As one can see from Rich's post, the FCC does not disingush based on power levels/Field Strength. Now in the case of Lonnie Kobres he was sucked in along with Doug Brewer and Kelly Kombat on that dark day of the Tampa sweep. What is interesting is that Lonnie was the only one criminally charged. Doug Brewer was running about 400 watts ERP, selling ads, had liners like "FCC Bite Me." He was running on 102.1. Kelly Kombat was a free form music guy and a student at USF. He was running on 87.9 and was known as 87X. I think he was running 40 watts. Lonnie on the other hand was running "God, Guns & Guts" radio and I think he was running 80 watts into a home brew antenna.
Now it gets better. Lonnie is convicted and placed on house arrest with a monitor. He has to pay a stiff fine and restitution to his victims. (who ever they are) After he served his time he was back on at very low power and told by his probation guy that he he stayed at this "low power" he would be OK. NOTE: Lonnie has an extra class license that he was able to renew. Doug Brewer on the other hand, faced no charges, was back on the air at high power, they busted him again, fined him (he never has paid) revoked his amateur license along with his commercial license. Kelly Komabt experienced nothing and was never heard from again.
This is very interesting. Even the FCC doesn't seem to know what to do as some people in the public don't see it as a problem. Some lawmakers don't see it as an issue. So that in mind don't you think we can make a reasonable change? It does show that the old school of Radio thinking is not working. I have done some reasearch last night and posted the results on Rubbed Wrong, but I'll post here since we're really getting somewhere. I looked at the box of my FCC complient FM Transmitter. Yes it does have Lo Hi power modes but the Lo power is -48Dbm which with the Dbm calculator to milliwatts = 0.000015848931925 Milliwatts. Now that in mind it takes 0DBm to = 1 milliwatt. So 28DBm would equal 630.95734448 mW which is just over a half watt and under 1 Watt. It might be a power level we should try and shoot around to get this petition going serious and might have some merit as far as the FCC goes. The real folks crying about this seems to be the NAB not anyone else. And if a Ham operator does this it not interference they are the least bit worried about. Now I think if we put our heads together as was mentioned on Rubbed Wrong we may get some sort of order to construct a reasonable petition that will have a leg to stand on.
I think that we have to put ourselves in both the FCC and the licensed broadcaster's shoes.
Given that a couple of milliwatts can cover a few miles (to a sensitive car radio) with a good antenna, why would the FCC (funded by the broadcasters) allow hobbyists and/or potential businesses to broadcast at much higher output levels, without regulation, with the greater potential to cause interference to existing stations and with the potential to take listeners and therefore revenue away from those stations? That will be a very tough sell.
I believe it was Mark that suggested that field strength levels on par with Canadian rules might be more achievable - the sky certainly hasn't fallen here in Canada with those regulations. Although it has to be recognized that 1000uv/m at 3 meters is still only nanowatts of power (maybe more with a mismatched antenna) and if you're lucky, and conditions are right, line of sight you get maybe 3000 feet range to a sensitive car receiver. Much less than that if there are obstructions (likely half that or even less).
Maybe the idea of a VLPFM (very Low Power FM) license is the way to go - I wouldn't call it a hobbyist license. You'd have the same rules as Part 15, with a still higher field strength maximum, and charge a fee for the right to broadcast. Portions of that fee could be fed back to the licensed broadcasters as compensation for potential lost revenue from listeners, and the rest to the FCC. There would be administrative issues to be sure, and I'm also sure there would be contention on the amount of the license fee. But getting acceptance of the philosophy behind the idea is the key - that Part 15 broadcasters have the right to exist (yes, I know, they do now in theory, but not in practice, at least in the eyes of the licensed broadcasters), that they can co-exist with the licensed broadcasters, and deliver alternative programming that the licensed stations either can't or won't.
OK so we pay a monthly fee maybe $25-30/Mo max. Even @ 1/2 Watt your not gonna make a profit and as far as taking a few listeners we're talking maybe 15-20 away. Seriously you're not gonna be a real threat to them @ these low levels of power. If I am gonna pay for a license I'd at least want to reach a mile maybe 2 where as if its FREE I could accept 1/4 to 1 mile and be happy. But paying $30/Month I'd want some reward for that in way of listeners which a few feet won't really get you. There should really be a compromise for all of this. I think below a milliwatt is really too low. It should depend on rather an outside antenna is gonna be used or not. If someone uses a rubber duck to even reach 1/4 mile you may need close to a watt. So too most folks getting this license or using these transmitters may use the stock antenna if they could get some range in the first place. At least get the range near what AM part 15 is already. The RIAA has always been greedy so too is the NAB. Maybe they should have these users as a part of their membership somehow like you said and that way they are actually helping the NAB. At least play an NAB program so many times a week on your micro broadcast station but the format be slightly different than what is on high power FM stations.
My take on the fees is that you would have several choices:
1. Free - use existing field strength levels
2. Not Free - use enhanced field strength levels. You're not going to get a watt. Or even half a watt. 1mw with a good antenna can reach several miles to a good car radio, maybe 1/2 mile or so to a home radio. That would still be field strength levels about 1000 times what is allowed right now. And the fee would have to be commensurate with the loss in revenue to the licensed stations, plus the overhead to administer the program. I suspect that $30 would be too low. It's not so much the direct loss of revenue from one VLPFM, but the possibility that multiple stations will pop up (which certainly would be possible). Plus you want to make the fees sufficiently high so that you're going to get serious entrants into the field, and not just someone fooling around.
Though the OP addressed FCC operations at least I am not able to add anything to that because I don't know enough about it.
There seems to be two issues which would contradict allowing higher signal strength on FM being a) possible interference to licensed radio services and b) loss of audience to the unlicensed broadcaster. Personally, I think the second issue is really weak but I do have experience with the first.
As a ham operator I have had two interference complaints directed at me. The first resulted from my operation on the 40 meter band with 280 Watts PEP SSB. My neighbor complained that I was interfering with his TV reception and I responded to try to determine why since I was not interfering with my own TV and was convinced that my signal was clean and legal. Working with him I found that a connection to a mast mounted amplifier was corroded and when repaired there was no interference. This one was not my fault but it took a while for my neighbor to believe this and it is apparent that it didn't make any difference to him since his TV reception was trashed.
The second incident was reported to me by a fellow ham and also by a local police department. I was operating mobile on the 2 meter band with a hand held and a 10 Watt amplifier. The amplifier was producing spurs in the 2 meter band as well as in the 156 MHz public service band. This one was my fault and I immediately trashed the amplifier.
The issue for the public is that their communications are being adversely affected and it doesn't matter whether one is operating legally or not. From a regulatory perspective it is difficult to allow unlicensed operation with technically loose specifications and at the same time to minimize the probability of interference. The question is what field strength should be allowed in the FM band? Though as a hobbyist I would like to see an increase I have to admit that if I were charged with this decision I would probably leave things as they are unless it could be demonstrated that an increase would still provide protection from interference.
The objections of the NAB or like groups could be argued but it will be difficult to give assurance that with higher power interference issues will not arise. It is going to take more than pulling a power or field strength number out of a hat to answer this.
Neil
The Association of Low Power Broadcasters could be the answer.
That silly commisioner Michael O'Reilly wanted broadcasters to form swat teams to hunt down stations that interfere, but the ALPB could step in and provide a diplomatic solution by holding fair trials at the Team Speak Meetings.
No fees, no fines, it's mighty fine.
Those that help themselves get all the help.
Yea really. If the TX is causing harmonics the engineers or ones who are licensed Ham's could help to make a transmitter more clean. Then everyone is happy. Plus the FCC would have to give an experimental user permit to determine the feild strength. They would have to be several experimental FM stations operating at a range from 0DBm to maybe 28Dbm. The reports would have to be sent to the ALPB and FCC and maybe have someone inspect a station while they run at the verious levels. Find a reasonable strenth that does not cause interference and then make that be the field strength. Canada already has 1,000 Uv/M so I'd start at that level here in the USA. At least get that level and go from there. New Zeland has the 1 Watt limit and the sky has not fallen on either country where field strength is higher.
It was Artisan who advised we look at things from the point of view of the FCC, and I did so while cutting shrubbery in full sun with temperature 94.
The FCC has to think in terms of the predicted demand for a Part 15 FM device, like those cigerette-lighter transmitters that send iPods 1-foot to the dashboard radio. Probably around 40-million people with those in their car... maybe. We have to play it safe. So they write a formula and the answer is what we ended up with. 250 uV/m @ 3M.
Now here we are wanting to broadcast to many dashboards with a single device. That wasn't part of the plan.
... The FCC has to think in terms of the predicted demand for a Part 15 FM device, like those cigerette-lighter transmitters that send iPods 1-foot to the dashboard radio. Probably around 40-million people with those in their car... maybe. We have to play it safe. So they write a formula and the answer is what we ended up with. 250 uV/m @ 3M. ...
Probably with due research and understanding, most analysts would find it unlikely that cigarette-lighter FM transmitters sending signals over a 1-foot radius to a dashboard (car) radio were anticipated by the FCC when the 250 µV/m maximum field at 3 meters from the transmit antenna permitted by 47 CFR §15.239 for unlicensed systems first was (and presently is) codified.
I sit back pretty far from the dashboard.
With all the proposals I see here so far. I have a feeling that any agreement and rule change for a service like VLPFM is going to require mandatory participation in the EAS system. Broadcasters number one purpose for being on the air is to provide local, state and government emergency announcements and information.
Even cable TV systems have to interrupt all programming on all channels for the EAS system. LPFM stations have to have an installed and active EAS system. Active part 15 stations without access to that system would be taking listeners away that system's purpose. Therefore, I have a feeling that in order to comply, the FCC will require such stations either a mandatory installed EAS system, or a way to be aware that that system has been activated and voluntarily sign off with instructions on where else to tune for local information.
Those EAS systems, to which two systems are required, are very expensive to purchase even in used condition. Often, that complete system costs more then than actual LPFM transmitter alone.
Can we as VLPFM operators with very limited budgets and...perhaps forbidden from broadcasting over the air advertising like LPFM station are, afford such equipment and keep it maintained as well?
Bruce.
No, MrBruce, we hobbyists cannot afford EAS equipment, which nullifys any hope of getting a VLPFM status. It was a good try while it lasted.