The recent decision by the federal government (FCC/OET) regarding Ken Cartright’s operation in Stayton, Oregon has put a chill on micro-broadcasting for all who participate. One could assume that this rules enforcement net will extend to other transmitter manufacturers and operators.
A recent offering on the web puts the real issue front and center in the discussion:
[LPAM] Re: KENC & The FCC
From: [email protected] on behalf of Jeffrey ([email protected])
Sent: Fri 7/09/10 7:45 PM
To: [email protected]
“From this development, it is becoming increasingly evident that the notion we all originally entertained – that it is possible to create a legal, license free, 100 milliwatt micro-service on AM that would be totally kosher with the FCC, and we would all be left alone – was unfortunately, a collective illusion ( ….with all due respect to pioneering sites like part15.us and hobbybroadcaster.org.)
I wish there was the time, money and means to lobby the FCC to FINALLY empower we individuals and create a “hobby class” of FCC license, perhaps 1 watt or a half watt on both bands, with no antenna/ground restrictions (for the sake of simplicity) and just leave it at that. It’s also time we finally make the term “pirate broadcaster” obsolete on the AM and FM bands in this country.
A few years ago, the FCC allowed a proposal for a 25 or 50 watt LPAM service to fall into limbo. The least they can do at this point is allow a 1 watt or half watt hobby service. But of course, I’m not holding my breath. As we all know, they take seriously corporate broadcasters, NPR, and even Prometheus and the “non-profit” groups and committees that outfit so reveres. But us? No way because we can’t be easily controlled.” [email protected]
Discussing and debating the correctness of the government and its agents decisions at this point is pointless. Every time a Part 15 “broadcast” station is turned off, we all lose regardless of the reasoning. If someone could explain how this makes us better at what we do and promotes the use of the public spectrum trust, you have found a willing listener. Please make your suggestions civil and truly useful, not the same old illusory opining.
Should the FCC continue on this track for the foreseeable future, how is ” the collective illusion” bringing us closer to acceptance and rule compliance? Will this result in the death knell of Part 15 community micro-broadcasting? I would suggest the end of such a service to many neighborhoods and communities does not enrich our lives or the lives of others.
Are there concrete assurances that operating some other kit transmitter or certified and manufactured unit won’t be the next government enforcement target? The Rangemaster is in the cross-hairs currently. And, I hope you would agree Keith Hamilton and Ken Cartright have made a good faith effort to move the ball toward the goal line of acceptance and compliance.
Yes we need a common voice that can take the message to the government that an AM micro-broadcasting service should be legal and have simple and consistent standards of operation. LPFM has just such a voice and it’s expanding…slowly. However, our independence has become our greatest foible. “-Because we can’t be easily controlled” is the exact reason we cannot gain the ears of law makers and agency wonks.
Over the past few years, I have read hundreds and thousands of opinions from folks in the U.S. and Canada regarding Part 15 and micro-broadcasting issues. Most of it has been civil. I have read the mathematical calculations and the science of radio well beyond most readers. It has not changed the result of practical application very much, if any. Message sent, message NOT received.
It is conceivable, Part 15 community micro-broadcasting does not have a future. And maybe, in reality, it never did.
Most hobbyists really could care less about community wide micro-broadcasting. Their OTR or NWX programs, DIY projects and antique radios are the reasons they even read most postings. These folks are not interested in moving the micro-power broadcasting effort forward. What will they gain? As along as they can hear their transmitter in their own radios and not produce interference, that is good enough. Part 15 micro-broadcasting for some is counter to their purposes.
After 5 decades of being in love with the harlot called radio, I find some satisfaction and comfort in accomplishment and fond memories. Even if I walk away, the memories will continue. CW McCall said, “Memories are like star light, they go on forever.” And even if Part 15 broadcasting never really happens, the memories will go on.
These are my feelings about where I am and we are. And I have learned not to argue with how people feel. My feelings represent the truth for me. How about you?
I agree
I would be absolutely saddened if the FCC decides to move forward with shutting down our Part 15 Operations.
I try and serve my community no matter how little of it I actually cover.
There’s 237 people that can hear my signal and I try to serve them.
Where I live our Oldies station abandoned the 50’s & 60’s and is starting to can the 70’s.
If I were to be silenced the neighborhood I serve would lose its community voice and Oldies music.
Not to mention my other 2 stations that serve their own niche respectively.
the fcc just needs to leave
the fcc just needs to leave the part 15 am b,casters alone. if they come and see 100mW average input +/- 20mW and a certified unit then they should just leave the b,caster alone.
there is no reason for all this nonsense the fcc knows it. the agents i beleive don’t like it. they are getting pressure from washington who is getting pressure from NAB/NPR, etc.
there seems to be a few rogue agents who are bust happy and get off on it, but they are few. i beleive most field engineers don’t agree with this aggressive enforcement policy.
The FCC and “microbroadcasting”
The FCC is certainly not interested in facilitating license-free broadcasting under Part 15, and it never has been. Their mission is to reduce interference to licensed stations. Of particular interest is their position about skywave interference by Part 15 stations. By this, it is not meant that a Part 15 AM station is able to interfere with any other station by skywave. There is no way that a Part 15 signal can survive the path attenuation and ionospheric absorption of a skywave bounce. What is meant is that the composite effect of thousands of Part 15 stations adds to the background noise in the AM broadcast band, which is also propagated by skywave. The electrically-short antennas used for Part 15 AM stations have a strong component in the upward direction. I seriously doubt that all of the Part 15 stations in the US contribute significantly to the other causes of MF background noise, like lightning, automotive ignitions, AC power line noise, electrical machinery, etc. Nevertheless, the fact that skywave is mentioned at all, shows how hypersensitive the FCC is about even the very low potential for interference by Part 15 stations.
However, I also don’t see that the FCC is trying to shut Part 15 stations down. They seem to me to be trying to maintain the status quo; said status quo being that Part 15 stations are, at best, only marginally useful for anything resembling “broadcasting.” They went after Ken Cartwright because his station was too good in the broadcasting role, and they found enough reason in the rules to get two of his three transmitters off the air. It really doesn’t matter to them that Ken was serving his community. They actually require community service from licensed stations. They are not interested in community service under Part 15 that they do not control by regulations.
There has to be some public interest aspect of Part 15 AM that causes the FCC to allow the little bit of it that it does allow. I don’t know what it is. Since they clearly do not care about public service by Part 15 broadcasters, what remains is the technical education the Part 15 operators receive while pursuing their hobby. It is actually quite a challenge to get a Part 15 transmitter to work. Originally, the Section 15.219 rules were intended to allow hobbyists to roughly demonstrate compliance to 15.209 limits without having to have a certified field strength meter. Then, the loading coil was introduced to Part 15, and field strengths several hundred times the 15.209 limits were possible within the rules. Despite the advantage of the loading coil, the FCC has not tightened up the rules to negate the increased field strength that results. So, I think that the FCC sees some public interest advantage to the experimentation pursued by Part 15 AM hobbyists, similar to part of the rationale for allowing amateur radio to exist.
Sounds Like They Turned Up Their RF Gain Control This Time.
Sounds like the FCC turned up their RF gain control, bought bigger and better loop antennas, and put up bigger long wire antennas. So if a kid wants to play with his or her lab kit and build a AM broadcaster that makes them upset now right? I guess we have to use less power like less than 9 volts AA battery power and a very short antenna. Wow, I wish I would of worked for the FCC they are doing things I wish I was doing with my radio equipment. How in the heck can you receive a part 15 radio station 8 miles away?? They must use some kind of low noise active antennas, and broad band signal sweepers. I guess I will be encouraged to monitor other part 15 stations and build a 4 foot AM loop antenna which I bet the FCC engineers already have built one and they control it remotely outside. I have seen loop antennas before that are magnetically shielded that picks up everything on the AM and LW bands. Ah Ha! That’s why that guy got shut down, they are using magnetic loop antennas that are 10 feet big. Magnetic loop antennas with RF amplifiers and a excellent communications receiver can really pull in a very weak part 15 signal.
Community Service as a Part 15 Standard?
“They actually require community service from licensed stations. They are not interested in community service under Part 15 that they do not control by regulations.
There has to be some public interest aspect of Part 15 AM that causes the FCC to allow the little bit of it that it does allow. I don’t know what it is. Since they clearly do not care about public service by Part 15 broadcasters, what remains is the technical education the Part 15 operators receive while pursuing their hobby.” -Ermi Roos
Public service or community service has been assumed by people to be required by the FCC for decades. This is not true. Licensees are not, and have never been, “required” to air public service programming or announcements. Folk legend opines the perspective the FCC requires community or public service. Outside of the rules regarding entries into the “Public File”, I challenge anyone to come up with a rule, regulation or law “requiring” community service on the part of radio station licensees. It is entirely voluntary; just like Part 15 stations. Even Public File regulations don’t require broadcasters to fabricate community issues for the convenience of the federal regulators.
When Part 15 “hobby” stations do a better job with issues in the community of “license” than the licensed broadcaster, we find the rub. Enter Ken and KENC. KENC’s Part 15 AM transmitters are all gone, ka-putt. Ultimately, Ken has apparently come to some sort of agreement with Don Coss, the licensee of the local AM station, to carry some of Ken’s programming. This is a partnership we should all begin to understand and emulate. Kudos to Ken.
And finally, the FCC couldn’t give a fig about the community service of Part 15 stations. Community service and Part 15 micro-broadcasting has never been an agenda item or a discussion item before the Commission, never. Part 15 “broadcasting” exists at the whim of individual FCC inspectors who apply the rules as they understand them, period. Technical broadcast standards being what they are, Part 15 will continue as a “hobby”. Anything else is wishful thinking.
Just take a look at the current fray over music performance rights and the suggestion to include, by government writ, we should have our cell phones turned into FM radio receivers. How does that factor into the mix for Part 15 broadcasters? Scores of licensed AM stations are getting turned off and the licenses turned back into the FCC each year. Some AM stations are being donated to churches, “community” groups and leaders for tax credits. When will Part 15 operators figure out, our programming is as good or better than what licensed operations are offering to listeners? When will we figure out, our future is to become the new tribe of community broadcasters who know how to be more than voice trackers and repeater radio? Part 15 is the “green house” for the future operators of “licensed” radio. Let’s call it, “Sprout Radio”.
I’m just sayin’.
Famous Quotes
Marshall,
To quote Sam Kinison in the movie “Back To School”;
“I like the way you think Mr….”
FSMs and public service
A field strength meter comprising an antenna, calibrated receiver, and a spectrum analyzer is a composite field strength meter. It does not matter that all of the components are not in the same box.
You will not be able to eliminate the background noise unless you severely restrict the bandwidth. Greatly restricting the bandwidth allows the reception of only the carrier frequency, but not the sidebands that contain the intelligence. Using more expensive equipment does not alter this fact. What limits the effectiveness of instruments is not their cost, but the laws of physics.
EAS is an example of an FCC mandated public service. Radio broadcasting is supposed to be for the public interest, convenience, or necessity. At license renewal time, it is useful to have done public interest programming to counter any challenges.
Just got one
That all band receiver will be fun, I just picked up an Alinco DJ-X3 0.1 to 1299.995MHz scanner and while it will probably take months to figure out how to fully program it, the rainy season is coming!
FSM’s and Public Service – Response
Ermi,
Your assessment of the working of a field strength meter is right on. However, if you take the composite signal and convert it to a digital data stream and then digitally remove the noise, what remains is the distinct RF signature of the monitored signal. It has been done for years in lab grade signal analysis equipment and software.
Years ago, when I was trained in tracking down interference issues with translators, repeaters and boosters, I discovered a group of broadcast engineers and radio amateurs in Eugene, Oregon who developed RF “finger-printing” hardware and software that accomplished the aforementioned task. So, if the FCC has a recorded digital snapshot of the signal, the capacity exists to determine who the culprit is and any violations of the rules.
EAS (emergency alert system) is not considered, by the FCC, to be public service. It is, instead considered a partnership tool with government units responsible for emergency management. It is part of the licensees responsibilities and sanction (the public interest, convenience, or NECESSITY). Please notice the difference in the words “interest” and “service”. Interest is a noun and passive. Service, on the other hand, is an active noun. If you study the EAS system, you realize that in some situations, some radio stations may be required to leave the air. How is that public service (in the traditional sense)?
NO licensee of a broadcast license owns the license; the government does (refer the the Communications Act of 1934). The license is a “public trust”. I suggest a reading of the latest edition of the Public File publication, “The Public and Broadcasting” (rev 2008), required by the FCC to be on file at each and every radio station. This publication clearly outlines the public service responsibilities of a radio station licensee.
Here is what the document says, “Quarterly Programming Reports. Every three months, each broadcast radio and television station licensee must prepare and place in its station public file a list of programs containing its most significant treatment of community issues during the preceding three months (“issues/programs lists”). The list must briefly describe both the issue and the programming during which the issue was discussed, including the date and time that each such program was aired and its title and duration. The licensee must keep these lists in the file until the next grant of the station renewal application has become final. Television stations will be required to file a Standardized Television Disclosure Form instead of these lists once that form is approved and made available. The form, which will also be filed quarterly, will require commercial and noncommercial educational television broadcasters to provide detailed information on the efforts of their station to provide programming responsive to issues facing their communities in a standardized format.” – FCC “The Public and Broadcasting-2008
And if your local radio station is in compliance, they will have a copy on file. Or, you can download a copy online.
More on FSNs and Public Service
Some people think that there is something magic about digital processing. Whether done in a digital or analog manner, noise is removed from a signal in the same way–by redundancy or bandwidth reduction, which amount to the same thing. An analog coherent receiver can detect a carrier signal buried inside the noise by greatly reducing the bandwidth. In digital signal processing, the same signal is analyzed many times to eliminate the random part and retaining the repetitious part.
To get the RF signature is a different matter. There has to be a reasonable S/N ratio to begin with. You will not get the RF signature for a signal buried deep inside the noise because the amount of redundancy required would be more than a practical signal processor can handle.
Subpart H of Part 73 contains the non-technical broadcast rules, and includes the many hoops the licensees have to pass through in order to be in compliance. Many of the rules are not self-contained in Part 73, but refer to other documents. It is the most complicated subpart. While there is a grammatical difference between public interest and public service, the law refers to public interest, and that is how the rules are justified by the FCC.
AM receiver sensitivity
With the best antenna and receiver, AM receiver sensitivity is limited by the background noise in the AM broadcast band. This background noise is quite high. In my area, it is in the vicinity of 150 uV/m during the daytime. I don’t think that using superior equipment will enable a Part 15 AM station to be received at a very long distance.
Lawyer’s Question
Ermi Roos has raised a lawyer’s question
Since background noises are high everywhere all the time, is the fcc field unit adding the level of background noise together with the level of the part 15 signal being monitored?
That would explain finding an illegally “high level.”
AM field strength measurement
In most areas, the 15.209 field strength limit simply can’t be measured because of the high AM background noise. The field strength recorded in NOUOS is nearly always thousands of uV/m, which is much higher than the 15.209 limit, proving that the 15.209 limit is exceeded.
FCC signal measurement technique…
The FCC field inspectors have very expensive receivers, detectors and spectrum analyzers. The receivers have calibrated digital readouts for frequency. The field strength can be determined and verified by using calibrated receivers and spectrum analyzers without using a field strength meter at all. The spectrum analyzer, and computer software, gives them the “RF finger-print” of the signal in question. Each and every transmitter has a distinct and unique finger print waveform. Radio amateurs and broadcast engineers, I am familiar with, developed the software and hardware years ago. This kind of equipment ignores the background noise entirely by digitally isolating the radio wave. Remember, their inspection results have to be traceable for court evidence rules.
So the discussion about the “black ops” of the FCC field inspectors falls into the category with black helicopters flying by in the night. Might be time for another conspiracy theory, eh?
Part 15 and Skywave Propagation
It is quite true that most of the radiation from a Part 15 system occurs at high angles, which I believe may be an overlooked factor contributing to the poor range that is generally achieved even with a low-resistance ground system. However, in order for a Part 15 signal to be reflected from the ionosphere and contribute to the overall noise level in the band, it would first have to reach the D layer, which is typically 60 to 90 km above the earth. Of course, the reflection coefficient is also much less than unity. Therefore, it is unlikely that even the most efficient Part 15 system would produce signals that would be able to make any contribution to skywave interference. I have thought about this many times while flying in a 747 30 to 40,000 feet up, and have come to the conclusion that even with no significant background noise, my station would never make it even that far. Thus, a very large number of Part 15 stations would probably not affect the noise level in the AM band.
On the other hand, the noise contribution of HD radio stations has had a devastating effect on the noise floor present in the AM band at night, and is now the limiting factor on many frequencies. Too bad the FCC didn’t consider this more carefully before they gave their blessing to the IBOC system. It would be nice if the Commission would stop fussing over Part 15 and pay more attention to the real interference sources in the band.
Commentation Continued
Marshall Johnson, Sr’s Commentary re: “public service,” is good to ponder. I’ve had the feeling that serving a community interest was sort of a penance that one assumed so (he/she) could present what they really wanted to air, which might be “good music” or a particular point of view about life. Really, with Part 15 it would be o.k. to ignore “public service.”
The public generally doesn’t get what they’d really prefer, but they can’t afford to become activists about every cause that they find important to their lives. Like Bruce MICRO1700 said, there isn’t time to get to everything one cares about.
Licensed radio is mainly about money, as it must be, so the argument about “good programming” is silly. The real game comes down to generating revenue, and the FCC serves “the gentry class” who have the money to afford stations.
But about skywave skip. I read in the literature that a minimum of 20-watts is needed to produce a true skywave signal, which would mean the point is moot when it comes to “tiny stick” Part 15 radio.
Finally, agreeing again with what’s been said, it would be interesting to learn the philosophy behind allowing Part 15, from the authoritarian perspective. We are grateful, but what are we grateful for?
A side note for the front of the back on top of the middle 🙂
In other words, idle barely-related chatter…
My favorite shock-jock retread life long radio guy Don Geronimo, now heard on KHTK in Sacramento, had a great rant last week about the forcing of FM radio capability into cell phones.
His bottom line – go out and try to buy a radio! I’m sure it varies by community but poor old Don couldn’t find a “radio” in any of the local big box stores in his area. iPod adapters with a tuner sometimes, other things that had radios in them, but just a good old table top or pocket radio? Nope!
Then I got to thinking about my days in supply chain management for retail and it dawned on me – the NAB screwed the pooch again!
Instead of starting wars with satellite radio and trying to force cell phone makers to add FM tuners, why doesn’t the NAB do what any other company that wants to move a product do?
Rent shelf space.
Most retail stores rent 20% to 60% of their shelf space to outside vendors (Frito-Lay snacks in your grocery store) to contracted shelf stockers (Hartz Mountain pet supplies) or jobbers (beer and soda bottlers)
The NAB could partner with SONY or Panasonic or Sangean and set up a small 3 or 4 item sub-unit with signage and coupons, maybe a cardboard pop-up display for the aisles, for very little money and really get people thinking about radio again – would have been a great summer promo. Or a great back-to-school promo. Or a great Christmas gift promo…
No way would that idea cost 1/100th as much as the war with satellite radio or the current cell phone tuner stupidity and it would have really jacked up the audience – Frito Lay, Coca Cola and Hartz Mountain do it because it WORKS!
Radios to Receive Us
SCWIS I’m glad you brought up the state of radio sets in the retail market. Except, that I think the subject is directly bearing on Part 15 life, and not a distracted issue.
Please try to get Universal Radio and C. Crane as RADIO SET sponsers, as they both have really fine models.
I’m just getting ready to order a wideband radio (100kHz to 1.3gHz). And the main reason for it is to monitor for harmonic and spurious emissions from “Toy City.”