There's another aspect to this which I thought about this morning - what was the original intent of Part 15, why did they allow LPFM to exist, and are they going to care about something "in the middle"?
It seems from what I've researched that Part 15 was created for short-distance, personal use. Going back to the 40s, I think there was a device that you could buy to transmit phonograph to your stereo. The wording of Part 15 opened the door to hobby radio after that. With FM, it's about very short-range transmitters for iPods and such.
So with all that, will the FCC care? Not only are we going to have to show that this is necessary from a social point of view, but that it's perhaps separate from Part 15 as we know it. Maybe another class of devices?
Its why it should be another service (Similar to part 15) where there is no cost (Or Little) maybe when you buy the Transmitters the cost could be put into them sort of like what Canada does with all storage media to suit the CRIA (An RIAA type group). When you purchase a CLPFM certified transmitter this cost could be in there and so much goes to the NAB to keep them happy with hobby Radio comming onto FM. I'd just like to call it Hobby Radio FM class of permit or HLPFM (Hobby Low Power FM) or MLPFM (Micro Low Power FM). But with the class you would sort of apply like a CBer did. You get a call sign but maybe different from a normal station. An example P15thelegacy your call sign would have a p15 befoe it. Or MLPTHELEGACY. MLPLEG something like that with the MLP before it. It could have the initials of your station followed by your zip code TLEG 27909 would be the call. The FCC gets a complaint that TLEG 27909 is interfering with other stations services they know to call me and I'd have to correct the issue or get off the air. I'd probably have to get a different transmitter or drop power closer to -48DBM till the problem is solved.
The FCC wont license a station to use less than 1W.
There was going to be a LPFM 10 watt class, but the FCC concluded they would not be viable and the noise they caused beyond where they could be recieved would prevent reuse of the channel in too large of an area.
Look at the history of TV CH 1, it was going to be for community stuff, but it did nkt survive.
Unless there is a massive shake up of fcc leadership, don't explain expect any improvments for unlicensed or community radio on the FM band.
If you wait long enough the current license holders on the FM dial will ruin the FM band the way the AM band was ruined. Then you will probably be able to pick up an FM station for as cheap as AM stations are.now.
It could be a license for a different class of service (call it something like Very Low Power FM or VLPFM), or it could even be a waiver for the field strength restrictions of Part 15 FM (with all the other Part 15 criteria remaining in place) and allow for a higher field strength (or if you're so inclined, ERP, both of which allow you to calculate range to a radio with a given sensitivity).
I really think that it should cost some money to get the license or waiver (how much would be an interesting discussion, to be sure). That would take it out of the realm of potentially playing around, and into the serious hobbyist or business arena. And you could certainly make the argument that VLPFM practitioners are paying their own way.
I'sn't the current AMers who go 1 mile playing around? Meaning they don't pay anything and efery since AM part 15 came out years ago you could go 1 mile. In fact that was a student that use to have an AM Transmitter he built and was gonna sell me. It went 1 mile on AM this was back in 2002 and I actually considered it at the time. With that said 1 mile is nothing new and paying for that 1 mile more than 20-30 a month just won't fly with most hobbyests you'd just be back to Pirate Radio operators who won't pay and may make them even more mad and start a faster trend for FM Piracy. You have to make this something that most folks who know the slightest about Electronics can do. The fact that these transmitters should not be available at your local Wal Mart will help curb that. It may be that you'd have to buy the Transmitter right from the FCC. You'd pick the brand you want and the FCC gets some of the proceeds towards licensing. They would certainly be approved because it is on their web site.
As far as ERP I forgot to mention we talked about that too at the meeting as a way to measure your distance. Many licensed stations don't mention wattage to the final of the transmitter, but the ERP of the transmitter. I know the ERP is every 3db gain is double the power. So 500mW with a 3db gain antenna is 1 Watt ERP if I'm right. And 6db gain is a Watt and a half I do believe I don't remember the exact formula I was learning this when I was into CB and wanted to get a good range back then. So if you go by ERP you'd have to have a limit of the ERP if its a Watt ERP your talking 500mW into a 3db gain antenna. A Rubber duck I think has 3db gain if that probably less. A telescoping antenna I know at least has 3db so it might be something that can work with the many transmitters already out there if they simply go ERP. For an example there is an illegal 7 Watt FM TX out there. But at low power its 1 Watt. If the antenna didn't have any gain you're OK but that is just an example. At least you can understand that alot more than say 1,000 uVm or so much DBm but there is a DBm to milliwatt calculator on the net.
Many details about FCC policy on Part 15 do not appear in the Part 15 section of the rules. Those policies appear in various other FCC publications, legal documents, and maybe even jotted on the back of a napkin in Washington D.C.
Up above macdev said, "what was the original intent of Part 15(?)"
The answer is not part of the Part 15 rules, but it does appear in a Denial for a Waiver to Part 15 Rules filed by Pennsylvania Youth Radio. Here is what the FCC says in their own words:
"The intent of Part 15 is to provide the radio enthusiast with an opportunity to experiment with radio, and to entertain friends or neighbors within a very limited range. The FCC never intended that Part 15 be used to establish a low power broadcast facility to service an entire community."
Exactly. Which is why I don't think the FCC will want to listen to this at all. I'm not giving up, I want to hear what more people have to say, but this "in-between" of Part 15 and LPFM may not be what the FCC is interested in.
Yes I got a refreshed memory now. Ok so we need a new class of service. A sort of hobby or Announcement Transmitter class to announce and entertain a street or neighborhood. We cant call ourselves part15ers but a mini radio station. Even those toy AM transmitters that were sold at Sears years ago in the Christmas wish book were called mimi radio stations. There was one that would transmit almost 1/4 mile. And so it goes that there was a double standard for part 15. But now we have our work which we hopfully will get help with from this radio group that helped LPFM to get started. Plus bow can you entertain a neighborhood when your tx goes maybe 1 or 2 houses down (C.Crane FM2). That said we need the class that canada has called announcement transmitter. This way we have an opportunity since such serive has not been denied. And in Canada its why they have 1,000 uVm. But we want something close to 2,000. It however is a start. A d what about those theater FM transmitters you can hear 2 miles out? How does this happen? I see more homework so I can pull some more tricks out of my bag. I just need to look for the weakest part of the FCC fortress.
You have called it, macdev, it's exactly an "in-between" service we are talking about.
As long as the FCC has their stated definition of Part 15 broadcasting, a low-power community service doen't match the description.
At the same time LPFM is a low power community service, but it's way more than a hobby and the filing window is closed.
The "in-between" region is a small range of field strength from the present legal level up to 1 Watt, which I think is the low end of LPFM.
The public doesn't even know they want what we hope to give them.
It's definitely going to be an uphill battle. But if it gets more information to the Part 15 community, and as a byproduct the public at large, and corrects the misinformation currently being bantered about elsewhere (such as Part 15 FM only being able to go 200 feet or you're a pirate), then it will be worthwhile.
To that end, I believe that we need to stop talking about input watts and the like. We need to get more rigorous about the goals of the initiative. Field strength is a good measure to use, as it's already there in the rules. You can achieve the same field strength if you use a lower input power and a good antenna as you can a higher power input and a bad antenna (such as a rubber duck). ERP (effective radiated power) is another good measure. Using either, you can calculate the maximum range you expect to achieve with a given radio sensitivity. And thus determine potential interference.
Increasing the range of the service is what it's all about, after all is said and done.
Does anyone know the history of Part 15 FM?
My memory thinks the allowed field strength was once much higher, then I think the FCC banned using FM for Part 15, then I think they came up with the present dinky rule.
But I am not sure of any of that.
Now that I can deal with but still we need to know the field strenth for 1 mile can anyone tell us that? It is the mysterious answer we all are waiting for. Then we can work for a way to open the doors to a new world for Radio enthusiasts. The public wants it just look at those FM transmitters around 7-30 watts. Alot more 1 Watt transmitters so it tells us the public Radio enthusiasts wants 1-2 miles to a home or portable Radio but never thought about how to go about legality. That is where we should come in. Some of us have the science and determination to achieve our goal sort of like a 12 step program. We know 10 watts is out but the sky has not fallen on Canada or New Zealand and New Zealand has a stronger field strength than Canada. This is where we strike but we need that magic number for 1 mile.
I did the math for 1000 meters above, but it more theoretical than real-world. I think we need real-world testing.
That brings me to another point - do you think the FCC would approve a 3-month experimental application?
Neil Radio8Z and I, as an assignment from the meeters at the ALPB, are delving into the rules for "experimental authority" and so far it looks like the FCC has literally removed such a category from the rules.
For one, Rule 15.7 WAS titled "Special Temporary Authority" and allowed application for experimenting in the part 15 service, but NOW that same rule is titled "RESERVED" and no longer exists.
Another section of the rules for regular broadcasters is Part 74 - "Experimental radio, auxiliary, special broadcast and other program distributional services" but despit that title all reference to "experimental" is removed from the section.
We will keep looking for a way to apply for experimental status.
Id hope they would as part of the proposal and they could have proof of non interference. Then we have physical proof they can use when the NAB starts to wine. We just need New Zealand's field strength. The math you done for that strength is a great start.