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I don’t want to start a YAID (Yet Another Initiative Discussion). And I also recognize that part of this is tongue in cheek.
This would be a big change. Bureaucrats don’t deal with change all that easily. It’s one of the biggest difficulties in all of this.
But sometimes, you can achieve a lot by changing very little.
So what if we’re lumped in with interference, and labeled ‘Intentional Radiators’? They can call me anything, including Hank.
What if we don’t focus on actually changing the rules, but changing the way that they are interpreted. Because, after all, words are imprecise, and can only go so far in describing intent (that’s why we have lawyers).
There is precedent for it. Ten years ago, when I first started broadcasting, it was quite common for FCC inspectors, when looking at AM installations, to let you ground to whatever you wanted, as long as that ground wire + antenna + feedline didn’t exceed 10 feet – that led to elevated installations on metal masts, signposts, buildings, etc. Now, somehow, those grounds are considered part of the ground wire because they can potentially radiate. It’s important to know that nowhere is ‘radiating’ found in the rules).
What changed? Only the interpretation. You can argue until you’re blue in the face about which interpretation is correct, or scientific, or factual, but the reality remains that if the FCC chooses to go back to their original interpretation, that’s their perogative. And nothing in the rules changes. They did it before! The only thing that the FCC has to do is to issue a circular, or bulletin, or whatever they would call it, clarify that interpretation (much like they’ve done with the 200 foot rule for Part 15 FM). In fact, I’m rather surprised that they never really have clarified the ground rule, when it would be rather easy to do (either way), eliminating endless discussions about said rule in Forums such as this.
Another possible interpretation change, this time for FM, would be to measure field strength at the border of your property, as opposed to from your antenna. This topic (about whether it should/could/is done), which seems to make its rounds in the various every few months, just reared again in another recent thread here. Again, it’s another thing that would be easy to do.
Rather than focusing on difficult, if not virtually impossible, efforts to change the rules substantially, perhaps someone could actually do something and organize an effort to accomplish this sort of thing. After all, this is something that the FCC can do on its own, without going out to its various stakeholders.
Then again, there are always those that never want to rock the boat, as they feel that they could fall out (i.e., the FCC could change their interpretations to reduce Part 15 range, rather than slightly enhance it). I say, that’s just hiding your head in the sand, and tacitly admitting that you recognize that there is some playing loose and fancy free with the rules already. For believe me, I’m sure that there are many licensed stations already pushing for further restrictions on Part 15, and sometimes doing nothing is worse than trying to do something.