FM Manifesto 2

Sure hope you can get changes you are seeking.....seems well written on the part about having a better way for user compliance and being certified should mean the manufacturer, not the end user should be responsible, but on the area of increasing the allowable signal strength I think you need a more compelling argument for increasing to BETS-1 levels or adding another classification like Canada has to allow 4x the current rule.

Hope you can get positive results....don't give up!

Mark

Absolutely, Mark, the thing we lack, and all of us who have talked about the FM Initiative know it, is a strong argument to present to the FCC to convince them an upgrade would be worthwhile.

Keep your input coming, you might be just the person who comes up with the missing justification which we need.

We all know and believe the signal increase should happen, but we're stumped on how we can convince federal ears.

"... being certified should mean the manufacturer, not the end user should be responsible ..."

Might the issue here be related to the fact that the manufacturer cannot control the installation of that device, which installation and degree of compliance may vary considerably from that of the configuration used for Part 15 certification of that device?

That's one factor, yes.

This doesn't really relate to part 15 FM broadcasting but case in point on how a manufacturer could make it rather hard to breat the rules without SHEER BLATANT WILL!! Walmart sold a pair of Bell South FRS Walkie Talkie's. They had a molded into the Walkie Talkie's a plastic antenna that looked like a rubber duck that in order to remove you'd have to physically cut and solder a longer antenna onto the Radio and that would mean that you would have to re manufacture the mold itself. It would be a huge deterrent as most likely your going to break the delicate parts on the PC board and it would not be worth the experiment to see what a longer antenna would do. The FM Transmitter could like a cell phone have a sealed metal case that the user COULD NOT open to solder a new antenna onto to begin with. Also lets talk about harmonics. The Whole House 2.0 (Per Carl Blare) was a spectral nightmare on a spectrum analyzer. The manufacturers should be liable for the junk these transmitters are spewing out into the airwaves. That SainSonic transmitter is another example. It should not matter that I had it 4 months the manufacturer is at fault for the poor filtering that fails to function after a short time. The filter should last longer than the life of the transmitter itself. Users often are not like me and over cautious when operating. The filters need to be 7 pole filters period. If the transmitter is found to present harmonics the manufacturer needs a RECALL and the user is either given another transmitter or their money back. I don't subscribe to the thought that a manufacturer can't prevent abuse. Even if the antenna has to have a chip installed like keys to a car it can be done or at least give a little effort.

Carl...

In my opinion the only way to get the FCC to listen about increasing FM signal strength is to try to write a well written document on the reason for the need of a different classification such as Canada has for "announcements" such as selling houses, garage sales, getting a radio signal to a parking lot advertising a store sale, businesses getting a signal to a local neighbourhood, drive-in movies  etc. and why FM is needed rather than AM. State some of the drawbacks of AM. It can be suggested that the highest frequency for this is not past 100 mhz if you are within a mile of an airport and only a certified transmitter can be used, and certification means tested for no harmonics and spurs.

And you can't have anything political, religous, pusuing an agenda, swearing racizm etc.

Other than that, no program restrictions.

Maybe you can mention that if there was a little relaxing of the rule and Canada's signal strength were allowed there there would be much more compliance and less pirating.

But how you construct the document is just as important as what you want...has to be worded right.

I started by saying getting the FCC to listen.....may not get them to change anything though. But the saying goes....better to try and be regected then never try at all.

An election is coming next year but in the US don't they campain a whole year? Approch your congress people running and present this to them.....they listen to people at election time.

Mark

Ultimately the FM Initiative will be in the hands of those in the leadership of the FM Initiative Project, which I think includes TheLegacy, MrBruce and various others.

My role is one who is supportive in principle because I think Part 15 users deserve a better slice of FM than is currently allowed.

My own usage of AM & FM is very confined to a limited area and I have no personal interest in "serving neighbors" with radio they aren't looking for, but I can understanding wanting to have some reach for many who want to share music and ideas.

I appreciate thoughts and suggestions from Mark and others about how the Initiative can best be written and presented, and agree with the commercial uses mentioned, i.e., real estate, yard sales, auto parking lots, a lot of such uses.

I can't agree with arbitrarilly disposing of free speech in the belief that will somehow appease the FCC. None of us that I know of want hate speech or inappropriate content, but commenting on politics or pimping a religion is an American right, as objectionable as some of it can be. I'm not sure why Canada is so tight-sphinctered about certain speech on small radio stations.

Keep generating the ideas, they will be useful to the Initiative guys.

Putting compliance on the manufacturer would be just about impossible.  Compliance has to fall on the end user, there are too many variables the manufacturer would have no control over.  If I had a FM transmitter box that I knew I could not get in trouble with no matter how crazy I got with it, as long as I did not open it, I would figure out the direction I wanted most of my signal to go in, put a reflector a half wavelength from the box in the opposite direction, and get a dB or two if increased field strength in my desired direction.  Then if the FCC came and found the install out of compliance, they would probably go after the manufacturer.  I would guess the end result being manufacturers would figure out the most gain that could be coaxed out of their FM transmitter boxes by crazy end users with creative mounting, parasitic elements, reflectors, and other things that change the RF directionality of the signal without modifying the certified box.  Then the manufacturer would reduce the output by that amount to ensure compliance not matter what. 

Also, how any change to the rules affects the public good should be addressed to make a compelling argument for the FCC to take the suggestion seriously.  Other than people who want to run a small FM signal as a hobby, who benefits from new rules?  On the other hand, who could be harmed?  Some sense of how the proposal would increase the noise floor on the FM band would need to be presented; it would probably be negligible compared to what HD radio did to the FM noise floor (since HD radio got through, that would be a compelling argument for the increased unlicensed signal proposal).  Also with the increased range what would stop commercial broadcasters from putting an unlicensed transmitter in a targeted community and feeding it with a HD2; things like that need to be covered.  (There are licensed broadcasters using optimized 15.219 setups to reach communities.)

I think if serious progress wants to be made on an unlicensed FM power increase, the work the UHF white space people did needs to be looked at.  In my opinion It would be much easier for a reputable manufacturer to convince the FCC to allow a waiver of part 15 emission rules for a specific product containing a GPS receiver and internet connection to verify an open FM frequency and a FM transmitter that uses variable power to will put out as much power as possible while not interfering with any licensed station’s signals than to ask the FCC for a blanket rewrite of 15.239/15.209.  That would require a manufacturer wanting to produce such a product.

As a PR side note, manifesto is a poor word choice.  Even if that gets changed, someone who wants to detract from any proposal can find that wording in a search engine cache, way-back-machine, or may have a screen capture of it to pull out later.  Government bodies tend to feel threatened by manifestos.

It is entirely possible to increase field strength and not impact licensed broadcasters.  At the same time, there is a lack of public knowledge on what makes someone pirate vs a legal unlicensed transmitter operating under part 15.  If a part 15 increase happened and people started hearing new stations they though were pirates the resulting law enforcement actions may be a PR nightmare for the part 15 community. 

"Entropy" is the name for the natural tendency of things to become disorganized. The statements made in this thread have skewed and become disorganized.

It all relates back to Post # 4 when Rich quoted from an earlier statement without giving attribution: "...being certified should mean the manufacturer, not the end user should be responsible..."

In not attributing the quote the false appearance is given (perhaps unintentionally) that Carl's (my) FM Manifesto 2 had said the words. I even got fooled and went over my own words looking for the quote, not finding it. Turns out it's from Mark's Post # 2, taken somewhat out of context.

From that point on a wrong notion became implanted in the ensuing discourse.

Here is what the original Manifesto says, put in fresh language: Tim in Bovey has shown with valid field tests that two prominent certified transmitters have RF power levels far higher than 15.239 allows. At the stage of cerification the manufacturer IS responsible for compliance, but Tim's findings show that at least two manufacturers cannot be trusted, which places the end user in innocent violation of 15.239 with no means of finding the error on his own.

Given the scenario that certifications are untrustable, the end result of FCC rule 15.239 is that the user is placed in possible violation, framed as it were, by both irresponsible manufacturers and an FCC that has failed to provide reasonable means for user compliance.

Oh, and stvcmty has come through with some good ideas, but never explained why "Manifesto is a poor word choice." Here's what I think is meant:

The word manifesto has been tainted by its Orwellian application in security speak. In its pure form manifesto simply means "a public declaration of principles, policies, or intentions..."

Other words have been contaminated by federal misuse. For example you wouldn't say you are broadcasting from a "compound," or you'd have the appearance of being a pirate stronghold subject to annihilation.

I used "manifesto" on purpose knowing it has a shock value thanks to Homesick Security, but stvcmty wins the day because we'll change it to something "friendlier," maybe "Easter Basket," I don't know, suggestions welcome.

Mr Blare stated in Reply 10: It all relates back to Post #4 when Rich quoted from an earlier statement without giving attribution: "...

The attribution for my quote "... being certified should mean the manufacturer, not the end user should be responsible ..." was given by/on the subject line of my post as "Reply 2" -- which is the post containing that original text.

Perhaps that went unnoticed?

"Reply 2" was taken to mean "The 2nd Reply."

Post # 2 would be referred to as "Post # 2.

Mr Blare wrote in Reply 12 above about the subject line of Reply 4 of this thread: "Reply 2" was taken to mean "The 2nd Reply."

And so it was.

However Reply 4 here was not my 2nd reply in this thread, it was my 1st reply in this thread -- as a careful review will prove.

Oh, ya, but... you were the 2nd reply overall.

Insult my reading comprehension and I'll recite the Part 15(Dot) US Rules to prove that I can read.

Anyway, it's fortunate you came along because we would like your input regarding the FM Initiative. As we have been saying, we believe it would be fair and reasonable to propose and promote a small increase in the field strength under 15.239, along with an actually achievable way for the hobby-user to verify their own compliance with whatever the rule is, current or increased.

As a veteren of domestic broadcasting, tell us how to do it.

Because the FM Manifesto Parts 1 & 2 is an active part of the ongoing FM Initiative, I have unburied Part 1 from deep in the forums and linked it here:

http://alpb.boards.net/thread/193/fm-manifesto-1