Well, there are 2 parts to this. Writing the petition, and then selling it (i.e., getting support, presenting it to the FCC or whomever is in charge of the spectrum involved, etc.). Getting political bigwigs involved is part of the selling, which you can't do unless you have something to sell.
As for Hobbybroadcaster, somehow I can't see Bill DeFelice and company getting involved in just a supporting role.
Snickers have floated around claiming that experimenting with part 15 transmitters above posted power levels during trial periods in search of future requested rule changes is piracy and illegal. This is false.
§ 2.805 Operation of radio frequency devices prior to equipment authorization. (a) General rule. A radio frequency device may not be operated prior to equipment authorization unless the conditions set forth in paragraphs (b), (c), (d) or (e), of this section are meet. Radio frequency devices operated under these provisions may not be marketed (as defined in § 2.803(a)) except as provided elsewhere in this chapter. In addition, the provisions of subpart K continue to apply to imported radio frequency devices. (b) Operation of a radio frequency device prior to equipment authorization is permitted under the authority of an experimental radio service authorization issued under part 5 of this chapter. (c) Operation of a radio frequency device prior to equipment authorization is permitted for experimentation or compliance testing of a device that is fully contained within an anechoic chamber or a Faraday cage. (d) For devices designed to operate solely under parts 15, 18, or 95 of this chapter without a station license, operation of a radio frequency device prior to equipment authorization is permitted under the following conditions, so long as devices are either rendered inoperable or retrieved at the conclusion of such operation: (1) The radio frequency device shall be operated in compliance with existing Commission rules, waivers of such rules that are in effect at the time of operation, or rules that have been adopted by the Commission but that have not yet become effective; and (2) The radio frequency device shall be operated for at least one of these purposes: (i) Demonstrations at a trade show or an exhibition, provided a notice containing the wording specified in § 2.803(c)(2)(iii) is displayed in a conspicuous location on, or immediately adjacent to, the device; or all prospective buyers at the trade show or exhibition are advised in writing that the equipment is subject to the FCC rules and that the equipment will comply with the appropriate rules before delivery to the buyer or to centers of distribution; or (ii) Evaluation of performance and determination of customer acceptability, during developmental, design, or pre-production states. If the device is not operated at the manufacturer's facilities, it must be labeled with the wording specified in § 2.803(c)(2)(iii), and in the case of an evaluation kit, the wording specified in § 2.803(c)(2)(iv)(C). (e) Operation of a radio frequency device prior to equipment authorization is permitted under either paragraph (e)(1) or (e)(2) of this section so long as devices are either rendered inoperable or retrieved at the conclusion of such operation: (1) The radio frequency device shall be operated in compliance with existing Commission rules, waivers of such rules that are in effect at the time of operation, or rules that have been adopted by the Commission but that have not yet become effective; and (i) Under the authority of a service license (only in the bands for which that service licensee holds a license) provided that the licensee grants permission and the licensee continues to remain responsible for complying with all of the operating conditions and requirements associated with its license; or (ii) Under a grant of special temporary authorization. (2) The radio frequency device shall be operated at or below the maximum level specified in the table in § 15.209(a) of this chapter for at least one of these purposes: (i) Demonstrations at a trade show or an exhibition, provided a notice containing the wording specified in § 2.803(c)(2)(iii) is displayed in a conspicuous location on, or immediately adjacent to, the device; or all prospective buyers at the trade show or exhibition are advised in writing that the equipment is subject to the FCC rules and that the equipment will comply with the appropriate rules before delivery to the buyer or to centers of distribution; or (ii) Evaluation of performance and determination of customer acceptability, during developmental, design, or pre-production states. If the device is not operated at the manufacturer's facilities, it must be labeled with the wording specified in § 2.803(c)(2)(iii), and in the case of an evaluation kit, the wording specified in § 2.803(c)(2)(iv)(C). [ 78 FR 25162 , Apr. 29, 2013, as amended at 79 FR 48691 , Aug. 18, 2014]
FM is so crowded near me it would be hard to use a higher field strength than is allowed by 15.239 without violating the most important part of part 15, 15.5. As such I do not feel an overwhelming need to engage with my senators over any sort of petition. However it would be ideal if someone had a senator who was an amateur radio operator or enjoyed less common radio/music programing. That would be a perfect legislative champion to help push any sort of action through.
The following is just my opinion.
Writing the petition is the easy part. Selling it is the hard part; for that all the friends possible are needed.
Saying “As for Hobbybroadcaster, somehow I can't see Bill DeFelice and company getting involved in just a supporting role” seems like it could start a fight. It can be read multiple ways and some of them are confrontational. Bill DeFelice is very visible and vocal about unlicensed transmission that is compliant with the rules in part 15. On almost any radio world article involving unlicensed transmission or pirates he posts. On many engineering radio blog posts about unlicensed transmission or pirates he posts. He has tried to engage the FCC on the topics of unlicensed transmission versus pirates. FCC rule changes are a public processes. I think it is reasonable to assume Bill DeFelice will comment on any action the FCC takes related to unlicensed transmission for AM or FM radio. Having him onboard with any petition would be good. Not having him onboard would not be a show stopper, but in the FCC public comment phase, assuming a petition went that far, it is possible he would have negative comments. Possible negative comments from someone with an interest in part 15 transmission could be anything such as higher field strength causing unlicensed users to crowd each other, general public confusion about pirates versus legal users, overloading of neighbors radios, or greater chance of interference with licensed services (a non-exhaustive sample of possible examples).
You're right - writing the petition is the easy part. But you have to have it before you start selling. Otherwise, you're selling air.
That comment was not meant in a confrontational manner. You said it yourself - Bill Defelice is a forceful guy. The last thing we need is another force, at least right now. We require organization and process. We have more than enough force.
Once the petition is written, then I would personally invite Bill along with others to comment on it and participate. Because we'd have to sell this within the Part 15 community, as well as the political arena.
And for a number of reasons, I don't expect it to be an easy sell anywhere. I can just see the Part 15-related comments now. If expanding shortwave is chosen, some are going to question why not AM? And if AM is picked, then others will question why not FM? Or, you're asking for too much, or too little or... you fill in the blanks. The best we can hope for is to come up with a technically sound and well argued proposal, that can also be understood by those who might not even know what Part 15 broadcasting is. I'm not going to lose much sleep worrying over whether anyone else outside of the petition team, including Bill or REC(Net), has issues with it. You do your best, and let the chips fall where they may.
I've always said that this is a long shot at best, but it's better than sitting in a corner and complaining while doing nothing about the situation at all.
Artisan, is there anything going on in Canada equivalent to the part 15 activities in the U.S.?
We have numerous forum sites and manufacturers, but so far as I know Canada only has one FM transmitter maker, and my knowledge ends there.
Are there low power websites or known numbers of station operators?
The various Canadien rules as you've described them seem to be more spread around and difficult to comprehend than what we have.
that we can't write up the petition and just sit on it till a more part 15 friendly administration gets put back into the FCC or sit on it and lobby / coordinate with our us congress people to put pressure on the FCC and then offer up the petitoion at the appropriate time.
i just approved a very interesting individual over at the petition site. if i am right this individual will have lots of good input to add to the effort.
we shall see. i suspect things are about to get very interesting.
A response to all.
In reference to:
"Selling it is the hard part"
In a few of my past posts, I have said we need people on the team who have or possess the vocabulary to word things appropriately and not sound like a bunch of two year olds asking for candy in a candy store.
Although, I can somewhat agree, that WE can put forth such a proposal, you NEED people on the team who have the knowledge and ability to cross all the "T"s and dot all the "I"s in a professional manner, or your public proposal will look just like that of a buch of two year olds asking for candy.
I wish I was not cursed with the inabilty to get a point across in 10 words or less, but I try the best I can.
I can NOT stress, the importance of having people on the team that can answer technical questions in a PROFESSIONAL manner.
You already know that any proposal is going to be met with technical questions from those who might consider the proposal, the FCC for one, has technical advisors on their team, the NAB will hire such if need be, to back up their reasons for the FCC rejecting the proposal.
If you are asked, what proof do you have that allowing 500 microvolts/meter @ 3 meters won't cause any new issues with existing broadcast services, how are you going to answer that question? Answering "Because I know it won't" isn't going to cut it, you'll be laughed out of the room. You need scientific data, you need proof beyond words, that allowing it won't cause more problems than there already is in the current state of the radio spectrum.
We need talented radio engineers on the team, not just a bunch of adults acting like we're in our second chilehood playing with our toys, in this case we are talking about transmitters that allow us to play radio station, or radio disc jockey.
Our hobbies, in reality are just interests we have that allows us to live our dreams, in the case of part 15, we,at a very limited budget can own a radio station at 1 in 100,000 the cost of a REAL radio station. Even if a radio station never hires us, we can still play disc jockey at home and make believe we are working in a big 100Kw radio station.
But when it comes to changing federal law, the time has come to throw away your childhood dreams and graduate up to serious life, because the FCC does not do serious business with children, when serious proposals are being considered.
Like I said, if you want to deal with law, you hire a lawyer, if you want a car worked on, you hire an auto mechanic, if you want to petition the FCC for rule change, you hire a consultant and radio related engineer who understands the current rules and who has the abilty to look for loopholes in the current laws/system and can use that information to argue with professionalism why a change can be be made and all opposing arguements are proven false.
We can not do that with the current team we have on board, because we lack that professionalism, we can argue, but when the day comes to an end and it is all said and done, we will look like those two years olds and be laughed out of the proposal hearing room.
We need to get an engineering team and consulting team on board who understands the obstacles we are facing and can provide a quick witted rebuttle as to why the opposing views or opposing partys are wrong and make them dumbfounded in the process.
Then you have at least a 60% chance of winning.
Edited to add:
My Son is a licensed attorney, his brief look into this proposal, he has offered the advice I have given to you all above.
Mind you, the current law his law firm currently specializes in, is highly expensive divorce cases between rich people, who are the only ones who can afford the fees charged, but in his brief look into this matter, he suggests working closely with radio engineers and a consulting team willing to help us with this proposal.
Bruce.
MrBruce, you can get all the experts in the room you want. Although I may be stretching the truth a bit, think of Congress or the Senate, or the U.N. But they, by themselves, won't get the job done. You've got to have the right organization and process to take all the conflicting opinions and disagreements and come up with a consensus. And when you don't have that, more people, even those knowledgeable engineers and consultants you've been talking about, won't do you a bit of good - in fact, it will likely cause even more confusion and hurt you.
ArtisanRadio Said:
You've got to have the right organization and process to take all the conflicting opinions and disagreements and come up with a consensus.
MrBruce Saids:
That is correct, but just remeber, the number 1 reason for rejection of any proposals we bring forth will be the potential for "INTERFERENCE" to licensed broadcast facilities or services.
The only ones who can provide professional and accurate information is those who can provide proof that they have that special training.
No licensed station got their license by just asking for it, they had to go through a lot of legal steps and engineering and analysis steps to get that license. That's an easier process than what we are proposing to do.
They had to prove that putting a broadcast antenna in said location, does not cause interference to another licensed station on or near their proposed channel and there is a lot that goes on within that process, that we take for granted, because we do not have to go through it all to put a part 15 station on air.
Many have lost their CPs or licenses for failing to have accurate information, because someone, even the station engineer failed to have all their numbers and figures correct because they were sloppy with doing the analysis right.
It is a very complex situation believe me and we're in for more of a tough time than any licensee attempting to get a Construction Permit and then a full service license.
Here-say will get us nothing but a waste of time, we need someone with an engineering background who knows what they are talking about and can prove it.
Saying we own and operate a part 15 realated radio station provides no proof that you are in any position to argue against FCC appointed engineers or the NAB that you know more than they do.
Edited to add:
If anyone wants to start a go fund me account and is honest, perhaps, we can use that money to hire legal consultants and engineers who have a degree in radio and can help us with our questions and provide answers and the guidence we need to get this thing started and have some chance of it succeeding.
I'd contribute to it financially, if one is created and made public.
Bruce.
There are 2 transmitter makers here(Canada)....Decade and Procaster.
Most forums are US based and are just about part 15....none started here by anyone I have seen or anything based on BETS as opposed to part 15.
As for the number of hobby stations don't know....Based on the 1/10th the population I'd say 1/10th the number that there are in the USA(maybe less).
Mark
Wow I've been really busy uploading my music for my Internet/part15 station to the new virtual server with over 100 GB's of music. So I've been really busy this week.
Wondering why the Initiative has really not had that many replies (though we have a few really good ones) is the fact that while I was busy working on the station another person made yet another clone of what the Initiative was set to do in the first place. I'm not against this but surprised.
The Initiative has already had a workable document we've posted in our Elite section to keep rouge groups from using this against us until the document was iron clad and workable. We still may post it in the other petition forum as well. I do have to admit its nice that you have REC(Net) involved in your petition for more power.
Looking at AM I do feel that we do have a greater chance for more power there. Even 500 mW down there would be a real advantage and or eliminate the ground resrictions. Plus I feel that it should be legal for one to build their own ATU for transmitters like The Talking House as their built in tuner is absolute garbage.
I'll sign up for the other forum too and see what gives over there. Its just weird how this all got started on June 5th of 2015 and yes it will take a certain amount of time. Also people must work and stick to the cause. Jumping from one group to another won't do it however.
A key thing to keep in mind is not only do we have to convince the FCC, we have to convice EVERYONE else. The FCC says it seldom makes its own decisions, leaving most of the choice up to the users of the spectrum and the public.
It is only my opinion, but I think that having two distinct initiative/petition drives will strengthen the overall cause of obtaining less restriction on part 15 field strengths.
From the FCC perspective two petitions equals greater interest on the part of the users of part 15 services.
and we have none other than RFB who joined the ranks of the petition site.
"Artisan, is there anything going on in Canada equivalent to the part 15 activities in the U.S.?"
Not that I'm aware of. I was hoping to take what is developed here and adapt it for an effort in Canada.
"We have numerous forum sites and manufacturers, but so far as I know Canada only has one FM transmitter maker, and my knowledge ends there. Are there low power websites or known numbers of station operators?"
There is only one manufacturer - Decade - that has a BETS-1 certified device that I am aware of. There are a number of RSS210 certified devices for FM (equivalent to U.S. Part 15.239). But you're not supposed to use those for broadcasting.
There are no low power websites, but a few of us Canadians participate in the Forums, and on the Part 15 Facebook group (although many people there do not seem to understand what Part 15 is, and have non compliant transmitters, talking about ranges many times that of legal installs). From what I can gather, there aren't too many of us who participate in BETS-1 broadcasting.
"The various Canadien rules as you've described them seem to be more spread around and difficult to comprehend than what we have."
They sure are. Never mind that there are 2 sets of rules, one for broadcasting (BETS-1) and one for everything else (RSS210). There are no certified BETS-1 AM transmitters - the ProCaster is RSS210 certified, as is the Talking Sign.