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Part 15 broadcasters perform a free and altruistic community service. As such should the FCC consider a separate section in Part 15 for low power community broadcasters? If your curious read on.
When community groups began to ask the FCC years ago about access to the “public trust” radio spectrum. Frankly, it fell on deaf ears due to the political pressure put on them by Congress and broadcaster organizations (paid lobying). But when the electorate made issue with Congress on community radio access without a huge investment and attorneys (after the scope of ownership rules changed in the 80’s) people on Capitol Hill began listening. The outcome was legislation establishing the Low Power non-commercial FM service.
Part 15 broadcasters perform a free and altruistic community service. As such should the FCC consider a separate section in Part 15 for low power community broadcasters? If your curious read on.
When community groups began to ask the FCC years ago about access to the “public trust” radio spectrum. Frankly, it fell on deaf ears due to the political pressure put on them by Congress and broadcaster organizations (paid lobying). But when the electorate made issue with Congress on community radio access without a huge investment and attorneys (after the scope of ownership rules changed in the 80’s) people on Capitol Hill began listening. The outcome was legislation establishing the Low Power non-commercial FM service.
Now the FCC is being ask to establish a low power AM broadcast service. Watching the progress of this new rule making is predictable. Already, the National Association of Broadcasters has come out vehemently against it, making accusations of ugly nighttime interference and reduced coverage. If that were true, the implementation of the Class IV nighttime deregulation would have been a total economic disaster. But onto the real issue.
Since the terrorist and natural disasters of the past few years, community broadcasting by small involved individuals and groups has provide exceptional service. Large licensed radio congolmerates have been found wanting in the ability to quickly react to circumstances involved with the aftermath of the disaster. Enter the altruistic Part 15 low power broadcasters with flexibility and a passion for what they do. Not just motivate by a bottom-line mentality.
The track record and service provided by Part 15 broadcasters should be recognized by providing a separate section of regulations expressly for the purpose of enabling low power community broadcasting. Part 15 was orginally dreamed up to regulate “intentional radiators” like garage door openers, wireless phones and microphones, computers, WiFi, digital samplers and such. Part 15 broadcasters take a slap in the chops when included with the rest of the intentional radiators.
Very few Part 15 violations involve low power community radio broadcasters. Even fewer violations would occur if the FCC would invest some effort in creating a portion of the rules for Part 15 broadcasting. The rules and regs should be realistic; not involving field strengths and technical standards requiring laboratory grade equipment to specifically comply with. Developing regulations and rules that are not ambiguous and contradictory. Rules that the primary user of the service could understand and comply with. Some areas to consider for this new rulemaking might be:
Antennas
Transmitter certification
Ground Systems
Signal purity
Interference amelioration
Redress of complaint and violation notification
Area of service
Technical compliance and operation reporting
Acceptable measurement techniques and documentationI maintain it is time to address this issue with lawmakers and make them aware of the amount of service these micro radio stations and their operators provide at no cost to government and listeners. The FCC and broadcast groups need to step aside for the good of regular people in small and oft times ignored communties.
What do you think?
Total posts : 45366How about this…
1) DC input to final RF stage exclusive of heater or filiment power or modulation must not exceed 1 watt.
2) Radiator and coax must be limited to 10 ft. (no ground restrictions)
3) Transmitters operated under this rule part must be Type Accepted and can not be constructed from kits or homebuilt.
4) the harmonics, s/n, etc. should be the same as it is for commercial Transmitters.
5) modulation should not exceed 100% neg. and 125% pos.
4) No singe person or entity can have more than 1 Transmitter and can not own operate or be affiliated in any manner with a commercial licensed station.
5) Transmitter should be located on the same property as the studios.
6) Transmitter/antenna height above ground should not exceed 90ft
this is just off the top of my head
Total posts : 45366Hi,
Without comment on what you propose, I offer the following:
You wrote: “Part 15 was orginally dreamed up to regulate “intentional radiators” like garage door openers, wireless phones and microphones, computers, WiFi, digital samplers and such. Part 15 broadcasters take a slap in the chops when included with the rest of the intentional radiators.”
My research shows that part 15 AM was codified in 1938 to allow for “phono oscillators” which were phonographs which would transmit to the radios already in the home. The purpose was to reduce the costs of providing power amplifiers and speakers which already existed in the radios thus enabling people to buy phonographs at low cost. It was never intended to provide for community broadcasting.
Part 15 now includes the other devices which you cite because they are all unlicensed as are part15 transmitters.
Neil
Total posts : 45366Quote=kc8gpd
How about this…
2) Radiator and coax must be limited to 10 ft. (no ground restrictions)…
6) Transmitter/antenna height above ground should not exceed 90ftIf the radiating length is to have a 10 foot limit, it could NOT be mounted to a height limit of 90 feet with “no ground restrictions.”
The conducting path from the tx chassis to the r-f ground plane at/in the surface of the earth is a radiating structure of the antenna. This means that the total radiating length you propose in item 6 would exceed the 10 foot limit you propose in item 2.
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Total posts : 45366
Total posts : 45366Most of the regulations passed in 1938 are no longer in affect. Not to say that section of Part 15 is any different. But certainly the world we use Part 15 in is.
In 1938, all transmitters available to consumers were electron tubes (voltage driven devices). Today nearly 100% of everything that would be considered a consumer grade transmitter is solid state (current driven devices). Not to mention, many of the devices included in Part 15 were only fantasy in 1938.
Since 1938, the FCC has grappled with regulatory creation for FM, television, satellites, wireless communications like spread spectrum, the internet, digital devices, BPL and a variety of services most of which have some significance to Part 15.
Cudos to the FCC for update work done in the last decade. But some point in the future, the FCC needs to embrace the growing number of Part 15 broadcast stations across this country. The thrust of my suggestion deals not with the devices used for broadcasting as much as their use. Regulations in other parts contain significant content involving service to the public. Why not Part 15 broadcasting?
Some Part 15 broadcasters do what they do because they have no other avenue to serve their neighborhoods and communities legally. Perhaps it is time to allow qualified individuals to provide very much needed services mega broadcast corporations are unwilling to provide.
72 years have passed since the Communications Act of 1934. And the FCC stills governs the public trust of radio spectrum with those same rules and regulations. Federal regulation must evolve with demand for new services and inventions.
Marshall Johnson, Sr.
Rhema Radio – The Word In Worship
http://www.rhemaradio.org
Total posts : 45366Just for the sake of discussion, if the antenna support proposed by kc8gpd was non-conductive (wood pole) and the antenna were mounted directly to the antenna (Hamilton AM100) with 3-4 guy lines/ground radials 20 feet in length with insulators to isolate the counterpoise effect extending from the transmitter chassis and equally spaced, would that not be a legitimate system if parameters 2 & 6 were allowed under a proposed rulemaking? Remember not every antenna support is conductive nor is every ground system buried ground radials. And by the way, AM broadcast stations have been licensed for decades with ground systems on the top of tall buildings. BTW they work pretty well too.
Marshall Johnson, Sr.
Rhema Radio – The Word In Worship
http://www.rhemaradio.org
Total posts : 45366Quote=kk7cw Just for the sake of discussion, (etc)
Elevated radials (two or more) can provide an artificial ground plane for an elevated, 3-meter vertical radiator installed just above the junction of those radials. The elevated radials won’t radiate if they are of equal lengths, and installed in the horizontal plane. This configuration does not need a conducting path to a good earth ground for most efficient radiation, and will radiate the same fields no matter how high it is above the earth. This antenna design was invented by George Brown back in the 1930s — the “ground plane” antenna.
The caveat here is that the elevated radials must be horizontal. If they slant down toward the ground as part of the means of guying the 3-m radiator support, they will radiate, and the effective radiating length of the antenna will exceed the length of the 3-meter whip.
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