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Hello all,
There have be posts here and other boards concerning the FCC through licensure or other means permitting higher powers and ranges than currently allowed by Part 15 rules for AM and FM operations.
Suppose, for a moment, that unlicensed broadcasters on FM are permitted to use 10 watt transmitters. John goes on the air on a certain frequency and Jill goes on the air on the same frequency and interference is now a problem. Who has the right to use the frequency?
Hello all,
There have be posts here and other boards concerning the FCC through licensure or other means permitting higher powers and ranges than currently allowed by Part 15 rules for AM and FM operations.
Suppose, for a moment, that unlicensed broadcasters on FM are permitted to use 10 watt transmitters. John goes on the air on a certain frequency and Jill goes on the air on the same frequency and interference is now a problem. Who has the right to use the frequency?
Now, we need some governing authority to cooridinate the frequencies. OK, John agrees to move frequency but now he is interfering with Charlton who was there first.
Suppose the FCC says you have to self regulate and coordinate frequencies. You must establish area coordination and the FCC will enforce frequecy allocations made by the volunteer groups.
What is the result? Ask any amateur radio operator who has tried in the last 25 years to obtain a 2 meter repeater coordination from the state amateur radio repeater coordination group. The frequencies were gobbled up by large ham clubs before anyone else could apply! I am not making this up since I have first hand knowledge of this. In my area, there are no coordinated frequencies available and none have been availble for the past 25 years. This is a result of but not the fault of “volunteer” coordination. The simple truth is that once the frequencies are assigned, there are none left.
Many have complained about the lack of clear frequencies in their area because the “evil” commercial broadcasters with all the money own the FCC. The same thing has happened (without the money) to amateur radio. The same thing will happen if “community broadcasters” get any clout from the FCC or try to self regulate. Who is going to mediate disputes and on what authority? Who would you allow to determine if or how you want to “community broadcast”?
If, as I, you enjoy learning about the technology and listening to your own programming in your yard via your part15 unit then I suggest you let the current rules be what they are and work within them. Licensing or coordination will only bring you grief and food fights.
Any frequency coordination will leave someone unhappy.
Neil
Total posts : 45366Author Mark Twain is quoted to say, “History does not repeat itself, it rhymes.” In the 1920’s, as America was getting a handle on the potential of a new communications medium called radio broadcasting, the federal government was called upon to protect the very limited resource called spectrum. It took Congress and the President over a decade to agree on the Communications Act of 1934. This act of law created the Federal Communications Commission and made radio spectrum a public trust administered by the federal government. In doing so, radio spectrum regulation did not develop as a component of a democratic process. The FCC began to develop and execute a long list of rules, regulations and administrative laws by wrote, some continuing to this day.
The very same challenges faced in the 1920’s and ’30’s exist today. Namely the scarcity of available radio spectrum. Neil is correct in his assessment of the outcome of frequency coordination efforts here is this country with commercial and amateur operators alike. And, yes, not everybody gets to be happy when another party decides who plays and who doesn’t.
I was the chairman of the Oregon Region Relay Council, a nationally recognized frequency coordination organization. Frequency coordination requires cooperation and teamwork to be successful. And when certain individuals will not compromise, the end result is frustration with the process and the outcome.
Neil brings up another good point. Frequency coordination without considerable science to back it up becomes a political process. Those who are good at politics get what they want, those who have lesser political skills oft times go away disatisfied. So, clubs and groups of people who have successfully discovered a common vision and goal become the “haves” where the lone operators become the “have-nots”.
Once again, broadcasters have been here before. The philosopher Santana is quoted as saying, “Those who forget history are destined to repeat it.” Part 15 broadcasting does need a clearer set of operating rules. Currently, regulating Part 15 broadcasting may well be like herding cats. There are lots of independent thinkers and doers, and darned few team players and consensus builders. Team players and consensus builders are the folks who change the regulatory landscape. When they win, we win. Self regulation could work if Part 15 operators would understand what is at stake. We must agree who will be responsible for decision making and the scope of the process as well as the outcome.
Where as “food fights” are unpleasant and unseemly, it is how we move forward in this country. And for over 200 years food fights have served us well. It would seem appropriate that the Boston Tea party was in fact, a food fight.
Marshall Johnson, Sr.
Rhema Radio – The Word In Worship
http://www.rhemaradio.org
Total posts : 45366You have some great points. But I blame the lack of frequencies for community broadcasters on the FCC and religious organizations wanting to create a national network of translator stations. Even though we are about 70 miles from a city of 200,000 and about 150 miles from a major city every single available non-commercial fm frequency is taken. In our case there are two out of state religious broadcasters each of which “had” to have a translator in every town in the area. Do they provide local programming? No. Do they have a physical presence other than a satellite receiver and transmitter? No. These are broadcasters who give nothing back to the community. I feel they violated the intent of translator station licensing. Worse still they’re after LPFM licenses now and have even proposed to the FCC that their “translators” should have priority over true local community broadcasters. Supposedly the FCC is planning to open a window for non-commercial FM licenses shortly. Good luck finding a frequency.
This is not a rant against religious broadcasting. I think that satellite delivered programming on these stations using so many frequencies is a waste. And personally I feel that their motives for such are a little less than true religious enlightenment.
Total posts : 45366Marshall,
Thanks for your interesting comments. My first post was prompted by comments I read on the Ramsey board where someone was complaining about newly licensed stations taking away “his frequencies”.
I imagined what could happen if part15 power and range was legally increased and these unlicensed stations began interfering with each other. Your account of the early history of broadcasting illustrates this.
I am not politically skilled and tend to view things as an individual. Perhaps you are correct in that some organized effort with rule changes would benefit all, but for folks such as I, using part15 for yardcasting, status quo is OK.
For those who want to broadcast to a local community, I would support LPFM licensing with limited range (say 5 miles for this discussion). The stations can coexist with space diversity rather than frequency diversity and there could be room for several of these stations on a clear frequency (there’s the catch) in a given area. As mentioned in a post in this thread, there appears to be “clear” frequencies to assign to translators and out of community broadcasters. Perhaps this should stop and the frequencies be reserved for limited range local LPFM as I describe. I know this kind of approach has been stalled before and maybe history will repeat
I ramble a bit, but am just doing some brainstorming on this topic.
Neil
Total posts : 4536625 years ago, or so, a religious broadcast ministry decided to test the FCC on the use of translators. The use of remote satellite programmed low power FM radio stations was proposed to the FCC. This particular organization had a broadcast license in the upper Midwest. So the FCC was forced to decide on the issue. Prior to this, translators could only be built and licensed to “fill-in” service area holes caused by terrain shadowing and antenna system challenges. In short, to make up for the shortcomings of the broacast station licensed facility.
The FCC bent to the pressure and changed a portion of the rules. The pressure came from powerful congressmen threatening to limit funding for the next budget cycle. And even now, LPFM broadcasters are trying to reverse part of the revised translator rules so that existing and proposed translators are unable to supplant existing LPFM stations. So far, no word on what the “new” FCC will decide.
It is for theses, and other, reasons efforts to develop a new LPAM community broadcast service are underway. LPAM would be less than 100 watts, most would be 10 watts. And probably best of all, LPAM stations, as proposed, would be able to sell radio advertising to local businesses and organizations. LPFM’s are under the same rules for advertising non-commercial educational public broadcasting stations are under. They don’t advertise. They are, however, allowed to recognize those people who financially “underwrite” the local LPFM.
Spectrum allocation has become, over the last 25 years, a political football. Congress, the FCC, the NAB, the NARB, the ARRL, churches and international ministries have all made attempts at controlling the available spectrum. I have spent weeks lobbying in Washington, D.C. asking congressional staff members to consider funding for a public project or a change in existing law. Most of these people are educated in the Ivy League schools and have no experience or perspective about the issues the rest of the country deals with. And the 450+ folks who are elected to Congress get their decision making information from these people. Is it any wonder things are screwed up? I have yet to find a congressional aide anywhere who understands the issues involved at the FCC.
So, the FCC runs, most of the time, with little or no direction from the folks out here in the hinterlands. So, the only time you and I get a voice is when we respond to FCC proposed rulemaking or get a consortium of like minded people together and propose a change to the rules.
To follow the original title of this thread, thats when the “food fight” starts. It’s not fun, its messy and its hard work. But, if we are willing to do what it takes to cause change, then we win and so do those who follow in our footsteps.
Marshall Johnson, Sr.
Rhema Radio – The Word In Worship
http://www.rhemaradio.org
Total posts : 45366Marshall, Referring to your last sentence above, what can we as part 15’ers, and especially LPAM’ers do. Since you’re quite knowledgeable would you outline a plan of action that those of us who are not so much in the know may follow. Aren’t there supposed to be some members of congress who are sympathetic to our needs, and how can we move the rest, that is, really reach them in a way that some aid just doesn’t shelve our correspondence? Jim B
Total posts : 45366Marshall & Others,
Your comments about the FCC being a bit out of touch is right on. There have been previous posts on this site regarding making comments in support of a new low power AM service. I’m not sure if the comment period is still open or not. The best thing anyone can do to push for this is to make comments in response to public comment periods with the FCC. It only takes a few minutes. Also take a few minutes to read through some of the other comments. That’s where I read the comment from one of the satellite/translator broadcasters where they claimed their satellite delivered programming better served local communities than true local programming. If you’re interested in LPFM then check out http://www.prometheusradio.org which actively works to promote LPFM.
Total posts : 45366But, does anyone agree with me that expanded community broadcasting should not be an extension of part15 but rather a new license class and part15 should be left alone?
Neil
Total posts : 45366Creating a new licensed service using old technology (analog radio) is not apt to cause the FCC to included community broadcasting in any proposed budget. If you want to know whether or not the FCC will pursue a new radio or communication service, follow the money. License fees to offset the expense of regulating a community broadcast service would take most part 15 broadcasters out of the running. Just the application for the construction permit would be several hundred dollars. The actually expansion of community broadcasting would be very slow as the commission would permit about 2 to 3 dozen new facilities to be authorized a week. It would take months, or maybe years, at that rate to assign frequencies, build stations and license the facilities. All we have to do is examine the plight of LPFMer’s to get a look at what a new service would suffer through. Without the FCC infrastructure and budgetary support, community broadcasting would languish just like LPFM.
And leaving Part 15 “as is” seems sort of pointless. I have yet to find a Part 15 community broadcaster who finds the rules and their enforcement workable. Basically, its damned if you do, damned if you don’t.
Part 15 community broadcasting, in my view, needs to have its own subsection of the rules. The subsection could include a list of acceptable frequencies that “might” be used. Use of a particular frequency could be based on coverage area, adjacent station frequency separation and such, just like the LPFM rules. Part 15 rules, as currently written and interpreted, were never intended to regulate community broadcasting.
All broadcasting has, historically, had rules involving bad language, offensive content, superfluous communication and programming service the local community needs. At one point, the mention of alcohol on Sunday or any reference to drugs or tobacco were absolutely forbidden. Would any Part 15 broadcasters be willing to fall under this increased scrutiny?
Candidly, I don’t see the FCC leaving Part 15 community broadcasting alone, except as constrained by the agency budget. The expansion of micro power broadcasting is going through explosive growth. The advance of computer automation software and digital music encoding has brought the source programming to any home computer. They must address the real technical issues, the programming content issues and the political issues.
Finally, it is my opinion that creating a new licensed community radio service and leaving Part 15 to its own devices is probably not very realistic. And as much as I agree with the intent of the idea, the realistic possibility of not extending community broadcasting within the framework of Part 15 lacks budgetary horse power and political will.
Marshall Johnson, Sr.
Rhema Radio – The Word In Worship
http://www.rhemaradio.org
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