Clip from Reply 33 (should it and its replies survive in this thread) ... It may be that, while the FCC never intended to use these devices for broadcasting (much like 15.239, 219 etc.), it would be a perfectly acceptable use. ...
Absent provable FCC support for posting the clip above -- believing/suggesting that such operations are "perfectly acceptable" for that use will carry a certain amount of risk for such operators subject to FCC jurisdiction.
That doesn't really matter to me -- just offered here as a "heads-up" to those it may affect.
I said that it MAY be perfectly acceptable. The proof will be in a manufacturer obtaining certification for a whitespace transmitter. If they can meet the technical specifications, I can't see why it wouldn't be OK, given the existing rules (short of the FCC amending those rules to specifically exclude broadcast transmitters). The preamble to the rules talks about unlicensed intentional radiators, similar to Part 15.219 etc.
There is no FCC penalty for speculating about new rules.
Even holding an opinion about intent of the rules is within one's province.
Thre's no risk in it.
Rich: "That doesn't really matter to me -- just offered here as a "heads-up" to those it may affect."
You said a long time ago, you do not operate Part 15 AM/FM as a hobby or business and that you are only here as a guide to the legal portion of Part 15.
So in effect, you are our self appointed Jiminy Cricket?
If you don't care about the hobby but want to waste your time setting folks straight about the legality of each members operation then so be it.
But i see no point in it from where i sit, if you don't care about the hobby and don't even practice it, then why bother?
Confused at BBR Worldwide
1 mW on 89.7 FM because Rich said so.
BBR asked: "So in effect, you are our self appointed Jiminy Cricket?"
I said: "Very Funny BBR. But I prefer to think of him as our Resident Hobby Agent. The enforcer of rules that haven't been passed yet, what we use to call in the navy A Sea Lawyer."
"And as Artisan Radio saw they took my suggestions and made them a reality. The FCC won't care if you pump audio into a transmitter from something other than a mic. All they care about is if your causing interference. It was a way for us to bypass scrutiny from the NAB. If we said Hobby Station it would not have passed."
No, no they didn't. You had NOTHING to do with this, I recall looking at this LONG before you announced anything about the initiative.
"I'll bet Source FM (think Whole House 3.0) is on it. I'll bet it uses WiFi and Google locator (think Android) or smart cards. This WAS MY proposal. So that may be your NEW certified Transmitter for Hobby FM broadcasting. It will cover 87.1-87.9 Mhz. I talked to Brian about such a said Transmitter if it was passed."
Nope, has nothing to do with it.
In fact if you read the document you'll see it dates back to January 2010. https://apps.fcc.gov/edocs_public/attachmatch/FCC-10-16A1.pdf
Here is the FCC Q & A page for whitespace.
https://www.fcc.gov/general/white-space-database-administration-q-page#9_14_11
Many times in recorded and unrecorded history ideas occur in multiple brains with the same concusions. It is refered to as "multiple discovery" or "synchronicity" if multiple brains have the same idea at the same time.
For example: KDX Carl and I routinely draw the same concusions about the same person(s) at the same time. We are in sync.
I have seen nothing in the FCC rules or this Q & A that would not allow unlicensed 'wireless microphones' to be used for broadcasting purposes in the TV whitespace. In fact, the FCC, in their definition of wireless micrphones, states that typical uses of these devices is to broadcast to schools, movie theaters, sporting events, etc. There are no property boundary conditions while using these devices that I can find, and, if they meet the power restrictions in the rules, nothing stopping them from exceeding those boundaries and being received by the community at large beyond these venues.
Unlike Canada, the FCC does not get involved with the use of transmitters - just their technical restrictions. I can't see unlicensed broadcasters in Canada being able to use these devices unless Industry Canada amends the BETS-1 rules (under current RSS210 rules, our equivalent of Part 15, we're not allowed to broadcast).
Unlicensed broadcasters would just have to use whitespace certified devices.
Looking for clues at the scene of the crime.
I have been in touch with the FCC today, first call was about my Restricted Radio Telephone operator permit. There was no record of it in their ULS Database and I was informed I will have to apply for a new license.
Also I asked about a GMRS license which i may get sometime this year.
After speaking with a very helpful lady at the FCC ULS dept, i sent an email to the Audio Division asking for a simple outline of what we can and cannot do with the new TV White Spaces under Part 15. I asked what was allowed, what was not allowed.
Can we experient there just the same as we do on any other part 15 service?
I asked for all the of the frequencies not just 82 - 88 Mhz, if I get a real response to all of these question's i will pass those answers on to this forum, until then we wait.
Barry of BBR Worldwide
Thank you BBR.
Nothing heard yet from the FCC.
Meanwhile i have been doing research for obtaining an experimental license to test 1 watt and 100 mW into a 15 meter (50 foot antenna) compete with ground radials.
I would like to test this on 1710 Khz to void possible interference on the AM broadcast band 530 to 1700 Khz. The license fee is $65 and a lot of important technical details must be obtained before filing for an application.
At this point, i am in the research stages, but i would like to use the information gathered from the testing to petition the fcc for a change in the rules for the AM band under Part 15.
Barry of BBR WorldWide
Thelegacy is already working a petition and I'm still waiting to see some actual petition being given to the FCC as this has been talked about for so long.
Mark
The FCC looks for hard evidence, charts and graphs, mathmatics, reasons why we think the FCC should take us serious. I feel a test and a legal one at that will get their attention.
If nothing else, i will learn for my own benifit by operating legally under an experimental license and yes i am aware of TheLegacy's work, but nothing says there can't be another petition out there, or that i won't share my findings.
I am not an unreasonable person. I have morals, respect but I also want the same thing, a change. A change in the rules that are outdated, rules that have not been upgraded for 2016 and beyond.
There are other countries that have totally abandoned AM in favor of internet radio and digital FM, they turned those AM services over to the public and municapalities on a first come, first serve basis and it works well for them.
Other countries have just abandoned AM (medium wave) only to leave it to rot.
The FCC see's probably 100's of petitions a month, some are thrown in the trash and others are piled up on a desk awaiting to be reviewed.
Even after the FCC reviews a petition they also have to make a decision, will it fly or will it die? Thats where the public comments come into play, and we have seen what public comments can do, they can either make or break a great idea.
Barry of BBR WorldWide