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Rich Powers posted a scan of the FOM i requested through a FOIA request over at…
http://part15lab.blogspot.com/2016/01/no-limits.html
Anonymous Poster added the following comment…
“when you make a FOIA requestit goes to the field office that covers your region or area. different field offices will garner different redacted results in theory as there appears to be no standard for redaction of material it appears to be up to the individual offices. so lets all make FOIA requests from all over the USA and it’s possessions and see what results we get. if we hit all the different filed offices with request it may be possible to piece together a better and more complete filed operations manual. a search of part15.us will reveal the actual wording used which you can modify to your needs. i believe the thread which stated all this is still archived there. thanks”
I would strongly advise that all the users here do the same. maybe we can coordinate. we all look up the different field offices that cover our area’s and one of us from each area should file a request with washington which will the request will be dispactch to the field office covering our area. i would recommend revisting the Denver FOIA Rquest as it was 4 years ago when i made my request a lot could have changed in 4 years.
myabe this would be a project for ALPB.
Total posts : 45366Considering the extensive redaction, was anything useful learned from this?
Neil
Total posts : 45366Yes. The FCC does not want you to know what they know.
Total posts : 45366Well actually we did learn a little bit..
First and foremost, that what information you can’t get from one office, you might be able to get from another.
I didn’t realize that in 2010 Bill at HB had submitted the same FOIA request as Robert had in 2012 (I’ve since update my blog with this information). However Bill’s request was compleately denied by Michael Moffit, Regional Director of the Northeast Region Enforcement Bureau in Illinois:“…We have searched our records and located one responsive document that contains twenty=two pages. We are witholding this document pursuant to.. [several FOIA exemptions].. These exemptions permit non-discloser would risk circumvention of the law…”
But in 2012 Rebecca Dorch Regional Director of the the FCC Western Region Enforcement Bureau in Lakewood Colorado, responded to Robert by supplying portions of the same 22 page field inspectors manual (Unlicensed Radio Operation II 220, Version Date: 5/21/08) which the Illinois office had denied, along with portions of an additional feild inspector maodule (Low Power Devices (47 C.F.R. Part 15) II21 5 Version Date: 01 /24/2008)
She withheld said portions backed by the same FOIA Exemptions, which permits nondiscloser of investigory records compiled for law enforcement porposes which would disclose investigative techniques or procedures., as well as protection of personal privacy interest.
We know from the introduction on page 2 “This module [ie: manual] explains the steps and administrative sanctions that FCC agents will apply to operators of pirate radio stations. Please note that pirates and unlicensed radio will be used interchangeably.”
But then, that paragraph ends, followed by a mysterious single line of addum, which is blacked out – indicating it references either an “investagative technique”, or “personal privacy interest”, however, it seems more likely to me, it’s a clarification ephasis of some kind to the previous paragraphs pirate/unlicenced interchange.
That elusive line they do not want us to know, I cant help but to conjecture says something about method/action of dealing with certain unlicenced broadcast which are in fact within the parimiters of 15.219
That might sound like a stretch, but keep in mind it’s also imeadiatly followed by catagories of Goals, Objectives, and Resources, which are also blacked out.
Why would the goals and objectives concerning illegal pirate activity be witheld?.. There’s no reason to. There must be an additional objective mentioned within besides the curbing of ilegal pirate activity.
I also don’t see purpose in witholding information on the measurement tools used, the databases and articles utilized, at least not if it were only for the purpose of ilegal pirate activity investigations… There’s a strong indication of an additional objective, which would be revealed if they had not blacked it out.
But is that aditional objective actually to curb unlicenced broadcasters who are operating legally? Doesn’t seem likely that is specifically what’s going on, after all they do emphasize “because there is no field strength limitation associated with operation under 15.219, an inspection is generally required to determine with absolute certainty that an AM broadcaster is in violation of Part 15.1..” I think it has something more to do with the certified part 15 transmitters themselves (after all specific transmitters are blacked out too, if it were just referencing high powered transmitters used by pirates, again, there would be no reason of witholding that information).
So I say it again, there’s a strong indication of an additional objective in this module.
Total posts : 45366In Post # 2 Radio8Z asked: “Considering the extensive redaction, was anything useful learned from this?“
There have already been several answers in the affirmative, to which I’d add:
The redaction itself is informative, because it tells us that responsible and reasonable effort to obtain information from our government to enable us to more fully understand our status and obligations is being blocked, forcing us into the state of uncertainty from which we’d made good faith effort to improve.
Such exclusion from federal management which directly affects our legitimate operation has not sufficiently been justified, in my finding, but rather, the language expressly refers to low power operation and pirate operation as in the same category.
The serving class have taken over the house and locked out their masters.
Total posts : 45366You never know it could even be to increase the allowed power on AM for unlicensed stations in orderto curb the issues on FM. Hey its heppening in other countries so it could be something on the docket for teh USA.
Total posts : 45366I find it interesting that they use ‘pirate radio’ and ‘unlicensed radio’ interchangeably, when we all know that there is a HUGE difference between legal unlicensed radio (i.e., you conform to the Part 15 rules) and illegal pirate radio (you deliberately do not conform to the rules, and in fact, you go out of your way to not do so). It appears, at least from that seemingly innocuous statement, that the FCC doesn’t care if you are attempting to comply with the rules, but still don’t conform.
Part 15 AM is pretty cut and dry, and anyone attempting to use FM is still largely in the dark as to whether they are legal or not, regardless of transmitter certification. That 200 foot guideline really doesn’t help, as, depending on your receiving equipment, height of transmitter antenna and a whole host of other factors, you can get ranges far less or far more.
The simple advice from all of this – either use a ground-mounted Part 15 AM transmitter with a short ground lead, or take some risk, use a certified Part 15 FM transmitter and hope that it conforms (I think you’re pretty safe with reputable manufacturers such as Decade or C Crane). Nothing has really changed (except the blood pressure of some).
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