From a poster over at my forums - FCC LPAM Petition

Very nice piece of work on the part of your Poster at your forums site, Part15Engineer!

This document contains many well considered proposals and topped off by a few unique inventions which are backward compatible to our part 15 use, so this is worth reading for everyone here.

Looks Great,
there are a few typos towards the end but the execution and technical details are covered very well.

Will do here to, well written. As I commented before unlike another "initiative" where almost 2 years of we are asking for this and that and never seeing anything actually done, it's nice to see a real initiative being taken here for change.

It mentions a license even though it's not for a business and is still considered hobby so the license I guess would have to be obtainable and affordable?

Mark

I am encouraged that a responsible party has formulated this petition and there is much to be considered, however, the technical presentation focuses too much on specifications rather than standards.  For example, the entire section detailing and encouraging codification of specific negative peak limiting could be replaced with "a means to prevent negative peak modulation (clipping) shall be incorporated".  It is known to those practiced in the art that there are many ways to accomplish this and it is not necessary to specify a particular method.

It reads as if it is an extension of Part 15 when it is actually a new radio service not related to Part 15 rules which govern unlicensed operations.  The references toward the end to changing Part 15 rules re antenna and transmission line and maybe power leave the impression that if the high power proposal is not accepted then at least these could be approved.  Proposed changes to Part 15 rules should be a separate petition, not tacked on as an afterthought..

Too much specific techncial restraints and methods are presented with the implication that they need to be used for "type acceptance".  I especially dislike the reference to "proprietary" methods cited for modulation control. 

The rationale for the new service is admirable but the petition contains too many stated technical restrictions, again, standards need be preferred over specifications.

When negotiating, one does not start with what one is willing to accept and this may be the outcome of this petition.

Yes, It is a good start but I believe it is flawed.

Neil

Aside from the grammar and spelling errors I have a beef with the fact this petition makes it almost impractical or impossible for a budding low powered hobby station wanting to cover say 5 miles (North, East, West, South) with your transmitter in the middle. I'll go into some of my issues and this is a copy paste of what I wrote in the public section of The New Radio Revolution site:

(1) it absolutely screws apartment dwellers. If you live on the 15th floor of a building and want to set up a community hobby station this proposal puts an end to this. (Why rejoice in something that will ream fellow hobby broadcasters in the butt).

(2) The proposal mentions that the coax MUST be buried to stop radiation and again this helps range. This you can tell was written by a radio broadcaster who probably works for an NAB affiliate and thus wants to put a kibosh to the hobby Radio operator.

(3) The proposal prevents a quick emergency set up due to the huge elaborate ground radial requirements.

(4) The proposal prevents a simple 8 Ft ground rod set up. Remember it talks about 30 ground radials at a precise wavelength that itself kills that.

(5) Telling the FCC they have the right to charge whatever they very well want is an open invite for them to charge steep and non affordable fees to the hobby individual clearing the way for only the rich to operate.

(6) Making a limit to only one station stops any possible future development of say an FM hobby station for that individual should one ever exist in the future. Again this was well thought of to KEEP the hobby operator from FM.

(7) because of these kibosh's to the hobby Radio operator on this service don't think you part 15ers will get away willy nilly either because the FCC may make stiffer requirements to you as well.

(8) The mention of part 15 (how many times do we have to tell you that the FCC said NOT to even mention part 15 in the petition)? Obviously certain folks don't listen to what our research has taken us.

(9) If the transmitter already has a modulation limiter similar to what is used in CB transmitters and Ham units why require an expensive O scope to be always in line? Again this raises the price BIG TIME and you guys complain that I wanted to have the FM transmitter scan first to make sure the frequency is blank? Yes I understand this would help to prevent interference but again this leaves things super wide open.

(10) Nothing was mentioned about certification of the transmitter itself or rather kits would be allowed. The agent is free to go willy nilly and ban you because he sees your transmitter was not certified and approved before manufactured and thus put on air.

(11) A starter station must start at a 6 meter antenna and then later after 6 month reapply for an extended antenna. Again this could cost you another 100K if the FCC chose to charge 100K for the application in the first place.

(12) This will not might cause more folks to say bump it and just run Pirate because this petition was not well thought of and did NOT take other groups in consideration before posting to the FCC. This was obviously a one-sided decision making process by a group who again had an elite access only which is exactly what we did only thing was we published our group and offered our access to those who was serious about the hobby. This petition does not have a hobby broadcasting friendly feel to it at all.

So before rejoicing because they done theirs before us you best read and let it sink in all the stipulations these folks are imposing upon all of you. This petition was a very one-sided way to squash Hobby Broadcasting (Legally that is).

Some more thoughts.  The petition DID suggest MORE (Not Less) restrictions for part 15.  And it was not well thought of wnen asking for more power.  The petition as it was written could even end a person from being legally able to run a Talking House AM transmitter on the wire.

Our group was working hard and it was only 2 of us writing the petition as many folks did not help us but rather complained that we had an elite section on our site.  This Yahoo Group was much in the same way as it was not well known this group ever existed.  For if it did I'd been the first one to say NAY to this proposal.

I hope Dan Braverman see's this and goes off his rocker on this in a fit of Rage.  I"ve already told Atrain and he was not happy at all either.  So expect some serious resistance to this one.

At least our group had everyone and their living situation thought of and we were not one-sided.  This one is only for those who own their own property and in no way a part of a HOA.  This also shows how the hobby community does NOT work well with each other and rather is self minded in thought.  Putting Down our group is no way to be of any assistance.

TheLegacy said:  "Our group was working hard and it was only 2 of us writing the petition as many folks did not help us."

That's not the way I remember it.

I recall that Artisan Radio and others were available to work with you, but all of their ideas were bypassed and the only people making decisions were the "2 of you in your group".

I put a lot of ideas and suggestions in the forums with permission for you to use any of them, but when your Initiative Website went online I wondered "where are all my ideas?" I asked you about it.

You told me I was welcome to re-submit everything I'd said.

You were inviting input but ignoring the input and never taking any advice.

That's what I remember.

That was not how it went:Here is what really went down and that was we were doing quite well with the petition when it was a sub section of the ALPB.  Suddenly there was a question about an individual I had to look into their background as they too were a member of a questionable website that has been well known to be unfriendly towards part 15 and even accused and narced on some people. so I was not sure about granting them Elite Access.

I have to give Atrain credit as well however as he worked hard until he was busy with his band, School, Real Life.  We had tried to contact Promethous for help as well as Alan Weiner because they were very activist people.

When it came to BETS-1Our group rejected that and we posted why.  And again it was all about increasing part 15 AM and little to no efforts were invested on FM!  Again it was clear that we were a PRO FM group (My Vision From The Start) not forgetting AM but that we wanted PRO FM minded folks to have Elite access.

87.1-87.9 MhzThis was our focus to get these frequencies legal for low powered Hobby Broadcasting.  Station8 had the guts to call and ask for the Office Of Engineering and Technology department (OET) while others questioned as to if we were liars.  An agent spoke with Station8 and advised NOT to mess with part 15(while others disregarded that.  Suggestions about going off air after 6PM due to temperature inversions WAS aknowledged by the agent as a great idea.

Harassing Emails sent to would be membersurging them not to be a part of our group because of would be intent from our group.  This was talked about in the forums from some of our members (Nice Try).

Complete ApathyMore bulking and negitive comments after Station8 mentioned he had some personal issues and could not do anymore work on the petition till his life was straight.  Yes suffice it to say some have other things in life to tend to (what a sin).  So now there was only ONE pro FMer to work on the petition.  AM was again a part of the petition in which was clearly posted in the Elite Section.  We even talked about top hats as Mighty 1650 wanted and even mentioned that in a post to clearly show WE LISTEN and in public with his handle.

More apathy and no respect from many individuals as more talk about what we will not do.  Yes I'd like to have put the petition out within 1 week after site opening.  We see how this petition will do that was published to the FCC.

Will we fix what was damaged?It will take a mericle from God and honestly I have to ask myself why should The New Radio Revolution care what folks who only want to Flycast think?  I mean look at how we're treated from the first day the group was invented.

Our group should (If we continue) be more Elite and underhanded than ever before and at no warning post OUR version of the petition while paying someone to check spelling and format (which can come from donations from My Internet station who want real range for Hobby Radio).  BEWARE Progressive Rockers are like an Elite Cult and we stick together.  It is quite clear some folks only wanted to laugh at the notion of any idea we had.  So I do think some sort of immediate reaction is in order to show we mean what we say.  Indeed some of us in the NRR are more than irate and we feel some want to wage a WAR and making our petition 100% perfect will be the nuclear bomb to end it.  Getting 100K to bribe the FCC should not be hard if I were to make a promo on my station and after the money is in we'll have clout and could get what we want.

We could be the loose cannon and publish our 100% no error petition to the FCC in hours!!

'

TheLegacy posted:  "Getting 100K to bribe the FCC should not be hard if I were to make a promo on my station and after the money is in we'll have clout and could get what we want."

Bribing government officials is a federal crime and we DO NOT want you to get arrested in a cage!

I'll tell you who to bribe.

Bribe me!

I guess I didn't realize it was a crime since its done all the time.  Scrap that idea.  Still donations to get a lawyer isn't a crime.

It's done off the books. No records are kept. It is "deniable".

Knowing what I know makes me a "conspiracy theorist" which is shorthand for saying "He doesn't know what he's talking about".

On the other hand bribing me is legal.

... We could be the loose cannon and publish our 100% no error petition to the FCC in hours!!

If you are confident that your petition is error-free in grammar, construction, technical content including the proof thereof, and more likely than other petitions to be accepted by the FCC -- then why not submit it to the FCC in the next day or so?

Blaming others for the lack of progress in the NRR submitting a petition isn't going to win fans and influence people.

And that's all I'm going to say about that.

Who is this mystery agent?