Part 15 Initiative

Not that it matters, since the decision appears to have already been made.  But if I had been asked, I would have replied that I think that it's a mistake to be identified as an activist group, with all the negative perceptions that that entails.  I believe a more professional, business-like approach would have been the way to go.

It also appears to me that this group is biting off a great deal, looking at not only FM but also AM, Shortwave, etc.  And taking on all the overhead that a completely separate group entails.  That's spreading thin resources even thinner.

Finally, I believe that even talking about anti FM trolls, never mind locking them out, is counterproductive.  Why not let anyone participate who wants to?  Even those who might disagree with what you're trying to do.  Constructive criticism is essential if you're going to get anywhere.  Just look at what other places have turned into when no one is allowed to disagree with the guys that run them.

This afternoon an ad-hoc informal meeting took place of a few who were available at short notice, therefore nothing was "decided" in any official sense.

Of those present it was agreed that it would be appropriate to form a separate group of those dedicated to an improvement of Part 15 FM, for the reason that the ALPB was not founded as an activist organization. Artisan has a point... maybe "activist" is a loaded term.

The idea was tossed in of applying for improvement of all Part 15 categories, LW, AM, SW, etc., and this idea brought no followup discussion at the time, but looking back at the record of ALPB meetings, the notion of piling on such comprehensive improvements was previously discussed and rejected, the ALPB deciding that best chance for success would arise from sticking to a single objective.

The strongest plan of action put forward so far in my opinion is Artisan's idea of assembling a close-knit drafting committee to collect and compose the best suggestions into a presentable document.

Because today's meeting was informal and advance notice was not given, I would describe it as a chat and not a policy meeting.

It was my assumption from Mram and a few other members of the ALPB that no interest was presented in changing the group from what it was which is folks who want to help other folks with their equipment and programming of their stations and to help others to set up a station. So I said How about a separate but equal part of the ALPB. This way we can have meetings and get this increase for FM drafted. FM is the forefront. Next we can try AM, LW, SW. Someone I can't remember on teamspeak called what I was trying to accomplish the FM initiative and since I was Pro FM but wanted to call it a better name thought about it for a bit and said “How about Part 15 Initiative?” since we want to get things done for all of part 15 so our signals can get out. There is an obvious interest in it (Or so I'm lead to think) because of the Facebook comments and the Radio survivor blog/podcast talking about a hobby service. After seeing the Florida law blatantly take a paragraph here and a paragraph there of the federal FCC rules and re construct it to fit what a chapter of the SBE in that area wanted without so much as an alarm sounding from what should have been screaming from the mountain tops I could not take it anymore. At first that was what the meeting was called for because Station 8 had some stuff to say about it. Really its time for Action and now we have a big fish to fry. Rich (I don't know if he wants to be a part of The Part 15 Initiative or not) already helped us by wanting to construct an Email to send to the SBE. Tim has been wanting to help too. So we do have folks who want to do something. Now is the time to collect names of who wants to be a part of The Part 15 Initiative as a full member. I want to address why we should until we have the petition for increased power on FM finished. An anti FM group or establishment can and often will go to the members of the FCC and let them know “Hey there is this guy The Legacy and he is raising hell on part 15 dot US about making some sort of petition about increasing FM for part 15. We can't have that. We need you to stop this asshole before it becomes the real deal. After all if they get this passed hobby Radio operators will take our listeners away and we can't have thus person raising so much trouble for us.” then they will give the enemy the play by play action before we get it off the ground. Before you know it part 15 dot us will have hackers doing DDOS attacks on the site to stop it before it starts. So surprise shock and awe is the way to win. Now Timinbovey is a broadcaster who knows how the other side thinks and already stuck his neck out to help us. If he wants to be a member I hope he does I'm glad to have him. But remember we have only one chance at this and its do or die once the genie is let out of the bottle. So before we let the genie out we better know what that genie is going to do once out of the bottle. I never tried to be sneaky to the rest of the ALPB it just seemed that the way it was going that more interest was in a separate entity instead the entire ALPB as a whole going after things like this. Again activist I don't know if that is the proper name but I want to have this portion of the group more geared towards change. Already there is a petition to get AM increased for Power and I have written an Email to Jeffery Gill to get this done as well as the AM side. He told me he has a lot of personal things going on but if I wanted to get help with something small he maybe able to help with that. So looks like the FM petition will have to be a separate petition. Now we just need to see who is interested and how far they are willing to go for The Part 15 Initiative. Who is with me at this time?

The ALPB Meetings on the 1st and 3rd Saturdays of each month are the location where formal meetings are held of ALPB members, the next meeting scheduled September 5th.

The Pro FM Initiative was first introduced for discussion by TheLegacy at a recent ALPB meeting, and has become the talk of the town. The ALPB makes an excellent planning stage for deciding how to structure the Pro FM Initiative, and little informal side meetings like we had today are helpful for hashing ideas for presentation at the next ALPB Meeting September 5.

Petitioning the FCC for a rule change can only be done in a formal manner, and the organization of a 2nd group, a Pro FM Initiative Group, is a topic that can be thoughtfully discussed by the ALPB Membership.

At the Meeting on Sept. 5 I am going to offer to act in an advisory capacity, sort of like I'm doing right now, hoping to help organize the Pro FM Initiative effort.

I believe the Pro FM Initiative needs an experienced director, and I nominate Artisan Radio, who has expressed a keen view toward organizing the gathering of facts and writing of a petition.

While I'm handing out titles I hereby name TheLegacy as the Inventor of the Pro FM Initiative. Look what you've started.

Now would be a good time to stop vilifying groups and individuals who appear not to support or to oppose the Initiative. Focus on the positive and encouraging aspects of this rather than fear of what others may do or say.

Neil

I 2nd Artisan Radio.  A do agree with you Carl I hope this thing goes off well.  I just want to do this without raising hell for the ALPB because although I'm all about the Pro FM initiative I don't want to ruin an already established group just to get this job done.  When someone tells me something can't be done sometimes it does encourage me to try harder and think of why it may not work in its phase right now.  I'm glad you guys want to do this and like I said its going to take work.  We do have people talking about us so some of them may want to join us at a later point in time who knows.  Yes in a few months this went far.  But like anything else it isn't built over night.

DITTO

Having been on the inside of efforts to petition the FCC, and having a tad of experience in this sort of thing I have a ton of random thoughts and perhaps there is some useful information in all the gibberish I'm about to type.  And let me say that I am certainly not against improving the coverage of FM part 15 broadcasting, but there are a ton of things to keep in mind.

Number one, is you need a REASON to petition.  What is the goal.  What is the purpose. If the answer is "because I need a better quality signal for my chosen music format than I can currently get on AM Part 15" forget it. The FCC doesn't even care a teeny tiny bit about your music.  They don't care about it on commercial radio, or public radio.  It's not a factor.  You can't argue "Well, no one is playing classical, or classic rock, or jazz, or whatever"  they don't care.  And your new station with a 1/2 mile radius isn't going to help the cause. There are 17,000 FM stations in the USA.  Near as I can tell every format is represented.  On a recent trip to Minneapolis I had no trouble finding an FM station for every format I could think of.  Country, classical, rock, hard rock, oldies, classic rock, spanish, hmong, american indian, jazz, talk, sports, you name it.  And taking into account all the extra HD channels there was no format lacking. this is NOT a selling point with the FCC. You really need to always look at any thoughts, plans, ideas you have from the opposing side and consider what the negative responses might be. The FCC has never cared about format or music.  Simply doesn't matter.  So, that can't be your reason for increased power. You can't say it's because you want to bring "classical music to your neighborhood" or whatever. That's completely off the table.  One thing you might consider is presenting the angle of how these little FM stations will provide coverage for the community, e.g. local events coverage, local news, etc. Are you going to pitch this as exactly the same as part 15 is now except with more power? I'd find it highly unlikely that you'd get more power simply so you can play radio on FM instead of AM. If you want to be taken seriously, you have to have serious purpose.  I would suggest visiting radio stations in your area and asking to look at their public file.  I'm sure many of you know that EVERY station must have a public file, that has license information, political rate information, tons of other things -- in fact this is one of the few things the FCC *really* scrutinizes when they inspect a station.  One thing that MUST be in there is a quarterly filing of "Issues and Answers"  This would include a list of issues in the area of service -- crime, housing, political problems, hot rod drivers, fire safety, whatever and then a list of what programming the station has provided to answer those issues. It may simply be a list of fire prevention PSA's played and an interview with the police chief about crime prevention.  EVERY station HAS to have this.  AND they MUST by LAW allow you to have access to the public file and also assist you in copying any documents that you would like copies of.  Look at some, and come up with a list of how increased power for Part 15 FM will help the community and more importantly why the existing AM service of Part 15 can't do that. This is going to be a very tough sell, but you must have purpose and then demonstrate it.  I would also suggest gathering dozens, if not hundreds of, letters from small town Mayors, presidents of Chamber of Commerce, educators, religious leaders, business people, and other people of importance in a neighborhood or small town stating why they believe having a Part 15 FM station with more power would be a benefit to the community.  This whole thing is only part about the technical side of it.  You have to have a REASON to ask for this, be able to demonstrate there is a need, and that better Part 15 FM can fill that need.  Again, you'd have to show why Part 15 AM can't accomplish that, and why all the existing stations aren't meeting that need. 

Your reason can not include "Well, Canada gets 250 uV/m at 30 meters, why can't we?"  There's really no comparison between the countries.  Lets look at some numbers. Using the latest figures I could find, Canada has 1450 FM radio stations.  685 of those are commercial stations the rest are educational or public stations.  They also have about 900 LPFM stations.  This gives them roughly a total of  2350 FM broadcasters total in the entire country.  The United States has 6624 commercial FM stations, 4057 educational or public FM stations, plus 6082 translator or booster stations, and 774 LPFM stations, for a total of 17,537 FM broadcasters. And you're going to tell the FCC that 17,537 stations aren't enough and you need a half a watt to meet the publics needs.  You really need to be prepared to do this.  The USA and Canada have roughly the same land mass both right around 3.8 million square miles.  You can see the potential for interference with FM in the USA is exponentially greater than in Canada.  Add to this that those USA stations are serving a national population of 319 million people, to only 36 million in Canada.  So consider the number of potentially interfering Part 15 devices sold in the country -- there are, just going by numbers of humans, going to be a lot more Part 15 devices in the US than Canada.  Clearly the USA has a lot more signals to protect. So that really shoots down any "Canada has it why can't we" argument. Engineers and hams, and US for that matter are already complaining about interference from Part 15 devices and we want to give some of the more power!

A well thought out and complete petition will include, thus far then, a here's why we need it, and here's how we are going to serve our community.  Any attempt to suggest it would be for our own educational purposes and experimentation would be shot down in about half a second. We can do THAT with what we have. I haven't researched the history but it's clear that personal transmitters under part 15 were always meant for personal use -- e.g. playing the phonograph through a radio in the 1930's, right up to playing the iPod into the old FM radio in the Buick. There are no rules pertaining to any sort of actual Part 15 "Broadcasting" just that we can, because the rules exist to cover it with low enough power. For what the geneeral public has been doing with Part 15 devices, it's been just fine. 

Then, you're going to have to consider all the technical parameters and you're going to need to have the tech details worked out by an actual engineer with actual numbers, charts, and hard facts. It would be good to have what you want and how it will affect existing services worked out, and then have opinions on the same side from various engineers included with the petition, not just a bunch of numbers from one guy.  Have it all peer reviewed and have documentation.Are you planning on just getting more power and changing no other rules in reference to part 15 FM? Or are you hoping to create a new class of Part 15 for FM use with a new set of rules?  Will the new FM have additional rules similar to LPFM?  After all your intent is to get more coverage to get more people listening, so you will need to be able to serve them with at least the minimal services provided by a "real" station.  Will you have EAS? Maybe that wouldn't be necessary, maybe just an EAS receiver that in case of an actual emergency could switch the station to "There's been an emergency, tune to "zzzz" local station for information. Sort of how the old Civil Defense system worked. Will YOU need to keep a public file and file your quarterly issues and answers?  I don't forsee getting more power for any attempt to practice more "authentic" broadcasting without some additional requirements.  It's best if they're all thought through and addressed in the petition.

You are going to have to have unrefutable numbers and engineering work, and a plan in place to insure that you won't create interference to existing licensed stations. With 17,000 of them out there that's going to be tough. this can't be guesswork, or something you're leaving to the FCC to figure out. You'll need to determine what sort of power, antenna, and other technical limitations will be needed to give the increased coverage without causing trouble. With thousands of Pirates caught over the past few years (see link I posted a couple days ago) how will this increased priviledge impact that? And in a good or bad way?

I can guarantee you the very SECOND any petition like this hits the FCC office the powers that be will rally big time and in big numbers to shoot it down. As I mentioned before they're all out to protect their livlihoods be they engineers or DJ's. The NAB has 8300 member stations.  Are you prepared to explain to them why this won't be a threat either technically or in stealing listeners away? If you don't plan on stealing their listeners, exactly who will be listening to you? That you won't affect their bottom line?  The SBE has 5500 members in 114 chapters.  Most of these are pretty hard core professional engineers who will be prepared to tear apart any technical data presented, so it's got to be good and it's got to be on point. Remember, the broadcasting industry in the USA has 314,000 employees and generates revenue of 1.24 TRILLION dollars a year.  Those 314,000 people, from part time weekend DJ's to big shot station owners need to make their car payments and feed their kids. And those bigshot stations guys we all hate all have dozens, hundreds, or even thousands of employees in their companies.

Where are the transmitters for the new FM going to come from. Certainly people aren't going to build their own as very few will ever be able to measure field intensity with accuracy. I'm sure there are a couple manufacturers already who can probably easily make changes to present units for a increase in power.  Heck, the Wholehouse 3.0 you just press two buttons and you're at Canada's power.  You don't even need a screwdriver! But there may be the need for more stringent manufacturing tolerances, and additional efforts to prevent modification. With the current Pirate problem this is going to be a HUGE concern. 

Remember any change is going to be open to public comment before any ruling is made. You need to be prepared for that. I'm pretty sure pro part 15 people will be outnumbered about 10,000 to one. 

Will the stations need some sort of license, or registration? What if 14 guys in a 12 block radius all decide to start litle stations in a city with 50 FM stations already?

As much as I am for improving Part 15 FM I think it's going to be a very tough sell to convince everyone that we just can't do it on AM, but if we could have the same coverage on FM it would be OK. 

So just some random thoughts, and excuse any typos -- I HATE typing.  I'm glad to help in any way I can, but you gotta be prepared to fight the good fight!

Tim in Bovey

Take a look at the ARRL example I posted in the ALPB section of this site.  I think it is a great example on how to approach the FCC.

I think it would be congress that would be the ones to actually pass the law on part 15....the people you actually vote for.

I could think of a good argument as to why FM is more desirable than AM but I think Timinbovey is right...you have to approach it the right way and there are so many arguments against it.....one is the big corporations to an extent run the government. I think having a classification that Canada has that the FCC doesn't that let's us go 1000uV/M@3meters could be a point. An election is comming up soon in the USA and approaching your congress member running for election when they will listen to you while campaining is a suggestion...but a handfull of part 15 forum members may not be listened to....99 percent of the population couldn't care less. But anything is possible!....a handful of people got the government to legitimize same sex marriage...15 years ago that would have been crazy talk. To the ones who want change....don't give up.

Mark

This would have to be worked on but this could be a good reason or excuse. Right now its full of holes, but with some good thinking we could use this but we have to tie it into hobby Radio and one way to do this is mention that commercial stations need to make a profit so they can't try and teach the public about traffic safety and the dangers of texting while driving and buzzed driving. I totally agree with Tim however if the FCC don't care about music formats the Album Rock Preservation Society won't work. At least not as the only reason. But music as part of a tool to lure to public to listen to your station to teach them something important now that could be a better approach. I'd like to teach about the difference between a tornado watch and warning. How about hurricanes too since here in NC we are effected by them. Now that is a good reason to have a Radio station. What would be cool is to get the folks into weather to make PSA's too and I'd play them. I say its a good idea and you may open my mind to some really interesting thoughts and ideas here. Again this is raw and rough and nowhere near the final product of our efforts. Something to throw at AM and why FM is important.

My station plays trigger files so that if your listening over the Internet and Targetspot has ads that are on a play list for your region which is based on your IP address. When there is no ads at the time you'll actually hear the filler audio file instead of what might be available from Targetspot. Since I'm piping my DJ software into the transmitter directly the filler file has messages about the dangers of Texting and Driving, Buzzed driving is Drunk driving and the dangers and consequences of these actions. These files were provided by DJC Media. The files were sponsored by the Ad console and is good PSA's to play. Just as the college station I use to do Radio for had carts they played regarding this type of PSA. Now I have to rethink a strategy to make part 15 hobby Radio important to the FCC. It could require all part 15 stations with more power to subscribe to DJC Media as their stream provider and you'll get the FREE ad files to trigger your ads which often are PSA's. So now we have a reason for the increase at least some. How can we prove AM can't make it and why we need FM for this is a hard sell, but here is a thought: We can get these safety messages to more folks and educate these folks better if they listen longer. Since AM often causes listener fatigue causing less listener hours. In order to change bad behavior and do the re education of that behavior it takes repetition just like programs for children often use this technique to teach numbers, the alphabet and other skills to young children. Since AM Radio is often unusable in areas of highly electrical activity and hydro FM is the only solution for public service announcements to have the most effect. Since adults are the folks we often want to attract to these public service announcements a programming that requires the highest fidelity is required as we use music as a filler for this educational process. Every 4^th song a PSA is injected onto the play list and while the listener is waiting for more music they are listening sometimes sub conscience hears this and its embedded into their minds. This is how commercials work and ear worms work. Since AM is all static and noise this would have a lessor effect in the teaching tool. Folks who listen to hard to find musical formats will listen longer thus hearing the messages more often.

I think it would be congress that would be the ones to actually pass the law on part 15....the people you actually vote for.

Uhhhhh no. That is what concerns me about the group's lack of understanding of how the FCC works.  Take some time and do some research.

The airing of PSA's is a very small part of answering the "public issues".  Now, granted I live in Minnesota and 95% percent of my radio listening is here, but there are already TONS of PSA's on the air, at least around here.  We run texting and driving, buzzed driving, DWI, and PSA's for nearly every valid cause that exists already.  In addition the Minnesota News Network, carried by most stations in the state ALSO plays within their news PSA's for all these things. We play PSA's for fair play and the value of volunteer referees for the Minnesota State High School League who oversees high school sports. There are PSA's for back to school safety, during the season there are hunting safety PSA"s, snowmobile safety PSA's, swimming safety in the summer, and on down the line.  I have most of these PSA's in rotation on my Part 15 station as well.  Every radio station I can hear plays more than enough PSA's. While this is a plus, the FCC in our mock inspections really didn't care a whole hell of a lot about our PSA schedules. 

Other things we do -- we air an interview every morning at 8:35.  The mayor is in after every city council meeting, a commissioner is in after every county board meeting. The librarian is in to tell about events coming up at the library. Organizers of nearly every community event, fundraiser, etc is in. This is 5 ten to 15 minute interviews EVERY morning. We do local news every hour produced in our own studio by our news director EVERY hour 7 AM - 6 PM.  We have local PSA's recorded by people like the historical society, the chamber of commerce, etc.  We have a community calendar PSA rotation of LIVE PSA's read by the announcers as part of their DJ patter all day, as well as some scheduled community calendar programs that all include local non-profit events, from church bake sales to defensive driving courses for seniors, to blood drives and free community concerts.  on any given day there are about 40 different announcements in rotation. These are all of course on the commercial stations I work for.  There is ) chance that a Part 15 station will have the resources in people and equipment to do these things.  When a child is lost or kidnapped, etc and an AMBER alert is issued will your station be able to broadcast that alert the moment it's issued? You need EAS to do that.  When the tornado is coming, or the train car full of amonia derails and they're evacuating will your station cover that?  You will if you have EAS.  If you don't have EAS will you or someone be at the station 24/7 to broadcast this information live and manually when it happens?  Imagine trying to convince the FCC that it's important to teach the kids about Led Zeppelin and Lynyrd Skynyrd and Pink Floyd, but you don't want to have to spend the money to be equipped to tell them the hurricane is coming! THESE are the sorts of things the FCC is going to look at.  Running PSA's, in my experience, is looked at like you're trying to look like you're doing good but with minimal effort.  A PSA for "school is back in session, please drive carefully and remember to stop for the school bus when the lights are flashing and obey the school crossing guards" recorded by thte local police chief is much more impressive and effective than running a thousand nationally produced ads for texting and driving that are played on hundreds of stations.  We keep a log of all locally created PSA's and the FCC is pretty happy to see a list of hundreds of LOCAL psa's involving the community in the public file. 

Congress would have ZERO to do with the FCC making any changes to the Part 15 rules. However you could certainly convince your local politicians who represent you in the federal government to support you and a letter from a congressman in favor of enhanced Part 15 FM would be a very nice addition to your Petition packet. 

When there's a community event, say "National Night Out" we do interviews, run PSA's and then show up with the station vehicle, provide music and do some broadcasting. 

We carry a ton of high school sports, which may or may not be "public service" but is a big part of our listeners lives and generates a good income.

Running PSA's is just a small drop in the bucket of community service. The quarterly filing of "Issues and Answers" in the public file is what the FCC looks at then verifies with program logs, etc to see that you're doing something besides playing music.

You'll never gain any points pushing that you're providing music education. FCC doesn't care. As I mentnioned before, In Minneapolis I couldn't think of a format I couldn't find on the air. I assume it's similar in other cities. It certainly was on our trip from Minnesota to North Carolina by car this past summer.  There was nothing lacking in formats. Up here in rural northern Minnesota where we have a lot more lakes and forest land than we have people I can still spin my FM dial and hear classical music, two classic rock stations,  several talk stations, oldies, pop, current hits, several varieties of country, etc. And that's up here in the boonies!  Further if you even try to play the "but we need this music" card the easy response is going to be that with the internet literally EVERY type of music is readily available, and free at that. I can sit and listen to Pandora and hear, so far anyway, any sort of music I want. I can also listen to it in my car as I drive (and you can't do that even with improved Part 15 FM for more than a minute and that's if you're driving slow). Now, granted with Pandora and all the others when mobile you're using up streaming data -- but MOST people have more than enough data in their plans that they're covered.  Not to mention millions of tax dollars are already spent on public radio that is playing and programming what commercial radio is not. 

That's an interesting concept (tangent here). I have to pay taxes by law.  A portion of my taxes are spent supporting public radio in direct competition to the radio stations I work for!  So I'm forced to help my competition!  Imagine how the local Ford, GM and Chrysler dealers would feel if the government sponsored a Toyota dealership in town on the concept that "You can't buy Toyota's there and we as the government have to make sure the people have access..."  For those curious -- you always hear public radio whining about how their funding is being cut etc -- did you know that non-commercial stations have to make their financial information available to those who request it?  I've analyzed several around here. Basically the operating funds for a non-com station come 1/3 from memberships from the general public, 1/3 from businesses who buy "announcements" they're never "commercials" and businesses who underwrite, and 1/3 from state and federal taxes, subsidies, grants, etc.  Obviously this ratio varies a bit from station to station, but that's pretty close.  But anyway, that's a tangent from the topic at hand.

And I KNOW some of you are thinking "but the big corporate crappy music jukebox station doesn't do any of these things" then go and have a look at their public file. Read their issues and answers.  If they don't have it, or don't give you access they're violated FCC rules.  They may run all sorts of public affairs programming at 5 AM on Sundays. By law they MUST have working EAS equipment and MUST broadcast at least a certain level of alerts as necessary.  I remember reading here someone had posted there was severe weather in their area and not one of the horrible commercial stations in their city had any weather warnings on the air. I looked up the city.  There were something like 40 stations listed.  I find it hard to believe that someone listened to 40 stations and was able to determine that no one offered a severe weather warning. Considering something like a tornado warning only lasts for maybe an hour as a fast moving storm moves through you have maybe a minute and a half to monitor any given station during that interval and have a chance to hear their warning.  NO station I know has gone to constant storm tracking mode, the announcements are inbetween songs, etc. Maybe YOU at your Part 15 would rush to your studio fire up your radar and sit there doing live coverage as you watch the storm go buy on the radar. Even if you were out grocery shoppping, you'd rush home to your basement studio and start your coverage. In the meantime the EAS at the commercial stations is broadcasting the warnings as required.

I really don't want to be the nattering nabob of negativism here, but I'm trying to encourage ya'll to be thinking of all the negatives so you can be prepared for them.

Tim in Bovey

You can also be sure the second the concept of increased coverage for Part 15 FM hits the pavement the music industry will be there with it's hand out. We already are required to have licensing agreements in place for broadcasting music, and with the news of increased coverage they'll want more $$.

There will always be unintended consequences.

Tim in Bovey