private individual has the equipment necessary to measure compliance with 15.239. It's also highly unlikely that a private organization is going to pull out their FIM to measure a signal. Particularly since you have to know distances to get an accurate measurement, and are these people going to start roaming the streets looking for suspicious antennas? Talk about being presumed guilty!
This has all the hallmarks of a political activity to deflect attention away from the root causes of the problems. That the FCC has lost it's way. That it can't or won't enforce the existing rules. Which themselves have been outgrown by the public and technology.
The FCC, which has been tasked to regulate the airwaves to serve the public, doesn't do either of those things anymore. And since the public isn't being served, they're starting to serve themselves, with the results you see today.
I don't condone pirates at all. But a lot of them are just attempting to fill voids in their community that the corporate radio stations have left. Yes, you're always going to have the lawbreakers, who do it just because they can. But on the whole, there are reasons for pirates. If the community they serve wasn't interested, they would disappear, much like many of the corporate radio stations are starting to do.
If the FCC would address the root causes of pirates, there wouldn't be these problems.
Disregard I think what I was posting about was removed?
Here is what I used to put up on my radio station every hour, and I'm thinking of doing it again:
'Artisan Radio is a Low Power Announce System, broadcasting under regulations issued by Industry Canada and the CRTC. If you have any issues with our operation, or programming, please contact us at <contact info>'.
