First, I want to thank all of you who have taken the time to sign my petition urging the FCC to institute a Low Power AM Radio Service.
I also appreciate the supportive comments many of you left below your "signature." We now have 50 signers, which is considerably less than I had hoped. But I suppose such results can be expected for what is, at this point in history, a specialized area of interest.
Through various on-line discussions prompted by the petition, I have come to see the need for a companion petition urging the FCC to increase the legal limit of unlicensed "intentional radiators" (at least in the AM band) to 1 watt with no limits on the height or size of the ground system to which the transmitter's ground lead connects. I chose 1 watt because I think it is enough of a power increase to make Part 15 broadcasting viable, but not enough to send up red flags with the NAB, NPR, and other big entrenched broadcast interests. I am also avoiding a proposed Part 15 increase on FM because I'm afraid that any increase in that band would send up red flags. However, if you disagree with my assessment of these situations, let me know.
At 1 watt, a Part 15 broadcaster may still need multiple transmitters to have a sustainable operation, but not as many as needed under current rules. Furthermore, as long as they play it smart, unlicensed Part 15 operators will remain totally outside the reach of the FCC's restrictive umbrella, dictated by a Congress of millionaire and billionaire lobbyist shills who have no idea what we ordinary people suffer on a day to day basis. Part 15 operators can continue to choose between commercial and non-commercial operation and go on the air whenever they are ready.
I have been assured by at least one LPAM petition signing "holdout" that they will support this kind of a Part 15 petition.
I would like to mention the following as well in the petition text:
1) The expanded AM band (1610 - 1710) would be the preferred place for this enhanced unlicensed service (antenna efficiency, less interference, etc.) but not mandatory. In crowded urban areas, if the expanded AM band gets filled entirely, an available old line AM frequency can be used.
2) The frequency of 1710 kHz should be set aside exclusively for Part 15 broadcasting.
3) Current Part 15 antenna rules can remain in effect (with external loading coils continuing to be okay within the total 3 meter length), but the language in Part 15.219 must be clarified so that the ground LEAD ONLY is measured as part of the 3 meter length. The actual height and size of the ground system itself should be of NO CONCERN to the FCC as long as the operation is not causing objectionable interference or breaking other rules. (So, in other words, if an aspiring Part 15 broadcaster in midtown Manhattan installs their 1 watt antenna and transmitter atop a 50-story skyscraper, with the ground lead connected to the skyscraper's electrical system or steel support structure, and everything else is legal, there is nothing the FCC or an established licensed broadcaster can do about it!)
4) This is a novel idea that occurred to me over the past day or so. I am considering a section of the petition that would urge the FCC to raise the power limit of unlicensed Part 15 operation in the shortwave broadcast bands to 10 watts. As most of you are aware, ever since the major European government broadcasters abandon them several years back, the shortwave bands have been starkly empty, especially compared to 15 or 20 years ago. Currently, the future of shortwave broadcasting looks even more bleak than standard AM (medium wave). Increasing Part 15 participation in the shortwave spectrum may be the shot in the arm this service needs.
10 watts is enough power to enable skywave propagation. Even in the expanded band, from my post here in north central Massachusetts, I've been able to log 10 watt TIS stations from New York, New Jersey, and Pennsylvania at night, and that's with some interference from other stations. Imagine the range 10 watts would have on shortwave at certain times of the day with no interference. Part 15 AM broadcasters who simulcast on shortwave may be able to increase their notoriety within a two or three state radius, which may result in increased listening to their web streams during periods when the shortwave signal is weak. I'm not sure if international agreements would be effected at this power level, and frequencies allotted to amateur, aviation, and other two way communication should be strictly banned from Part 15 broadcast use. But this may be something worth pursuing. Should shortwave be included in a Part 15 petition? Or will it needlessly complicate the effort.
I am interested in your input about any of these proposed sections of the upcoming petition. I am hoping that when both petitions have run their course, I can submit a formal docket to the FCC, complete with many of your notable comments, urging them to make these changes. An appropriate forum for this would have been to file comments on the FCC's Revitalization of the AM Radio Service, Docket #13-249. But it appears that March was the last month for which they were accepting comments from the public. So another forum will need to be found.
Thanks again in your interest in radio for people of ordinary means. If you are reading this on a blog, please contact me directly, as there is no assurance that I will get around to visiting the forums and reading your message there.
Jeffrey Gill
Minimum Wage Media
I don't think that you'll find many people who don't support increasing Part 15 power levels on AM (not going after FM is a good idea) and clarification of the rules is also essential. I really like the suggestion of using the shortwave bands, as they are vitually empty.
However, I would recommend formatting your post a little better - it looks at first glance as one run-on sentence (it isn't - it's actually well written) but it's rather daunting to start reading. I almost didn't.
The time seems right to open a movement to allow greater use of bands that are admittedly going out of popularity (AM-medium wave) and out of use (shortwave).
1 Watt seems very reasonable for the extended AM band, and 1710 kHz would be very useful for Part 15 use.
At present the range from 1710-1800 kHz is used for beacons and navigational aids, but such use must be very small because no one I know every encounters any traffic when scanning that range. It would probably hinder no one to allow Part 15 on 1710 kHz.
Shortwave has gotten even quieter with a decision by the Broadcasting Board of Governors to end Radio Liberty, Radio Free Europe, Radio Free Asia and VOA English broadcasts. Source: PCJ Media:
10 Watts seems very generous as a proposed Part 15 limit for shortwave. Perhaps the ALPB Members will explore this subject on Saturday night at the next Meeting.
As alluded to, the political powers-that-be are the anti-hobbyists and anti-freedom crowd who want to get all the money and own the audience, so this kind of talk will earn their enemyship. Some of them are so constipated they would like to do-away with the dribble of micro-power now allowed for Part 15.
But they obviously aren't competent or AM and shortwave wouldn't be failing.
As you develop this be aware that some justification will likely be needed for proposed technical changes. From a technical perspective and ignoring possible objections from broadcasters/groups the choice of power limit and antenna/ground lengths need be based on something.
One watt sounds good but linearly extrapolating the range increase would be about 3 times that of a 100 mW level. This would represent a 10x increase in area.
Also consider that the ground lead length has a marked effect on signal strength. What limit could be acceptable to the FCC? Is it possible to know this so it can be addressed?
This is not meant to discourage you and others but I believe these topics will need to be carefully prepared for a petition so as to be realistic.
Neil
I agree and support more power on part 15 unlicenced broadcasting and I will sign a petition....even though I am in Canada and therefore it wouldn't mean much. But I think the FM band should be included in a petition. In the US the legal fm power is so low that it's almost useless. FM is so much simpler to transmit and has high fidelity audio and doesn't need a whole elaborate outdoor set-up. But 1 watt AM transmitter power could, from an indoor 10 foot wire, get to the neighbourhood from your bedroom and more people could do this without loading coils, ground radials, and property to be able to do this.
The FM could at the very least go to what it is here...1000uV a meter at 3 meters.
New Zealand, has a good system....you're allowed 1 watt of power on(I believe) AM and FM unlicenced as long as you cause no interference.
But, you know the big corporations that own most of the radio stations also run the gov't.
In today's edition of Radio World is a Commentary by Don Schellhardt titled LOW-POWER RADIO IS INCOMPLETE.
Mr. Schellhardt talks about LPAM and LPFM, but I will quote the section on LPAM:
"Low-power AM: Last decade, in response to a Petition for Rulemaking by the Amherst Alliance, The LPAM Network and others, the Commission opened Docket RM-11287. Public comments were sought, and received, on possible licensing of low-power AM stations. Ultimately, however, the petition was neither granted nor rejected.
"Now, however, the FCC is considering Docket 13-249, proposals for revitalization of the AM band. In this proceeding, reopening of Docket RM-11287 has been urged by Nick Leggett, William Walker, president of the LPAM Network (lpam.net) and me.
All of us endorsed an April 28, 2006 proposal in Docket RM-11287, reflecting a consensus of LPAM advocates at the time, which would pattern AMs after the 10-watt Traveler's Information Stations... Jim Potter of Missouri proposed LPAMs of 150 t0 300-watts."
William Walker, noted in the article, was the guest on Low Power Hour No. 1 and is a long time Part 15 enthusiast.
I for one, really enjoy the idea of 10 watts on SW! It's about time we re-vamp the shortwaves with some good programming again! Plus- I had done an experiment with a 4 watt CB transmitter on AM and was heard over 800 miles away! So, this goes to show you that propagation is the damndest thing. As for the AM increase, I also agree with that proposal. But I do feel adding FM in there might jsut be asking for too much. The FCC is extremely tricky and must be dealt with the upmost amount of scrutiny. The problem is actually getting people to sign this. If the FCC was to actually even bat an eye at the proposal, I feel like we'd need at least 500 signatures. Only getting 50 is a good start, but is about as much impact to the FCC as is stepping on a small twig. They don't give a rat's ass until we get at least 500. To really actually get in their face, we'd need over 1,000 without a doubt.
