im OK with a ALPB facebook page
The ALPB facebook page was created and I have to say it was done very well and is off to a good start. Now what how fast it will grow! Almost 100 new members in less than 24 hours!
Great JOB GUYS!!!
Bruce.
MacDev has it right. To make your case, you need to think like the FCC. The Commission is all about control, obeying Congress and doing as little as possible to change existing rules unless there is a compelling need.
What is the purpose for making changes in part 15 FM regulations? Is it to create a micro-community station? All that will do is raise the alarm from licensed broadcasters and hysterical cries of "planes falling from the sky" and "pirates." Plus, in the unlikely event that the FCC were to turn it into a service, such as an LP-10 or even LP-5, they would lard it down with a bunch regulations, a possible auction and EAS requirements.
If the purpose of part 15 FM is yardcasting or, better still, stadium-casting, is the current environment making it too noisy to adequately cover a yard or stadium or parking lot, thus necessitating an increase in power? Several years ago, I spoke with a field inspector at the Los Angeles office who had issued an NOUO to a guy in Santa Maria who had a Rangemaster set up. He said that the purpose of 15.219 was to allow for parking lot broadcasting--churches, shopping centers, etc. No field strength was set to allow for flexibility in the environment the part 15 AM station would be used in. But the 3m rule, definitely meant that the signal would die out before going too far. Is it possible that with the environmental noise and lack of support for AM in cars and the few cellphones that have FM radio, part 15 FM rules should be adjusted to allow for stadium and parking lots? I also, like the Great Britain idea of allowing for temporary FM licenses for special events. Could the FCC develop a service similar to this--say for a month? (I also like how GB allows for companies to own LPFM stations and not just non-profits. Individuals cannot own an LPFM but for-profit companies can--but only one station.)
If you're talking about a power increase for part 15 FM for use in stadiums and parking lots, you need to have proof that such an increase is justified. The FCC needs facts and figures to prove that current rules are inadequate.
My pet peeve are TIS stations. I think their usefulness has passed. Running a loop over and over is not a good use of an AM channel and does not benefit the public. Besides, many cities that have TIS stations, now have LPFM stations that are doing what TIS stations were intended to do. Two cities where I live have done just that and they have virtually abandoned their TIS stations. I'd like to see TIS turned into an LPAM service, a 10 watt (or higher) station manned by real people.
But don't think like radio enthusiasts, think like the FCC.
I think the argument has to go something like this.
Part 15 broadcasters are not a threat to existing radio stations. Because we don't do what they do.
Licensed broadcasters are very concerned these days about listeners abandoning the radio dial. And rightly so. There are so many alternatives.
Part 15 broadcasters with a greater coverage range will bring back some of those listeners to radio. Listeners that likely would have sought out the programming that they wanted elsewhere. And if they're listening to the radio, then there's the chance that they'll spin the tuning dial (figuratively, anyway) and check out what else is around.
So, Part 15 broadcasters won't take away listeners. They'll bring them back, and potentially help the licensed broadcasters as well. Bettering radio overall.
And also helping the FCC fulfill one of its mandates for the the betterment of radio.
There will have to be technical studies done on the increased levels of potential interference that will occur, but realistically, I don't think that will be a problem. Here's the argument for that.
Part 15 signals are very, very weak. If increased coverage is obtained, they will still be very weak. It is far more likely that licensed radio stations will interfere with Part 15 signals rather than the other way around. Particularly with the crappy radios around today, which have poor selectivity and adjancent channel signal rejection. That interference reduces the already limited range that even a boosted Part 15 signal will have. No true Part 15 operator wants that, and will go out of their way to reduce the interference they receive to as little as possible - thus reducing the off chance that their signal will interfere with licensed stations. It really is and will be self-regulating to a large degree.
Plus, most Part 15 operators are truely professional in attempting to stay within the rules. Currently, the only interference I've ever run across (other than blatant pirates) has been from yahoos who buy illegal, overpowered transmitters off e-bay, don't know what they're doing, and blast away (because they're only interested in getting a signal around their house). You have just as much of a problem for that kind of situation today, and increasing Part 15 coverage areas isn't going to make the situation any worse.
Anyway, I'm sure those arguments can be improved upon, but I believe the tenants are sound.
"Licensed broadcasters are very concerned these days about listeners abandoning the radio dial. And rightly so. There are so many alternatives."
But according to a licensed broadcaster, if anyone can bring them back to radio, they can do it; whether it's a change in format, web stream, contest, etc. They don't need an unlicensed broadcaster to do it.
Look at it from their standpoint (and I was at one time a licensed broadcaster): "Why should some guy be allowed to fire up a $100.00 transmitter and take listeners away from my station when I've spent 100K's of dollars and gone through the process of getting my station licensed? Where is the fairness in that?"
And I don't think the FCC will allow unlicensed micro-community radio stations. I don't think they have the stomach to start a new class of service and if they did, it would be a licensed service. Plus, as someone else here said, the NAB and licensed broadcasters would immediately cry "foul" as soon as such a proposal was formally introduced
But if you can convince the FCC to expand part 15 FM, like a new rule, 15.2XX, to include FM broadcasting for large venues then I think you would have a shot. Like 15.219 the rule would eliminate field strength requirements but would only allow the use of certified (and well filtered) transmitters that are designed to limit the distance of the signal--maybe a half-mile or one mile at most.
Another option, is an unlicensed emergency FM service. If you recall, during Hurricane Katrina, the FCC allowed on a temporary basis a few unlicensed stations to broadcast at higher ERPs to get out emergency information. Perhaps convincing the Commission to allow a permanent emergency FM service might work. It would take some artful wording to get the FCC to allow such a station to broadcast 24/7. But every day their is an emergency of some kind.
A third option is to get members of Congress involved. Ken Cartwright was able to get a local senator involved in his conflict with the FCC. Many are favorable to hyper-local radio and highly unfavorable of the FCC's convoluted way of regulating the airwaves.
But, as I've said before, you need to think like the FCC. And in their mind, an unlicensed micro-community radio service would be a non-starter. Their reply would likely be that such as service exists: it's called LPFM. They are, however, afraid of Congress.
I am going to be participating a lot less here as the days move on as I feel I have got my word out and got the process started of addressing the issues of a need for a rule change for the use of part 15 AM and FM.
I wish everyone luck with this process. I will not be participating in any Part 15 AM or FM radio broadcast service under the current FCC rules. When a suitable rule change is made to which ever radio service, AM or FM, I'll reconsider becoming a part 15 radio station again. In the meantime, I am a defunct radio station and will remain a defunct radio station.
So, this will pretty much be my last post here at part.us
I will keep supporting your facebook page's growth and try to get as many interested parties to join it and support it.
In the mean time, I want to make a statement about those ebay Chinese transmitters. Although they are under a constant assault of being the result of America's interference, they can be made to comply if the owner takes care to add the proper filtering to the internals of the transmitter and not to abuse the legal power output.
I have not dabbled in powerful Chinese transmitters, however, I do believe they can be altered to comply with interference issues, if the time is taken and research is done by the owner to make those changes.
That is my opinion as an electronics repair tech.
Good luck with your continued growth and success on Facebook! You're off to a good start!
Bruce.
MrBruce -
I understand your opinion about pitiful 15.239 (FM), although 15.219 (AM) isn't too bad.
Enjoyed having you here, the door will always be open if you decide to drop by with an idea.
I quit a few times, although I didn't mention it to anyone and no one realized it, so I returned as if nothing had happened.
Carmine, if licensed broadcasters could bring listeners back to the fold, it already would have happened. Instead, listenership continues to dwindle. Something new needs to be attempted. Surely even they can be made to see that. Or if they can't, perhaps the FCC will see it.
I think that your idea has merit and it could also be one avenue of approach. I don't believe that we're anywhere near to making a decision as to how to move forward - this is the idea throwing around stage of the process, and every idea is of equal value.
Speaking with other people in the radio industry lately, it's unlikely part 15 will ever get changed. I said that before. part 15 has a purpose, and we're piggy-backing off of it.
There is, however, an interest in community radio. It makes sense, and communities should have the right to have their slice of bandwidth.
I hope Carmine5 doesn't think we're all living in a fantasy world over here.
Hint: I read what you wrote about us on the other site. Not cool, dude.
I read it as well. I don't think that we're the ones living in a fantasy world.
Right now, we (as in the ALPB and members of this board) are looking at every option and idea, i.e., we're discussing the situation. All opinions matter. No one has made any decisions yet as to how to proceed.
It's what happens when you have a democratic process, as opposed to a dictatorship.
Oh, and by the way, the Facebook page was created to promote discussion about many topics in the field of low power broadcasting - not just changing the Part 15 rules (although I'm sure that that will be a hot one). Anyone who is interested in low power broadcasting, either on the AM or FM bands, or even longwave and/or shortwave, is invited to participate.
As I indicated, I rarely comment on this board for various reasons. But I wanted to address the misunderstanding on the "98 feet" rule as well as share my thoughts on the FCC based on my experience with the agency as a (formerly) licensed broadcaster and what it might take to possibly convince them expand part 15 FM.
But I won't be commenting here further.
Saying we're living in a fantasy world is an insult, quite frankly. I'd rather be here with open-minded people instead of "over there" where the slightest mention of doing anything outside the norm or asking questions labels you a pirate. Nobody here is living in a fantasy world, we're trying to make a change for the better instead of being locked into the absolute minimum.
This is how you make change. You ask questions. You talk with other people. You do experiments. You don't blindly follow other people. We are not sheep. I recently wrote an article for a radio publication talking about why I think CLPFM is a good idea. "Broadcasting" 200 feet over FM is pointless in my opinion. If broadcasting half a mile isn't hurting anyone, and we can prove it, why NOT give it a shot?
So have fun over there, I suppose. I don't really think they'll be making strides for any serious change.
That's why I came here.
If and when we make change, you'll know who to thank. I can guarantee you it won't be anyone over there.
EDIT: One thing I should note - you said that we were proposing an unlicensed micro-community FM station. You may want to re-read what I wrote:
"Allow people to pay for an annual CLPFM license, and make sure they stick to the same rules that larger stations do"
Don't even tell me "THEY" are over "THERE" making fun of "US" over HERE about a Facebook page?????
Why am I NOT one bit surprised?
Bruce.
To make the claim "they are living in a fantasy world" you've got to go the other step of the way and explain what that means. Saying it all by itself has no definition.
As a philosopher I know things Carmine5 clearly doesn't know, which leaves him to "keep the status quo the way it is."
On the flipside Mr. 5 is admitting that he is living in a world of realism, a place barren of creativity.