A very fine line indeed.
I do agree that the other sides of the argument have to be considered in any sort of petition. I just had a problem with the inferences that they were fact, and irrefutable. I believe each can be addressed and countered; whether the FCC and others accepts those counters is, of course, the question.
I still stick with Part 15 FM as a personal service and add this thought to the conversation:
FM Rule 15.239 does NOT provide yardcasting to users of certified transmitters.
The weak signal doesn't even make it to all indoor space, except with a super radio.
The ONLY way to get yard coverage would be a jump up to the Canadian BETS standard.
It could be why Scoche and other transmitter manufacturers (Which are certified) are under the radar of the FCC. Until the repack of TV (If it does happen) they may just let that one fly by for now. It could be something we address in the comments once the petition is ready for the public. Since Jeffery Gill has the AM petition going we should see how this plays out. (Notice his FM frequency of 87.9 Mhz). Funny thing was it didn't seem to follow the same outline as the ARL's in any way. Wonder what was up with that? It does have a lot of signatures on it and I did mention FM a long time ago on it too.
If you google FM Transmitters dirty little secret however it does talk about the complaints the NAB had and the continued overpowered transmitters from smaller companies. 87.9 Mhz was mentioned as an alternative and to start making transmitters that go there as it causes less interference. There was also a small initiative for 87.9 Mhz to be lifted from a gray area as part 74 and franken FM part 15 transmitters are already legal. So in order for the FCC to tell if your Frankin FM would be to visit your station. And there is no such thing saying you can't turn off the video part of the TX. Again there are two sides of 87.9 and the saga. I still state that rather or not the station you throw a carrier over the top of serves your area your still illegal if you transmit over the top of it so it boils down to the lessor of the two fine line areas. I'm not the FCC but if I were I'd rather a hobby broadcaster use a unused frequency than one that is used in any case. If severe weather comes or emergency comes up and a storm is in the area of the distant station it could encourage the public receiving the distant station to check their area if the weather man talks about the direction of the storm. Its a nice reference sometimes to tell if anything will be in your area. Maybe at least get a temporary allowance of 87.9 Mhz till the FCC decides to utilize the frequency for something else. This would put it outside the gray area. This could also help our cause. However we need data proving that the scoche and other transmitters using this frequency does not interfere with anything using the present and new proposed field strength. I'd be happy if 87.9 Mhz was the channel the FCC gives a temporary higher power allocation to see how this goes. I'm gonna use it for now. May soon go AM to be sure I am not going to get anyone mad at me. Yes FM is a very sensitive area and for some reason AM isn't. But too I don't see increased strength for AM yet.
Tim brought up some very good points, things that I've been finding in my research. The FCC doesn't give a rat's butt about YOU. What you need to show is how this change is going to affect people at large. My original idea was to give the ability to broadcast to your town. There's a severe lack of community broadcasting, and LPFM is too much. Yeah, yeah, everyone talks about how LP10 didn't make it. That doesn't mean something else will fail.
The point is, I wanted to start a station for my town. That's how I came up with this idea in the first place. I want to give people in the community the ability to be on the air and be a part of something. This isn't about money or piracy, it about community and nothing more, and the FCC is limiting the ability for people to do just that.
So the Part 15 thumpers can be happy yardcasting, but I'm not happy with that, and LPFM is too much for what I want to do. There needs to be something community-based.
And a community can be as small as 3,000 Ft square. That too is my point. LPFM is by far too much for the common individual who just wants to have a Black Party broadcast. It could even be to sell homes within that 3,000 Ft area. Your still broadcasting to a community who wants to buy houses. And if you play music well again your 1,000 Watt per channel Stereo could cover that same area. Its highly unlikely your going to cause that much interference in that short range. But we have to show proof of concept.
Here's something else which may be of interest. It's an article about a poll taken, asking people where they get their new music from. Not surprisingly, internet came up as #1, and not radio. I ran a poll like this myself and came away with similar results.
It could help show that radio needs a boost of some kind.
http://www.radiosurvivor.com/2015/08/18/new-music-seekers-say-farewell-to-amfm-as-first-choice/
TheLegacy sparked my response by stating: "LPFM is by far too much for the common individual."
Not only is that true, LPFM is not and was designed not to be about any lone individual. LPFM applicant requirements included having an already developed not-for-profit public organization who would apply for and manage the LPFM frequency. There was NO WAY for a lone individual to get an LPFM license.
Except for a few LPFM stations owned by funded organizations, cities for example (WCFI), keeping the financial footing afloat and co-ordinating with the public to offer air time is actually a worse problem than being a slave on a chain gang. At least slaves on chain-gangs don't have to buy their own chain.
LPFM is designed to fail, except a few rare exceptions that will go on until the licensee asks whether it's worth the expense.
The fact that LPFMs cannot be sold or transferred by their licensee's is the final kick in the rump.
I have been contacted by someone very high up and informed that LPFM stations CAN be sold and transferred.
That is a good thing.
Only if you have more than $85 grand to buy a station like this. But here is an idea: What if the ALPB had dues and we saved up and bought all the LPFM stations and handed them out to those that wanted to broadcast from their homes. We could simply pipe their Internet software into the transmitter using a mixer. But even if we done that we'd still not be able to pay the huge bills. To get real we'd have to charge $100-200 a month in dues and that would not even cover it. Face it folks for an individual to run LPFM is a moot idea or point. It can't be done. You would hve to get huge donations each month even if you fudged and made up your own organization. They know this can't be done and use it to throw it into our faces when we try and run a hobby station.
Here in our town we have a 50 kW 88.1 FM station that characterizes itself as a "community station" and by their definition members of the community may sign up for air time and bring in their record collection and be a DJ. But it's limited to that. It is a station of 24-hour-a-day D.I.Y. disc jockeys.
They do not allow members of the community to come in and do interview programs or topical programs about issues in the world.
It is failing. In the last few weeks desperate pleas have appeared in the printed press about the failure of the station to raise the money needed to be a big play pen for record collectors.
So let me see if I got this right. If I lived in your town I could bring in my CD's and do an Album Rock show and as long as I don't talk about politics I could play some tunes and then after a few tell the audience the Artist-Track-Album? Can I take requests? Would I be able to use my own cell phone as a Rockline? If so that would be cool. But the fact that their failing means the public is not willing to donate. This is another reason we need an easier way for hobby Radio to stay a float. Sounds awesome. I'd like to see that here but since it didn't work where you are I know in this town it won't work. there is a lot of unemployed folks in this town.
The "community station" I am talking about recently fired its manager by surprise... "Clean out your desk and leave the building..." and has a history of in-fighting and disagreements among its volunteers and board.
That's the way it usually is at not-for-profit community stations.
The Pacifica Stations, located in Los Angeles, San Francisco, New York, Houston and Washington D.C. recently fired their Director and she changed the locks and locked herself in the main office for several days before she was removed by court order.
Picking a board to run these "public" stations is very dangerous... tugs of war for control easily break out.
If the Low Power FM Initiative succeeds, here is one way to upgrade the present very low power certified transmitters to a new operating level.
Notice: This is presented for academic interest and may not be permitted by rules in your area.
http://www.radiobrandy.com/Panaxis-FMA-5000/
To drive the amplifier it takes 200mW input. And at 16 Db gain you'll get far more than 1 Watt out of it. And I am sure the FCC is not going to allow more than 1 Watt. Heck 500mW to 1 Watt into a standard rubber duck antenna is going to be a challenge as I'm trying to come up with a field strength that compares with that now and taking into account that over 75% of the certified transmitters sold Today are already putting out 1775 uVm @ 3 meters as we speak and that said the range of usefullness is questionable due to the poor standards of Today's boomboxes, Stereo's and Clock Radio's. Its going to take 4 times 1775 Uv/m at 3 meters to square root and make that range useful to simply get out a few feet to a portable Radio. When Tim does more tests I am sure we can start shouting numbers. I still need folks to say they want to be a member of this said group. Artisan Radio already has stated he'd help with a petition but needs others to join him. No one except possibly Carl has said anything about writing one. Bruce said that we may need a lawyer to help make a legal document. But we need names to say Yes I want in. Outside of that we are just spinning our wheels and going nowhere. I do like the tests however and makes us think a bit. There is still the better chance we would have at getting rid of the ground rule for AM and maybe rid of the length rule for AM and leave the 100mW rule in tact. That way we can experiment with antenna designs for indoor broadcasting easier. You can do quite well with 100mW into a good antenna. We did it at the school for the Blind long before all the rules were known. Even a Science Fair AM transmitter can transmit 1 mile on a good antenna. Get rid of the antenna restrictions and you'll get 3 miles or more easily on AM because you could slap 100Ft of wire and be done with it. Or make a nice virtical indoor antenna or attic antenna and have a long ground to the basement water pipe and get out far at 100mW. Lots of fun at QRP.