I don’t know if any of you read this before, but it was a first for me…
I don’t know if any of you read this before, but it was a first for me…
I have heard it expressed repeatedly that part 15 originally was NEVER INTENDED as a means to publicly broadcast radio to a listening audience. It’s been said numerous times on this forum and that forum, by advocates and foe alike..
Well, guess what an official FCC document stated 36 years ago?..
I excerpted some key points from this document, not all of it positive, please read it all, but make special note of the paragraph in bold..
Part 15 of our Rules permits operation in the AM Broadcast
Band of a miniature transmitter, called a Low Power Communication
Device, without an individual license provided that the input power
to the device does not exceed 100 milliwatts and that the total length
of the transmission line plus the antenna does not exceed 10 feet.... etc. etc.
These technical specifications are designed to limit
communication range for the protection of authorized radio services
from harmful interference, and yet are considered to be sufficiently
lenient that a reasonable operating range is provided for a Low Power
Communication Device. Moreover, regardless of strict adherence to
the technical limitations in Part 15, a Low Power Communication
Device is permitted to operate on a sufferance basis only,
Intermision..
===============================================================
suf·fer·ance
Noun: Absence of objection rather than genuine approval; ie: toleration.
================================================================
Because of this overriding noninterference condition and the severe technical
limitations imposed, Part 15 cannot be used to provide a regular broadcasting service.
The intent of Part 15 is to provide the radio enthusiast with
an opportunity to experiment with radio, and to entertain friends or
neighbors within a very limited communication range.
Ain’t that great!!.. unfortunately in the next line it dampened it a bit..
The Commission never intended that Part 15 be used to establish a low power
broadcast facility to service an entire community.
Well, I never intended to drink more than a couple beers last Saturday, but the actual result was that I got drunk off my butt. – Probably a bad example, but the point is that intent only gets the ball rolling, it doesn’t determine the extent of how far it will go. — In other words, initial intention ain’t the law (is it?).
But anyway, the big ta-da is that the FCC acknowledged the intent of part 15 is to enable broadcast to your neighborhood – 36 years ago!
What do you all think about that?
Source:
http://transition.fcc.gov/ftp/Bureaus/Mass_Media/Databases/documents_collection/74-87.pdf
Here it is in in entirety..
Here it is in in entirety.. It may be easier to read then the original pdf.
————————————— 1
360 Federal Communications Commission Reports
F.C.C. 74-87
BEFORE THE FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON,D.C. 20554
In the Matter of
WAIVER OF PART 15 OF THE COMMISSION’S RULES TO
RELAX THE TECHNICAL LIMITATIONS IMPOSED ON THE
OPERATION OF A LOW POWER COMMUNICATION DEVICE
IN THE AM BROADCAST BAND
ORDER
(Adopted January 30,1974; Released February 13, 1974)
BYTHE COMMISSION:
1. By a letter received on October 2, 1972, Victor H .Fischer,
Pittsburgh Pennsylvania, representing himself as the spokesman for a
group which calls itself Western Pennsylvania Youth Radio, petitions
the Commission to waive the technical restrictions imposed by Part 15
on input power and antenna length permitted for a Low Power Communication
Device operating in the AM broadcast band without an individual license.
The petitioner desires to furnish a noncommercial educational radio service
to his community by using equipment which cannot comply with Part 15.
2. Prior to requesting a waiver of Part 15, the petitioner was
operating a six-watt transmitter and carrying on the low power
broadcast operation described in his petition. Such operation was the
subject of a complaint which was investigated by the Commission’s
Field Operations Bureau and the petitioner was informed that his
operation did not comply with Part 15 and that such operation (without
an individual license) was in violation of the Communications Act .
As a result of this admonition, the petitioner terminated his operation .
The petitioner then sought legal status for his operation, and in a letter
to the Commission dated September 5, 1972; requested a license to
operate a noncommercial educational community service radio station.
The Commission’s reply, dated September 15, 1972, informed the petitioner
that his proposed operation was not eligible for licensing under
any of the provisions set out in the Commission’s Rules for a broadcast
station. Our refusal of the petitioner’s request prompted the filing of
the subject petition.
3. Part 15 of our Rules permits operation in the AM Broadcast
Band of a miniature transmitter, called a Low Power Communication
Device, without an individual license provided that the input power
to the device does not exceed 100 milliwatts and that the total length
of the transmission line plus the antenna does not exceed 10 feet. In
addition,our Rules limit the level of emissions on spurious frequencies,
and the amount of RF energy that may be conducted into public
utility power lines. These technical specifications are designed to limit
communication range for the protection of authorized radio services
from harmful interference, and yet are considered to be sufficiently
lenient that a reasonable operating range is provided for a Low Power
Communication Device . Moreover, regardless of strict adherence to
the technical limitations in Part 15, a Low Power Communication
Device is permitted to operate on a sufferance basis only, and in the
event harmful interference is caused to any licensed radio station,
operation must cease promptly. Because of this overriding noninterference
condition and the severe technical limitations imposed, Part 15 cannot be
used to provide a regular broadcasting service.
4. In essence, the petitioner proposes that the Commission suspend
the technical limitations in Part 15 to permit him to carry on a
nonlicensed operation providing coverage and service that would resemble
a regular broadcast operation. Because relaxation of the technical
specifications and operating conditions set out in Part 15 would
greatly increase interference potential to the regular broadcast service,
the Commission has not granted such requests as the petitioner’s in
the past. The intent of Part 15 is to provide the radio enthusiast with
an opportunity to experiment with radio, and to entertain friends or
neighbors within a very limited communication range. The Commission
never intended that Part 15 be used to establish a low power broadcast
facility to service an entire community.
5. In support of his request, the petitioner sets out the technical
requirements for his proposed operation, and merely states that interference
will not be caused. The petitioner has offered no information
or technical data to justify waiver of our rules; moreover, there is no
showing how the public interest would be served if the restrictions in
Part 15 were suspended to permit the petitioner to carry on his proposed
operation.
6. The Commission is not convinced that grant of the petitioner’s
request is either justified or appropriate . Accordingly, IT IS
ORDERED That the petitioner’s request for waiver of Part 15 is
DENIED.
FEDERAL COMMUNICATIONS COMMISSION,
VINCENT J .MULLINS, Secretary.
45 F.C.C. 2d
Original document: http://transition.fcc.gov/ftp/Bureaus/Mass_Media/Databases/documents_collection/74-87.pdf
Typical
“5…The petitioner has offered no information
or technical data to justify waiver of our rules; moreover, there is no showing how the public interest would be served if the restrictions in Part 15 were suspended to permit the petitioner to carry on his proposed operation.”
Basically what that part is saying is that the petitioner has not submitted a high enough bid nor has spent enough big bucks into the coffers or given a sacrifice of the petitioner’s first born.
And big stations prove they are serving the public interest?
How? In what way? How often..if at all?
And where does the FCC get their data to support licensed stations are and can prove they are serving the public interest? Because the public does not protest when it’s time for the station to renew its license?
Well the public is not going to take time out of their already way over-flowing busy schedule trying to make ends meet in this wonderful economy to worry about some radio or tv station’s duty of serving the public interest because the public was forced to concentrate on something else.
And there have been examples of public decision being tossed aside for special interest in the past.
The public might be a bit distracted but they are not stupid nor do they forget…especially when those decisions are made by those who the public put the trust into.
A round and round late night discussion for a talk show. One that most certainly will not air on corporate controlled media.
And maybe that is what the establishment is afraid of…the truth getting out and a huge awakening of the masses.
Makes sense to me.
RFB
Yeah, in the way those last
Yeah, in the way those last couple paragraphs were worded, if you reverse the conclusion of the actions, it indicates that if the petitioner had provided data to show ‘that interference will not be caused’ by ‘the technical requirements for his proposed operation’, and detailed ‘how the public interest would be served if the restrictions in Part 15 were suspended’ as a means to “justify waiver of our rules”, then Commission could have deemed ‘the petitioner’s request as either justified or appropriate….
Then end result would have been: ‘the petitioner’s request for waiver of Part 15 is’ APPROVED.
Now, not saying that’s what would have happened, but the last paragraphs of the official document do indicate those are the very reasons why the request was denied.
Raises Eyebrow
“but the last paragraphs of the official document do indicate those are the very reasons why the request was denied.”
Could it be that simple? Simple enough that if the specified data the FCC points out in that denial were to be met, would the FCC grant authorization to a low power AM station under 250 watts?
I doubt it. I am sure some other roadblock would get in the way…..say a local station afraid of some low power, low budget, low range competition.
RFB
I agree. Like I said.. I’m
I agree. Like I said.. I’m not saying that’s what would have happened, just that it is what was indicated from the way it was written.
Commenting Again
After now seeing the full length version I absolutely agree with the last few comments made here in the thread, and I find the Commission’s reason for denial pretentious and condescending.
Common sense can decide whether 6-Watts would interfere with the majestic licensed but overwhelmingly boring stations, and as for “serving the community…” It’s glaringly obvious that communities aren’t being served and someone who hopes to do so deserves the opportunity, or we’re left with nothing, which is what the decision achieved.
In “Robert’s Rules of Order” there is a formal tactic known as “Suspension of the Rules,” whereby a formal board can accomplish something not easily possible within the rules, by “suspending the rules (meaning, in that case, the bylaws, but it could also mean the FCC Rules)”, the Board is then free to accomplish what it wills to accomplish.
In my reality opinion the FCC 36-years ago and now doesn’t want to open the door on “reasonable exceptions to their rules” because if they do it will create more work and fewer coffee breaks.
Prospective
“In my reality opinion the FCC 36-years ago and now doesn’t want to open the door on “reasonable exceptions to their rules” because if they do it will create more work and fewer coffee breaks.”
It is actually a part of the global wide, destruction by design of spokes within the economic wheel of progress.
Maybe a different prospective is warranted here.
Ever walk into a government building..doesn’t matter what agency or city or state. Ever notice how they all have the very same dry, dull, over-bloated atmosphere…stale….empty..void of creativity and individuality.
Grasp that, and you understand why 6 watts would be such a problem.
RFB
What a Share
I mean, thanks for finding and sharing that page of history, Rich Powers.
I like your comments about what was being said along the line and agree with your takes.
I even thought that the phrase “was never intended to service a whole community….” could not be said in any absolute sense because it depends on how one defines “a community,” which could vary widely.
We also have the expression “intentional radiator” on our side of the case.
I also tend to think of the word “assumed” in place of the word intended: we never “assumed it would be used to service a community.” That would sound like a regret, as in “We should have banned service of a community, but darn it, we didn’t.”
They don’t remember what was said 36 years ago precisely because of beer. If they haven’t de-intended Part 15 by now, we have nothing to worry about.
Another point of view? You
Another point of view? You can have the glass half empty, or half full. I prefer the half full approach.
If the FCC and Industry Canada opened the door to higher power, then there would literally be chaos on the airwaves. Even with the rules today, I’ve run into illegal transmitters countless times.
I really have no problem with letting those who pay the big money for licenses get most of the perks. And if anyone thinks that radio stations make big money, think again.
I think that it’s great that there are provisions for unlicensed broadcasting, even if range is limited (and it wasn’t really intended). In this holiday season, I’m thankful that I can do this Part 15 thing as a hobby, unlicensed, with relatively few rules (other than output power or field strength), and with relatively little money outlay.
Being Adaptive
Radio Artisan what you are exhibiting is the art of adapting to the world that is rather than struggling for the world that could be.
Being adaptive is no guarantee of survival, but it can result in survival because it is also known as “low profile”, where one does not bring attention to one’s self.
This is neither praise nor criticism, I am just making what I think is a fair description of your position.
All the participants of this website are adapted to the status quo, because we all follow the rules as they are.
But some of us practice that lost American art of “protest speech,” once considered a plain right, now viewed as dangerous and unwise.
Chaos?
“the FCC and Industry Canada opened the door to higher power, then there would literally be chaos on the airwaves. Even with the rules today, I’ve run into illegal transmitters countless times.”
Exactly how would there be such chaos on the airwaves if the FCC opened up a low power radio service? And WHAT would that chaos be exactly?
That was the same argument way back when LPFM was debated back and forth for years by the NAB/SBE and petitioners for the service. Where is the proof that the low power levels will wreak chaos today with all these LPFM stations flooding the low end of the FM band???
It never happened. And it wont happen with another LPAM or real LPFM service.
See here is where I have a serious problem with the idea that opening up power levels a bit will cause chaos. Exactly how would it cause chaos? How would chaos result when the opening of power levels of 10 watts or less were to take place when following the technical specifications for the service in order to be granted the license for that power level?
If a person were to use every technical trick in the book to put out a spectral clean signal, did their homework to find a frequency to not cause intermod and out of band interference, installing all the necessary filtering and monitoring, just like the big stations do…then WHERE will this “chaos” come from???
From the “pirates” that will continue to throw up dirty signals at power levels even way beyond authorized low power levels?..Of course. But WE ARE NOT THE PIRATE OPERATORS!!!
We cannot expect the FCC to take our position seriously if we keep putting our operations and intents into the same basket the FCC puts pirate operations in.
We need to crate our own basket, one that clearly shows the difference between serious low power broadcaster and the idiots just doing things out of spite or hate.
We are not part of that group at all. Therefore we should not dip our sticks into that sand pit and try to convince the FCC to give us higher power levels when we are talking to them from the prospective of wreaking chaos!
We MUST prove that we can transmit a clean signal at higher power levels and operate these with responsibility and meet every single technical requirement to avoid that chaos.
We have to separate ourselves from the bad element. Like separating the wheat from the chaff. Yes a long difficult process…but doing nothing or planning nothing ends up in nothing too.
RFB
Another point of
Another point of view?
Submitted by ArtisanRadio on December 21, 2011 – 11:07.
…I think that it’s great that there are provisions for unlicensed broadcasting, even if range is limited (and it wasn’t really intended). In this holiday season, I’m thankful that I can do this Part 15 thing as a hobby, unlicensed, with relatively few rules (other than output power or field strength), and with relatively little money outlay.
I just read this thread again — a year later.. and just felt compelled to say; I love your above comment (in a part15 kinda way) 😉