OK, here is some direction on how you can write your petition to the FCC. Below is phrasing for a similar service from a old RecNet LPFM comment filed back in 2004.
"PART 15 BROADCASTING
In addition to the licensed services that we have discussed, we feel that the FCC should revisit the current Part 15 rules on low power devices in the bands 525-1705 kHz and 88-108 MHz.
Currently, there are a small number of "part 15" broadcast stations. These stations, mostly on AM, provide local news, views and information. Because of the current 100 mw limitation on these stations, their coverage areas are extremely limited. REC feels that these operations be expanded on AM to allow for up to a 500 mw to 1 watt power limit. This will allow these stations to serve their very localized neighborhoods and not interfere with full power broadcasters.
On FM, we would like to see a process to allow for increased field strengths when the transmitter and antenna is fully enclosed in a building and that the signal that radiates outside the building meets certain field strength guidelines. This will allow for organizations to be able to do in- house broadcasting using regular radio equipment. Applications can include conventions and sports arenas. For FM, we are proposing no changes to field strengths on antennas located outside."
Modify and expand it to your heart's content. You might want to mention that part 15 can play a similar role as hams in times of emergency. In reality, most people don't have amateur band receivers but they do have AM/FM radios. When an emergency strikes, part 15 can re-broadcast ham broadcasts to local residents.
Artisan Radio, Carl Carmine just gave us some Very useful information we can use for the petition. Why it was never started is beyond me. But we have a really good base foundation now we just need to put in the missing pieces. What are your takes? Any takers now?
What Carmine posted is of no use to us because there's no link to the original document.
The short excerpt doesn't give us context... such as explaining why part 15 was mentioned in connection with LPFM.
I'll play with google and google certain phrases of the document and the correct combo should give the link. Its intense but can be found if we keep doing it. Carl I think we may be getting closer but its still going to take some time and patience. As long as we have the interest and we keep at it we'll have a workable solution coming.
While I appreciate Carmine taking an interest in the petition, I simply don't agree with a lot of his premises. And the structure of the petition was never going to be an issue - there are plenty of examples out there. I'm not sure why everyone is focusing on that - it's the ideas that are more important.
Here's my 2 cents (perhaps what it's worth).
I don't believe that you should mix Part 15 AM and FM in the same petition.
I'm also not sure that proposing Part 15 AM increase to 1/2 - 1 watt is really necessary. It would be easier and simpler just to remove the antenna and ground restrictions (or even just the ground wire restriction), but keep input to 100 mw. However, we really don't know the impact of either proposal. Looking at Part 15 AM in the context of this petition is opening up another can of worms, when one can (FM) appears to be more than sufficient. Besides, 1 mile+ for Part 15 AM as it is currently is already useable. It's FM that has miniscule range.
I also don't believe that proposing a change to FM field strengths for transmitters with inside antennas only is workable. Are you going to have two levels of certified transmitters? It just seems overly complicated to me. If you really want to provide FM service within buildings or large private properties, wouldn't it be better to change the rules to allow a certain level of field strength at property boundaries (but whatever is necessary inside those boundaries)? And the discussion certainly didn't start out with that intent only - I thought the goal was to increase broadcasting range period. Has that changed now?
I'll repeat something that I said earlier that I believe is really important if you want to get anything done, and have a chance at acceptance. It's got to be kept really simple and straightforward (i.e., the KISS principle). It's got to be easy to understand, and easy to defend (the two go hand in hand). And at the end of the day, if the FCC says NO, at least you've given it your best shot.
P.S. I don't understand theLegacy's comment about him not understanding why this thing hasn't been started. By whom? Someone has to take the bull by the horns and take charge. I know that a few nominated me earlier on (maybe seriously, maybe not), but that doesn't make a lot of sense, given that I'm not even located in the U.S. I will help, and give my opinions and such, but this has got to be driven by those who are most affected.
Yes I think range is what we are after. AM could do better without the 3 meter ground and antenna rule and keep the 100mW output the way it is. You can do very well with 80 feet of wire and a ground from earth to the second floor of the house. Imagine the range from say a Talking House AM Transmitter on 80-100 Ft of wire.
The reason I concentrate on FM for now is that our signals are not likely to penetrate a building even made of wood or brick at more than 80 feet from your property. With the 1,000 uVm @ 3 meters your looking at around 2,000 feet and a building may cut it to just less than 1,000 Ft. This can get you a nice neighborhood signal range.
Thelegacy wrote: The reason I concentrate on FM for now is that our signals are not likely to penetrate a building even made of wood or brick at more than 80 feet from your property.
The measurements taken and reported in Reply 3 of the thread linked below show that a weak FM station has essentially the same signal strength inside a wood/brick home as just outside it.
Duplicate post, deleted by author.
My nomination of Artisan as project leader is (was) serious, and it holds true now... although the point about not being a subject of FCC rules (in Canada) is understood.
If we are without a project leader perhaps we could take an example from the NBC Symphony Orchestra which was brought to prominence in the 1950s under its leader Arturo Toscanini. On his death, the Orchestra performed a final concert without a conductor as both a trubute to Toscanini and to what a professional orchestra he'd formed.
We can be a leaderless cause... a well formed group (the ALPB) working as its own leader. A committee.
Many of you have missed what I said at the beginning. Those were not my words. It was a "copy and paste" from reply comments filed by RecNet in 2003 for RM-10803. The proposed rulemaking was in connection with the creation of a localism task force. RecNet pitched LPFM and other forms of broadcast "localism", including part 15. It's a pdf file titled, "rm-10803." You may still find the file on the RecNet site. I downloaded it several years ago.
Like I said, you can use those words, change them to suit your needs or reject them. It makes no difference to me. But if you're looking for a starting point, that's as good a place as any.
RecNet's post is a good starting point to build a petition as a good building block for a solid foundation for the petition. Plus a non partial leader or project manager is a plus for he or she is not emotional one way or the other about the results. This could be a plus too if someone wanted to argue a point that the leader or project manager was biased in any way shape or form. Where as I for example may get more emotional when hit with a barrage of anti establishment from the opposition. He be less likely to blow his top than a partial leader with their own wants and needs to be met. A non partial leader or project manager would have a clear head which would get more done. Just something I had to think rationally about. Plus being he's from Canada people may ask him how the higher power on FM has effected his country and that too could be a plus when you want to make a comparison between the two as a reason to change. And the subject of Pirate Radio may come up. He could demonstrate the lack of Pirates in Canada as another tool to throw in as well. Its really not a silly idea at all. You've seen how my emotions can get the best of me so why not try Artisan Radio? I'm still going to fight and be a part of the think tank too, but he's had experience with AM as well where as I have only had little several years ago with a real toy.
I agree with what you wrote, TheLegacy.
I continue to believe that Artisan Radio would give the Pro FM Initiative an impartial director, and I am no less certain of that with the current questions about BETS-1.
Artisan did exactly what a trustworthy leader should do, he shared the dicrepencies and confusions about BETS-1 at the same time he encountered them.
It is also true that being outside the Homeland (formerly the U.S.) Artisan has nothing at stake with Part 15 rules, and although we might call that impartiality, it could as easily excuse detachment.
Perhaps the most bewildering fact about what we're going through is the lack of numbers... people with an active interest in improving the state of Part 15 FM. We can't help but notice that most forum members have expressed no viewpoint either pro or con.
Using the word "activist" again, I notice that the greatest majority of Part 15 operators and hobbyists in the states do not participate here at part15(dot)us... they are "inactive."
We have one member who's spoken against us there and speaks supportively here.
The main theme detected at the other site is that we are spinning our wheels and will fail, which disqualifies them as members we'd want, but gives a perverse sort of negative whisper which enters the experience.