"That is what concerns me about the group's lack of understanding of how the FCC works. Take some time and do some research."
First of all, there is no group, at least not yet. So any sort of judgement about the knowledge of the members of 'the group' is meaningless.
As an aside, few have offered to help to date, including the author of that comment.
There have been lots of positive suggestions thrown around here. But I'll repeat my argument that the petition not be written online. Works in progress are always dangerous - you never win with the readers. If you get something wrong, even something small, you'll be admonished and lose credibility. If they disagree with something, even before you've completed your argument, you'll get attacked and often they lose their open mind (if they ever had one) about that particular point. And if there is something that they agree with, you'll hear nothing.
I'm not arguing against constructive criticism - that's the lifeblood of any idea - but wait until the idea is complete before letting others have a go at it.
The Pro FM Initiative, as I see it, is in the "think tank" stage, where we are groping for the mental concepts and the language to clarify what it is we actually want to achieve.
The seed of the idea is very simple. Some of us believe the field strength allowed under 15.239 should be increased. Unfortunately that wish by itself is not a sufficient argument and so we need to come up with all sorts of "reasons" that we were not thinking about in the first pace. The trouble is the simple idea is morphing into something totally different that I don't find worth pursuing.
The tipping point as I see it is the risk of converting a hobby into a form of broadcast service loaded with requirements and responsibilities, i.e., public files, EAS equipment, public interaction. If someone wants so much responsibility they should get a part time job at a licensed station and forget the dream of "playing" radio with part 15.
"Hobby" to me means doing it because it's fun and interesting. You can do it on Tuesday and turn it off on Wednesday. You can re-arrange the schedule at will and change formats everyday. A hobby is a mature person's toy.
Translating our "wish" into appropriate FCC language should not, in my opinion, make any promises about providing anything whatsoever for the public except non-interference. However delicate it may be, the only reasonable argument is that hobbyists may safely exist at a higher power allotment than presently exists.
I posted what I thought (maybe I am wrong) an example of how to approach the FCC in the ALPB section of this site. I am sorry that I have wasted your time here.
Here's a link to John WDCX's post on the ALPB Forum
http://part15.us/forum/alpb-forums/alpb-general-discussion/example-arrl-petition-rule-making-change
With all the doom and gloom I just read and had to process over the last few days (Its why I've been a little moe calm) the petition from the ARL has done what we were about to do. There were no promises made to the FCC only facts about interference and the lack of in the frequency bands the ARRL wanted to increase power in. There were several references to Canada's higher power and documented lack of interference. This is what we are going to need for the FM band. Yes Tim has a point we have the addition of increased FM stations in the USA. My proposal for the mandatory scanning before transmitting on the higher power transmitters is a must. Brian from Whole House FM Transmitter made a suggestion to me not to do anything that would punish them for the current transmitters they already have and to leave room for those who don't need or want 1/4-1 mile range so I'm going to try and respect his wishes there. I'm in total agreement with Carl about the requirement of the EAS and logs and everything else. I can barely afford to live on disability as is the members of my household. To have all these requirements would kill off the Radio station as it is. As it is my Internet Radio station could already be in jeopardy in 2016 if the royalties go up and my stream license provider has to call it quits. He has already warned me that the PRO's want more money and are leaving no room for small web Radio stations like mine. Radionomy is another outfit I could go with but I really don't like their hard to use web software and their servers often buffer all the time. So I'd have to make a choice between by the book or go part 15 only. Part of me says F them and change my station name and run on a non USA server where that country has no copyrights and hates the greed of the USA and won't give out IP's. But I'd still have to spend $100-200/Mo for an Internet scrambler with more than 256 bit encryption and my ISP barely handles 128K so the scrambling will take more bandwidth probably 2-3 tiles as much. I'm hoping at least the NAB does get their way about on air Radio not having to pay any royalties as the NAB is already working on this which makes Internet Radio providers mad that they have to pay for music licensing and broadcast Radio may not in the near future. Carl is right about reverse payola which should also be illegal for Radio. Back to topic of part 15. My point is that although I'd love to have a 24/7 FM station monitoring the weather with equipment the only EAS I would have is a modified Motorola Droid 4 which had amber alerts and EAS (sort of) built in. I could wire up a relay system where as if the droid went off it stops the audio and pips the message to the transmitter. The droid 4 had a text to speech program so any weather alerts and emergency alerts would be broadcast to the transmitter. The modified Droid would have its own service and that phone would only be used for tethering when the internet messes up here and the poor man's EAS. But still I'd have to constantly be calling for donations to afford that 2nd service as that would be. As much as I'd like to be a community Radio station and follow the every need like a LPFM station I simply cannot do that. If I could I'd have applied for the window and bought after I got my CP the part 73 transmitter costing $3k. Not to mention the $85K to rent land for the tower and you still need the thousands of dollars for engineers and they are not going to do anything for FREE. A friend in part 15 wanted an engineer to come and measure his stations field strength with a Patomac FIM 71 and he was laughed at as the engineer said “You can't afford me!” so again not happening for a hobby caster such as ourselves. I'd say re word and follow the outline of the ARRL's petition and see what we get from there. It would have to be someone who is good at this stuff. I hope at a later time we won't have to have a lawyer on retainer who knows about FCC laws on our side. This again could get very expensive. I don't know which way to turn at this point I still want to try this but we really have what seems like years of work to do. Some are still wanting to help which is good however this is really going to take an effort never taken from part 15 operators before as far as I can see. We really are on uncharted territory here. The storms ahead look treacherous so now where do we go from here? Do we stay home or try what the ARRL has done? I know Artisan Radio has talked about helping with a petition we have WDCX's understanding about an outline so at the next meeting we should talk a little about this. Without promises we have a greater chance of getting shot down in seconds so the real question is how we can get some data that shows a lot of what is being called Pirate Radio just because it is a little over part 15 how has that going to convince those operators to operate within the expanded field strength rules. Maybe we should find folks that started in part 15 Radio and later has graduated to professional Radio and how part 15 Radio and their audience made them a success in Radio Today. Canada's 1,000 uV/m @ 3 meters needs to be brought up and the lack of interference. This along with the contour charts of that strength and how it would help bring in an audience. We also need to bring up real estate agents who want to sell homes and how FM would help sell their homes with increased field strength. Think of services that could use this increased strength. If interference could be caused how are we planning to dampen the possibility of this from happening. I'm hoping that now we still have an interest in this and the consistency with in any part 15 initiative project that we create to accomplish this goal in the end. What worries me is that with all the talk we don't have 50-100 people with the skill and determination to get this to a reality. I know there are lots o hobbyists running stations and I'm sure they want an audience.
No one would disagree that the FCC allows low power "Intentional Radiators" as a personal communications medium on AM and FM.
Because it is "personal," the practice of the hobby belongs to the person doing the low power broadcasting. The privilege is not assigned to a street address or private property as has been claimed elsewhere.
As a personal communications medium Part 15 gives the individual about as much range as they'd have by their spoken voice. That certainly "fits" the effective RF field to the individual person.
By talking in terms of "reaching an audience" or "attracting listeners" we are no longer talking about a personal radio medium... we have crossed a line and are describing a public broadcast service.
Asking the FCC to approve a new public (non-private) broadcast service they will logically reply that we are trying to re-invent LPFM, which already exists (albeit the filing window is slammed shut).
To repeat what I said earlier, the reasonable position for us will be to ask for more leniency in the personal power allowance under 15.239 and for that we need a strong argument.
The certified FM transmitter manufacturers may take interest in a stronger power because it would cut down on the number of returned units that likely come from disatisfied custumers who find the present limit tantamount to being defective.
The issue is not the mechanical process of filing a petition to the FCC. It's all pretty simple and straightforward - it can even be done online. And the FCC's decision-making process is well laid out.
The issue is also not the mechanical process of writing the document. The ARRL petitions and others are all available publicly. I don't think that we (the royal we) should follow any of them blindly, as most are rejected no matter where they come from. They're good reference points, but just that.
Writing a petition is really no different than writing any formal document. You let people know what you're going to say, you say it and then you conclude by saying it again (and again, and again in appendices that provide excrutiating detail and support). Again, it's a mechanical process.
Carl is correct (at least in my opinion) in that we're at the think tank stage. We can't get too hung up on the mechanical details right now.
Particularly since the real issue is the content. Just what are we trying to do? I suspect that there are as many ideas out there as individuals and that's great, some workable and some not. And I suspect that there many, many more arguments, both in favour and against, those ideas.
All that has to be brought together and decisions made as to which avenues to pursue before we get down to the real work. Which is developing strategies that will get the data to support those decisions. As well as developing strategies that will get the data to subvert opposing arguments.
As an example, my one and only, since I'll say again that I don't want to write the document on the Internet, the argument has been made that Canada and the U.S. are totally different in terms of FM station needs. That argument is both correct, if you look at the two countries at a surface level... and false.
It is true that Canada is a vast country, and the overall population density low, but most of it is unpopulated for various reasons. The majority of the population lies in a very small band close to the U.S. border - I don't know the exact percentage but it's very high (and that's an example of the types of facts that need to be gathered). The population density of the Greater Toronto Area/Niagra Peninsula is higher than many parts of the Eastern Industrialized U.S. and Europe (again, that needs to be supported by specific facts). And that's where the majority of Canadian FM stations are - the FM airwaves are jam packed.
So, the Canadian FM experience, at least in the urban areas, isn't all that different than that of urban areas of the U.S. And that lends itself to the argument that FM interference isn't likely to be increased if Canadian field strength levels (or something similar) were adopted. Of course, we're going to have to have appendices showing sample field strength contour maps for whatever field strength level is being proposed, etc.).
That's why I welcome all opinions, both positive and negative. Because each needs to be taken into consideration in the final document. In fact, most of the comments that the petition is likely to receive (if the FCC puts it out there for comment - they can reject it outright) are going to be negative, and that has to be recognized and dealt with beforehand in the document itself.
So let's not get too hung up on the bits and pieces right now. They'll come, once you make your strategy decisions.
And let's not make any assumptions about the knowledge of whatever team ends up writing the petition before we know who the members of that team are.
I'm sure there will be more than enough comments once the team is in place.
Reply to Carl's last post. I believe that that position does need to be discussed.
Reply to theLegacy's post. 50-100 people? You can't do anything in a reasonable period of time with that number. Think 3-5, any more and you increase the communication overhead significantly. Large teams generally don't get much more done than smaller teams, if they get it done at all (and most don't).
Finally, some sanity is coming into this discussion courtesy of timinbovey. You can call me names and be childish but what Tim is saying is indisputable. Again I urge all to re-read why the FCC got rid of the LP10 service and ask yourself, "Would the FCC approve of a micro-broadcaster service on FM given what they did to LP10?" Also, consider why the Commission established part 15 on FM and AM in the first place (garage door openers, experimenters/hobbyists, baby monitors, church parking lot broadcasting, FM radio adapters?). Given the increase in environmental interference from computers, cellphones, lighting, etc., do the current rules on power and field strength for part 15 still make sense or should they be increased to compensate for today's technology? (after all, they're thinking about giving AM broadcasters a power increase for the same reasons).
Finally, I would contact the RecNet and Prometheus Project people for ideas. They have the experience on writing petitions for low power radio and they have the ear of the FCC. While I doubt they would think much of your plan to increase the range on part 15 FM (after all, they are the primary movers and shakers behind licensed LPFM), I think they would be very open to the idea of building up a stronger part 15 AM service, especially since it's already known as LPAM. Would a community benefit from a micro-watt LPAM service? And, yes, be ready to offer EAS on such a service (perhaps just analog EAS decoding will do instead of going full EAS/CAP). If the FCC is worried about interference, perhaps a database can be kept of those who are broadcasting using unlicensed AM transmitters; something similar to what they're doing now with unlicensed users of the TV band.
Contrary to what some people here think, I'm not totally against your trying to get more power for part 15 FM--who knows what the FCC wil approve of if given the right argument. But be careful, you don't want to run the risk of losing what we already have--especially as it pertains to 15.219. That is what concerns me (and some of the others) the most.
Why would our discussions about increasing field strength under 15.239 result in losing the status quo? I see no logic in that at all.
First of all, I haven't seen any name calling or childishness.
You're entitled to your opinions, Carmine, as is Tim. But I would hardly call those opinions indisputable. Facts are the only things that are indisputable, and what some might see as facts are in reality just incorrect or just opinions. But worthy of discussion and consideration - of course.
However, you're mixing a lot extra in with the Part 15 FM initiative (from what we might actually propose, to arguments in favor or against it, to completely new ideas such as an increase in Part 15 AM strength).
Perhaps I'm misreading what you're saying, and you're proposing going for an increase in Part 15 AM strength rather than FM. That would bring a whole new set of issues into the equation. Maybe you could clarify that.
I don't even see where EAS enters into the discussion. It's true that the FCC can, if it approves a rule making request, add any conditions it wants. But given that the most likely approach will be to ask for, as Carl Blare puts it, some leniency in the FM rules, I believe that would be highly unlikely.
And as for your last paragraph - at last, a tangible and realistic reason why some people appear so dead set against even attempting to change the Part 15 FM rules. How likely is it that a petition to change Part 15.239 will result in the FCC changing Part 15.219, not for the better, but for the worse? I don't know. Is that realistic? Again, I don't know. Perhaps that's something to be researched historically to see if something similar ever has happened.
Having been a licensed broadcaster myself at one time, what timinbovey has said is right on the mark. And I was under the impression that you were doing a more comprehensive petition; FM, AM and HF or SW.
Part 15 AM/FM as used by hobbycasters has pretty much stayed under the radar of the FCC--except for the occasional NOUO. Would asking for a power increase be kicking a hornet's nest--calling unfavorable attention to hobbycasting and prompting the FCC to re-examine the part 15 rules for FM and AM? Something to think about.
But, like I said earlier, reach out to RecNet and Prometheus Project. I think they would be a very good resource for what you're trying to do and might help you with your petition.
"Having been a licensed broadcaster myself at one time, what timinbovey has said is right on the mark."
Tim is helping us a lot, and it's appreciated. Your comments are appreciated as well. But a lot is opinion, sometimes based on incorrect facts. I've already demonstrated, for example, that the licensed FM market in Canada is very similar to that of the U.S., despite what might appear otherwise.
"And I was under the impression that you were doing a more comprehensive petition; FM, AM and HF or SW."
A lot of things have been talked about, but no decision has been made yet. That's what I find most perplexing about some of the negativity - we haven't even decided what the petition is going to be about, never mind formulate any of the arguments to support that unknown subject. If I had my way (and there's absolutely no guarantee of that), it would be as simple and as focused as possible, i.e., only about Part 15 FM. With the arguments to support it again as simple and as focused as possible.
"Would asking for a power increase be kicking a hornet's nest--calling unfavorable attention to hobbycasting and prompting the FCC to re-examine the part 15 rules for FM and AM?"
If that is really the concern of some Part 15 hobbyists, then I can understand their concern. I find it difficult to believe, however, that Part 15 has actually flown under the radar of the FCC, with all the attention that pirates have obtained in the past little while. After all, the only unlicensed broadcasters are Part 15'ers and pirates - and the FCC has to determine which is which. If the FCC was going to revisit the Part 15 rules, then surely their current pirate initiative would have been the time to do it. However, it is a valid concern, and one that needs to be thought through.
"But, like I said earlier, reach out to RecNet and Prometheus Project."
I know that someone has attempted to contact Prometheus. The last I heard they hadn't responded. I have my doubts about their willingness to support an increase in the Part 15 FM field strength (they might even be an objector), but you never know.
Even if, say, the Canadian BETS rules on field strength were adopted, that wouldn't make a huge difference to Part 15 FM. Except for exceptional circumstances and applications, if you wanted to broadcast, range would still be much less than Part 15 AM (with ordinary radios, probably on the order of 800-1000 feet, or 1-2 city blocks). Call it immediate neighbourhood broadcasting at best, as opposed to community (which is LPFM) or city (commercial licensed broadcasters). But it would be better than it is today, and at least open up more possible uses, with little chance of interference to existing services. At the very least, it would truly enable personal broadcasting, as Carl Blare would put it, something that isn't even possible today unless you have a good radio.
It might even get rid of a lot of the illegal transmitters that people buy on e-bay and other places with the sole purpose of transmitting throughout their house and yard.
I'm just throwing things out there from the other perspective. Angles that must be thought of because they WILL come up.
As I see it the whole increased FM idea comes down to two things: I want people beyond just me, in my yard, to be able to hear my hobby FM station. And I don't want to do it on AM because the music sounds better on FM. So, it's NOT really a "personal station" as covering your yard would be fine were that the case. Yet it shouldn't be known as "public broadcasting" as that would require additional scrutiny and responsibility.
That's a very fine line.
Tim in Bovey
Your sort of right about this. However think too Christmas Light Shows. These people broadcast to the public and has for years and their music was not licensed from any PRO that I can be sure of. So when your talking about a small group of people like your personal neighborhood again though its public its only within that neighborhood to as if someone threw up a 1,000 watt stereo and put on some Album Rock it would travel a good 800 Ft away from the house as you'd hear it outside with the windows down. Would I have to pay royalties since anyone who drives by my 800 Ft range would hear it? And here we go again with Canada. They don't pay royalties because their transmitters travel further than ours do legally.
I know FM is getting more crowded here as well. Stations are transmitting with more power than before it seems as well. And 87.9 is gray (However some well known people are using it as well). One such person who has an AM petition is using 87.9 Mhz and is on the website and has for years. The Schoche has 87.9 as its list of frequencies and is certified. So I guess it depends on the area but I'd rather transmit where there is less potential for interference than to continue to transmit on 96.3 Mhz and which is the only quiet frequency I can use without fear when a temperature inversion comes in. Plus I think that station may be playing around with their power as well because last night there was a sports event on that station and it was BOOMONG!! Makes me wonder if commercial stations are playing by the rules in the first place. Sporting event Hey we turn up the power. This time they forgot to turn it back down its still in there Today.
So you have both sides playing in gray areas and that is how it goes. The FCC is on the sidelines just waiting and wondering what to do next.