There is no requirement in the Part 15 Rules for an un-licensed station operating as a part 15 intentional radiator to identify itself on the air.
There is no requirement in the Part 15 Rules for an un-licensed station operating as a part 15 intentional radiator to identify itself on the air.
In fact, there is nothing said about programming or speech in any sense, as the Part 15 Rules deal exclusively with technical requirements.
Meanwhile, in another section of the rules, namely Part 73, which pertains to (licensed) Radio Broadcast Services, something of importance is said, with reference to “part 15”:
73.3550 (1) Users of non-licensed, 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.
It is fair to quibble over the failure to post this rule in the part 15 section, and having done so I will move on to a discussion of what is being said.
“May use” is an important phrase, because it supports my opening remark: “No requirement is made for a part 15 station to identify itself…” If you “may use whatever i.d.,” that leaves the choice of using none.
But part 15ers are inclined to scale themselves along the lines of full-power stations, and this typically means having an identity.
“So long as propriety is observed…” This is a guideline well worth a visit to the dictionary:
pro-pri-ety 3: appropriateness 4 a: conformity to what is socially acceptable in conduct or speech b: fear of offending against conventional rules of behavior.
This part of the rule is not as clear as it tries to be, as we are a Nation that includes non-conformists as a protected segment, and criticism of conventional norms as fair ground for discussion (difference of opinion).
“…and no confusion results with a station for which the FCC issues a license.” This is somewhat obvious, but does leave room for interpretation. For example, we would not say “This is WABC 770 New York,” which is a well known licensed station, but many part 15ers use legacy call letters from stations that “once were,” and this is probably acceptable because those stations are no longer licensed (the rule speaks in the present tense).
I am considering operation with no on air identity. But before I do, I would appreciate feedback about what you think of the idea.
Identification
I have never seen a cite for improper identification for a part 15 station. This doesn’t mean one doesn’t exist nor that “KDX radio” is a legal identification.
The phrase “confusion results with a station for which the FCC issues a license” could apply even if no licensed KDX exists since “a station for which” can refer to a class of stations and not a specific station despite the singular case. I take this to be ambiguous. However, the phrase “confused with a particular licensed station” would be clearer but this doesn’t necessarily mean that my interpretation is right.
What was the intent of this rule? To avoid confusion with a specific licensed station or to avoid the implication that the part 15 station is licensed? It is only my guess that it is the latter.
It appears the chance for a problem is small but not nonexistent.
Neil
This N That..Cuz Its Where Its At
Licensed stations are issued or are approved of call letters and are forever assigned to those stations. A non-licensed station to copy cat the identification of a licensed station is kin to impersonating a police officer. Bad idea.
I don’t see what the confusion would be in the rule. You simply cannot use an already assigned station identifier issued under license by the FCC. The statement within that rule “Part 15 stations can use whatever identification they wish” does not mean your freebie green light to start using call letters assigned to a station under license by the FCC no matter where it’s located. It means you can identify your station in any other way you see fit as long as you do not use identifiers already in use and assigned.
Seems pretty simple to me. I doubt its reasons are to prevent public confusion, but more to protect the licensed stations assigned call letters which is their identifier.
Sort of like a copyright that cannot be re-licensed to anyone else ever, other than the exception of a license ownership transfer.
And the majority of licensed stations have call letters that are specific to either the station’s location, or program format, which makes those call letters special and should be and are protected as those call letters also serve as the licensed station’s legal identifier. So you have a few things there associated with those call letters that are specific to each licensed station. Just as their channel is protected, their identifier is also protected.
RFB
Point Well Taken
The point you (radio8Z) make is the same as what I assumed by the rule, namely that by simply appearing similar to a licensed station (a class of station) a part 15 station would be in violation of 73.3550 with the letters “KDX.”
Of course that puts the legacy (unlicensed) call letters used by some part 15ers into question.
It is for the reasons noted by Radio8Z and agreed with by me, that a few months ago I changed my on-air call sign to KDX1, as there are no licensed stations containing numbers in call letters.
A few days ago I changed even farther away from appearing licensed by calling the station “Worldround Radio.”
But now I am considering a “no name” approach, which would leave the listener to think of us as “the station on 1680.”
Station ID
Sure, it makes sense that the FCC doesn’t want unlicensed stations to be confused with a licensed station by a local listener, much the same as the non-interference clause. It’s like cheating to pass yourself off as a licensed station by using their call letters, could even considered obstruction of business. But I see nothing wrong with using call letters that aren’t for licensed stations, or for legacy stations where the call letters have not been re-issued for a licensed station.
But what about this:
You gain permission from a licensed station to do a localized re-broadcast because most people’s radios can’t get it, or they don’t have computers, etc. During that broadcast, that station ID’s itself.
Now what? Should we take the responsibility to announce it as a re-broadcast from another station both before and after the segment (how I’d probably do it)? What is appropriate?
CYA
“You gain permission from a licensed station to do a localized re-broadcast because most people’s radios can’t get it, or they don’t have computers, etc. During that broadcast, that station ID’s itself. Now what? Should we take the responsibility to announce it as a re-broadcast from another station both before and after the segment (how I’d probably do it)? What is appropriate?”
To protect yourself and to help clarify to the listener, announcing it is a re-broadcast originating from such and such station would be the way I would do it.
Using no form of identifying your station simply puts the listeners into limbo mode as to who and what they are tuned to. Do any of you really think that the public tunes into radio to make sure they are listening to licensed stations or non-licensed stations and that they would allow confusion to get in the way of something they dont even care about to begin with???
Reading too much into things and squeezing blood out of a non existent turnip IMO.
It’s your choice to use something to identify your station with, or use nothing at all, as long as you don’t use already assigned call letters when you do identify your station.
But I’m glad the confusion got defused quickly..or is it?
RFB
A Close Reading
A close reading of the opinions given by the last several members brings radio8Z’s comment front and center, when he said “..there is ambiquity.” The opinions vary from one another on at least one count…. whether an I.D. is that of a currently licensed station, versus whether an I.D. resembles the call letter of a possibly licensed station, which would be true of “KDX.”
The other problem, giving a disclosure that you are broadcasting the program of a licensed station with permission, is all well and good. But it only matters if the listener stays tuned long enough to hear the disclosure.
Even legal call letters can be confusing, and I have an example from the 1960s. A retired Judge Kady started an AM station at 1460 with his name as the call letters. I discovered the new station by DXing one day, and was first captured because I knew the announcer, who said “This is Kady…K-A-D-Y….”
I seriously thought he was saying, “This is K-D-K-A-D-Y, a six-letter call sign!
Generic No Name
It’s official, my various frequencies carry fine programming minus any station-identification.
The stream is also unidentified on the audio portion, but the website contains full station identification.
Not affiliated with any other “anonymous”
Too Much
Ken Norris asked what might be good practice when re-broadcasting a program, with permission, from a station that gives its call letters within the program.
RFB believes it would be good practice to announce the originating station and permission, as self protection and courtesy to listeners.
But we have no rule addressing this issue.
In my case I mention all permissions along with program descriptions on our website.
The sun is going down now on the NO I.D. STATION and I have not wondered what station it is.
No Numbers in Licensed Stations?
Carl, I manage our city’s TIS AM station. The call sign is WQGD298. And then there are translators which have numbers in the call sign.
Myself, I ID as MRAM and no stations would have that call at least not in this country and generally I identify as a Part 15 station at least once an hour.
That’s Right
You are right MRAM, and it was right in front of me but I didn’t notice it, translators and TIS stations indeed have numbers within their call sign.
But since there is no requirement for a Part 15 station to I.D. itself, I have decided not to impose a burden on myself that doesn’t exist.
MORE ABOUT NON-REQUIREMENT:
Just as a part 15 station is not required to identify itself, it is also not required to announce its location. The station’s location is made obvious by the small area covered by the weak signal, but no special announcement is required. Going to an extreme, there is no restriction about announcing a far-flung location, like “From a solar powered cabin in the northern-most woods of Wisconsin,” or, “From the penthouse of the 21-story MRAM Building on an island in the Ohio River.”
All licensed radio stations
All licensed radio stations have call signs. HAM radio operators have individual license call signs, whatever station they may be operating in the HAM bands.
Yet Another Twist
Until just now reading Ken Norris’ post about HAMs having call signs, I just re-read 73.3550 and it says “so long as… no confusion results with station for which the FCC issues a license.”
That also means, I am only now realizing, that a HAM cannot use his call letters for a part 15 station.
Call Signs
A ham cannot use their call sign for anything other than operating ham stations, be it theirs or another ham operators station, at that point I think the requirement still is to not just call out the operator’s call sign, but the originating station’s or other ham operator’s call sign if the visiting ham operator is running the other operators station.
Although there is no requirement for identification for Part 15 stations, it’s a good idea to come up with one that not only prevents confusion, but also gives the Part 15 station a uniqueness from everything else. Stations are heavily linked to their identification and frequency on the dial, adding more to the recognition of what the station is and what they air.
I don’t think it’s any added burden or trouble to identify your Part 15 station, I look at it as a courtesy to listeners and to allow your station to become familiarized to the listeners by how it identifies itself. Just using “Part 15” as an identifier really doesn’t give the station any uniqueness at all, in fact to me that is sort of a gray scale dull hum drum way of identification, no uniqueness, nothing special here move along.
And why not give your Part 15 station a unique identifier? Just because there is no requirement, does that mean you have to set aside making your Part 15 station special and unique in how it identifies itself?
RFB
Pointless Experiemnt
Everyone is more reasonable than I am right at this moment in time regarding the I.D. question for part 15, but I am right now enchanted by the fact that there is something I am not required to do, so I am seeing what life is like by not doing it.
Probably after having made no point whatsoever I will return to being a station with a name.
But for now I’m actually having fun.
“What are your seven stations called?”
“Nothing. Just, stations.”
I think also there is no law that dogs must be named. So why do people do it?
No Name Radio
Well I have heard of no-name brands but no-name radio..that’s a first.
“Thank you for tuning in to No-Name Radio, where No Names are mentioned to protect the guilty who bring upon themselves more confusion than what is necessary. Next…the No-Name Show with host Nameless Name. Today’s discussion, the wide range of no names. But first..Seals and Croft singing their great classic A Horse With No Name”.
:p
RFB
RFB Gets It
I think my “generic no-name” radio idea is sinking in.
Today is day two, and I find no-name radio “smooth,” even better than non-commercial radio, which actually does have commercials that are called “Under-writing messages.”
On “no-name” it’s all about the message (the program) not the messenger (the station).
This much fun at times approaches happiness itself.
Making low power lower, everyday.
Desert Radio
Seals and Croft? Huh-uh, done thingso … America recorded A Horse With No Name.
But anyway, I’ve been signing on and off with “This is Friday Harbor Tiny Radio … FHTR … The Voice of Friday Harbor”. I think I’ll put some whale sounds, a clanging buoy bell, and a ferry horn in the background.
That oughta do it, eh?
No Name And Wrong Names
Well let’s chime it up as no name wrong name! 😛
RFB
Hi RFB
This is neither here nor there, but –
I always like the little expressions
you put after your comments.
Is there a name for those sideways
characters that look like faces?
Best Wishes Always
Bruce, DOGGRADIO STUDIO 2
Return of the ID
While lunching salmon on whole wheat my brain swam back upstream and I decided to have IDs again, after all week with no ID on my frequencies.
But no voice. No. These IDs will be Morse code. And the tones will not be shrill. They will be soft and low modulation.
It may take another week to produce the Morse IDs.
I think those side-ways smiling faces are meant to be smiling faces, but they have no lower limbs so they roll on their side.
Part 15 radio ID
My not-required “legal ID” on the Part 15 AM station mostly has been “Big D Country, Tallahassee.”
Seriously, Carl – Whatever Makes You Happy Is The Bottom Line
I know of some Part 15 stations that
do not identify at all.
I have a broadcaster friend in Virginia
who has a collection of equipment, and
a certified FM transmitter. The operation
is so casual, that he just plays music,
and doesn’t identify. This is a guy
who did a lot of work in radio and TV.
His computer does most of the programming,
but he also has some reel to reel machines,
a cassette deck, a CD player, and a
mixer.
He runs the station on weekends and uses
it for music out in his yard. It probably
goes farther, but he enjoys it just for
himself.
Now that I think of it, I can think of several
part 15 FMs that just run and don’t ID.
These people are so casual about it, that
they don’t even know about Part 15.US.
But their operation is making them happy.
They all were ex-broadcasters, and having
these small stations fills a hole in their
lives. Which is exactly what my station
does for me.
So Carl, don’t worry about it. If you
decide to come back with an ID at some
point, you can do that. Otherwise, just
enjoy the ride.
Best Wishes,
Bruce, DOGGRADIO STUDIO 2
Sounds Boss
Your not required ID sounds boss, radio boy. I like it.
Here at the generic station, I’m still running on nameless autonomy, except when my letters slip out during shows like The Low Power Hour and Blare OnAir. But I also have programs from WBAI New York and many other sources that name themselves during their programs, so who knows what after a while.
I still intend to introduce Morse Code IDs.
Broadcasting from a steamboat on the Mississippi.
I had forgotten about this, but…
Back when my 1690 kHz was on – in the audio
chain, it had a “VOX – voice or audio
operated relay.”
When music was playing, the relay would
be shut. Between songs, when there was
silence, the relay would open. This would
short some contacts and fire off a Radio
Shack voice module, that would say,
“Dog Radio, Part 15.219.”
When the music came back on, the relay
would shut again, and the module would
stop giving out the audio ID.
It worked really well, but was very
very hard to set-up. If there was
noise, or ground-loops, or the
dynamic range of the audio was wrong
for the settings of my “ANTI VOX” –
it wouldn’t work right.
Best Wishes,
Bruce, DOGRADIO STUDIO 2