There is only one rule defining voice content broadcast on a part 15 “intentional radiator” type station, all other rules distinctly describe technical allowances.
There is only one rule defining voice content broadcast on a part 15 “intentional radiator” type station, all other rules distinctly describe technical allowances.
The exceptional rule is not grouped with the Part 15 section of the rules, but is in Part 73 – RADIO BROADCAST SERVICES
Sec. 73.3550 Requests for new or modified call sign assignments.
(1) Users of nonlicensed, low-power devices operating under part 15 of this chapter may use whatever identification is currently desired, so long as propriety is observed and no confusion results with a station for which the FCC issues a license.
At the time I found that rule we had already been operating for two years as KDX, and our reasoning went through a few contortions before adding a number “1” making our part 15 call sign “KDX1”, definitely not an ordinary licensed station.
Those contortions of thinking that lead the way to that change was our finding that “no licensed station has been assigned the call sign KDX”, “In the present time licensed stations are assigned four-letter call signs, whereas a few legacy three-letter call signs still exist”. The letter ‘K’ is typically used for stations west of the Mississippi, but at least one exception ‘KDKA’ was assigned before the dividing between ‘K’ and ‘W’. There are also a few legacy ‘W’ stations west of the River. But after tossing around all these thoughts, we decided that ‘KDX’ sounded too much like a licensed call-letter.
Now that I’ve shared the whole story about why we are KDX1, I move on the the new question I am actually here to discuss…
In our sign on announcement we say that we are a radio station operating under “provisions” of the FCC Rules Part 15. We obviously can’t say “Licensed,” so I wanted a word that most exactly reflected what the part 15 rules allow or enable.
Those would be usable words as well… “Under Allowance of FCC Rules Part 15” or “as Enabled by FCC Rules Part 15.”
Maybe “As Permitted….” but I don’t like that because it implies a “Permit”, which is in the same class as a “license.”
Let me know what you think about wording what our kind of “unlicensed legality” actually is, boiled down to a single word.
a radio station operating
a radio station operating under provisions of the FCC Rules Part 15. – That’s what sounds best to me, as it is accurate, and definitely sounds more secure than a radio station operating under “sufferance” of the FCC Rules Part 15.
When Truth is Funny
Your words (Rich Powers)are based on the dry truth: “sufferance” was the word used in an FCC document describing what I would call the “tolerance” of part 15 radio. Although “sufferance” sounds like there’s pain involved.
Rich Powers, your perfectly sensible use of the word “sufferance” in your recent note puts it into a category of parody, satire, or jokes-man-ship, something not well suffered by the writers of legal wordage.
Anyway, it seemed funny to me.
How I Did It…
Carl, best I can do is share how I used to ID my old operation in Annandale VA back in 2000-2001:
“(:12 sec music bed) You’re listening to Annandale Terrace Radio — a ‘Part 15’ AM radio station — broadcasting legal and license-free on 11-70 AM; with music, information, and items of community interest. A-T-R 11-70 *IS* Annandale Terrace Radio, Annandale Virginia”.
The ID summarizes the whole package without getting too technical, and the ‘legal part’ happens after the overemphasized “IS” in the last line.
Then, 1x per hour around :12 after, I would play a produced 30-sec promo briefly explaining ATR and Part 15 radio in an entertaining way (“less power than a firefly’s tushie”), and including an email address for anyone wanting to know more.
You could probably get by with the same: “A Part 15 station”.
I’m working on Rolling Valley Radio now, about 4 miles from my old digs in Annandale; not quite on the air beyond the testing phase, but I’ll probably recut the old ID with the same wording when the time is right.
Best of Luck.
Contemplating
Your ID makes a lot of sense, Rolling Valley, because any listener who was actually questioning the legality of a station’s existence is probably already knowledgeable to what “Part 15” means.
A more typical member of the public would be very unlikely to question the presence of a station on the dial, and might take alarm only if a station was broadcasting something very strange or perhaps offensive.
Obviously the FCC, should they happen to monitor, might be appreciative of being told what type of signal they were hearing.
Yet, it is interesting to realize that, other than being advised not to mimic a licensed station, there is no requirement at all for an identification.
I get the impression that most stations are inclined to have an identity and also to associate themselves with their town or community.
Here’s a very spurious thought of the moment… spur of the moment thought….. what if a station claimed to be coming from some far away place? It wouldn’t break a rule….. “Radio Antarctica from the Ross Ice Shelf.” I may have said something like this before, it seems familiar.
Clear Identification
I too had to choose very carefully how my stations would be identified. There is a licensed station with the call letters “KROX”. So I improvised and came up with “K-ROCKS”. The FM and AM run on a separate SAM automation system and is set so that at 59:50 of every hour, it inserts the ID as saying…”This is K-ROCKS ZeroPointRadio AM and FM, Casper Wyoming. An FCC Part 15 compliant license free community broadcast station.”
To the average person listening, the first part of the ID would be easily understood as it identifies what they are tuned into. The second part…”An FCC Part 15 compliant license free..” would probably make most a bit confused as usually radio stations do not announce within their ID’s “An FCC Part 73 licensed station”. Thus the added part “…community broadcast station” was also added to give those who would be confused by Part 15 and idea of what it would mean…community broadcast station.
It seems to work really well with the public. And sort of sounds catchy too!
RFB
This is how I do the ID thing.
I guess you could say I have 2 programs.
The FM doesn’t go anywhere, so nobody
hears it but me. For my own enjoyment,
I took jingles from other radio stations,
and changed them. I have run different
callsign jingles through the FM. It is
practically a closed system, anyway.
One callsign I have used is an 3 old letter
American call that no longer exists.
Woops, I have to run. I will continue this
in a few minutes.
Bruce, DOGRADIO STUDIO 2
While Waiting
While waiting for Bruce to come back, let me say that I really like
“An FCC Part 15 compliant license free community broadcast station.”
It gets right down to the official part of the I.D.
But I cannot say “community station” because the community is on its own and doesn’t have a radio station. They are all seeing the stupid bowl…. foregive me…. the “super?” bowl… on wide screens.
But I am a personal radio station, programmed by me and for me….
and the listener is welcome to be my guest. Come and go at will. Provide your own snacks.
Long Short Range
“They are all seeing the stupid bowl…. foregive me…. the “super?” bowl… on wide screens.”
I heard somewhere it being referred to as “StuperBowl”.
Go….TEAM! Although I don’t really get into football much, I do pick a team to win for the big game and just wait till it’s over and hear the score on Part 15 radio…mine! 😀
That is..after referencing to the sports column in the newspaper the following day! In the meantime..the TV stays on either the weather channel or sci-fi!
Breaking down the definition for “community” in this case could go in different directions. Probably some would hear the ID and think “it must be a community effort”. Although I and I alone run and maintain and pay the expenses of my station’s operations, it does serve the community more than it serves me because I can broadcast to myself without the use of any kind of RF signal by simply turning on the stereo and pretending it’s a transmitter!
You just never know who is tuned in besides the radios in the front room. If you checked your signal coverage and it goes beyond the front door and fence line, there is a fair chance that others in the immediate area could be listening too. Getting confirmation of that outside of knocking on doors being met by iron skillet wielding house wives is when your at a store across town listening to a conversation in the next isle about a program you know only airs on your station!
Sort of makes me feel all warm and fuzzy inside! 😀
RFB
The Vanity Factor
RFB said, “I can broadcast to myself without the use of any kind of RF signal by simply turning on the stereo and pretending it’s a transmitter!”
Well, so could I, but using a radio transmitter has a “vanity factor.”
It is the super ego, the narcissist in us, believing that our taste is something special deserving of public display, that compels us to transmit in the open air. “Believe in yourself,” goes the adage.
This instinct should be, and here again we launch into an editorial position, a matter of human rights….. probably protected by an Amendment to the Constitution.
The part 15er doesn’t want much, on the other hand. We are not megalomaniacs, which brings us back to politicians.
OK. I’m Back
So if you look above – this is a continuation
of that upper message.
The other callsign I used on the FM is a
5 letter Mexican call – that was fun. These
were from pieces of jingles that were edited
and modified. It was the first computer audio
editing I did, and it took me a zillion years
because of my poor eyesight. But again – it
was really fun and it was worth it.
Again, nobody hears the FM but me, so I’m figuring
this is cool. Also, the FM is not on all the time.
The AM transmit operation is a different story.
For the 3 years it was running, it’s was always
just “Dog Radio, Part 15.219.”
So that’s what I did with the ID thing.
When the AM comes back on, whether is is CC, or
Part 15.219 – it will have different programming
than the FM.
So that’s how I do it here.
Bruce, DOGRADIO STUDIO 2
I Thought So
I knew it. You are a fake Mexican.
Don’t go to Arizona.
KDSX The Old legendary AM And The Relatively New Part 15
Carl the identification you’re talking about is how i came up with KDSX because back in the 30’s a new am station came on as KDSX AM 950 Sherman, Texas i cant find a logo for the station but it was a legendary and has decent history to it too. unfortunately its a long story and as the story goes and all the way to the late 90’s or early 2K when they moved to 1700 AM and change letters to KKLF and dropped the KDSX Call Sign. In early to mid 2009 i changed the old call sign of WVMB to KDSX was a great choice for me and legacy of KDSX continues as a part 15 radio station and proud to be a part 15 fm radio station.
An I.D. Story
Last night I solved a special situation by sending an I.D. based on the Rich Powers Method, as follows:
“This is Part 15 Radio Station KDX1, closing our internet stream for copyright compliance during the next program. Broadcasting continues on AM, FM and Shortwave. Our internet stream will return at a later time.”
Then I aired a program that was not cleared for internet use.