Increase acceptable Part 15 power limits to 1 watt in the AM band and 10 watts in the shortwave broadcast bands.
This is a companion petition to "Create a Low Power AM Broadcast Service in the Expanded Band, 1610-1700 kHz."
I feel strongly that the FCC's current rules governing unlicensed radio broadcasting in the United States are, at the very least, out of date, and at worst, an affront to open competition, personal expression, and the free flow of information and culture among average Americans.
I have been a Part 15 broadcaster for the past 10 years. I was amazed how simple, rewarding, and inexpensive it was to construct a home brewed antenna system and a kit transmitter and end up with a "legal" AM signal that reached roughly two miles during daylight hours. I now own two Part 15 stations, Troubadour 1700 and Liberty & Justice 1640.
Comparing my 20-plus years of employment and volunteer work at licensed stations with the process of building and maintaining my own Part 15 stations, the Part 15 experience beats all of my licensed station experiences hands down. Part 15 radio teaches ingenuity and a wide variety of technical skills, all in a low stress environment where there are no limits to creativity. But the best part is that even if you are financially challenged, you don't have to waste time networking in an industry where most owners and managers don't share your values, hoping to find that big radio ownership opportunity. For as little as a few hundred dollars, you can get on the air with a kit transmitter. You can serve the communities and neighborhoods you know best.
But my Part 15 efforts have remained hobby level at best thanks to the rules of your agency. The current maximum AM power level - 100 milliwatts - produces an urban grade signal of no more than 1500 feet, even with the most efficient system. Unless your transmitter is strategically located in the downtown center of a reasonably sized community, you will have few if any listeners and no regular financial support.
Thanks to the generally poor job licensed AM radio has done in reflecting the full diversity and interests of our society, more and more people over the past decade have discovered the ambiguities of your agency's rules and have resorted to establishing their own unlicensed Part 15 AM stations. In light of the growing popularity of Part 15 radio, and with consultation received from several experienced Low Power radio advocates, I urge your agency to make this medium more viable and sustainable by instituting the following rules changes:
1) Increase the allowable amount of power to the final RF stage of "intention radiators" in the AM broadcast band (520 - 1710 kHz) from 100 milliwatts to 1 watt. If, as a result of this change, the FCC deems fit to impose stricter rules concerning out-of-band emissions on the new breed of 1 watt kit and pre-assembled transmitters that would emerge, we will not object. (Note: This rule change should NOT apply to "unintentional radiators" which, if anything, should have their restrictions tightened.)
2) For at least the time being, eliminate all antenna and ground restrictions on Part 15 AM operations in order to allow experimentation for the best efficiency at each transmitting site within the operator's budget and any local zoning laws. If a "no antenna or ground restrictions" policy still works well after several years of trial, then make the elimination permanent.
3) Totally eliminate the use of Part 15.209 (i.e. field strength threshold) in determining whether or not an intentional, unlicensed transmitter in the AM broadcast band is operating legally. The only restriction for unlicensed operation should be 1 watt to the final RF stage, period. We should be keeping rules as simple as possible, and relationships between operators and your agency as unambiguous as possible.
4) Designate the frequency of 1710 kHz solely for use by Part 15 broadcasting. This will give Part 15 broadcasters a default, interference free frequency to use if the rest of the AM band (even the regular expanded band frequencies) is too crowded locally to provide stable reception.
5) We trust the overwhelming majority of would-be 1 watt Part 15 broadcasters will be responsible operators. But should a dispute occur between two unlicensed operations, it will continue to be up to each party to resolve the problem amiably among themselves. For this reason, 1 watt Part 15 broadcasters should be required to identify their station "moniker" or name (NOT "call letters," since these can only be assigned by your agency for licensed operations) at least once an hour, close to the top of the hour, along with the name of the municipality or neighborhood in which they are located. Part 15 operators should also be required to divulge reliable contact information, either on air, through a website, or through social media. Should the operator of a licensed station encounter a legitimate TECHNICAL ONLY issue caused by the operation of a Part 15 station, the licensed station must likewise approach the Part 15 operator directly, and only file a complaint with the FCC if multiple attempts to reach the Part 15 operator, or to agree on a resolution, have failed. Under no conditions should any licensed broadcaster have the power to successfully demand that an unlicensed broadcaster be taken off the air simply because his/her operation is unlicensed.
6) Significantly raise the level of acceptable Part 15 operation on certain yet-to-be-determined shortwave broadcast frequencies from 30 μV/m or 100μV/m at 30 meters to no more than 10 watts to the final RF stage of the transmitter, with no restrictions on antenna or ground system. Ever since the major European government broadcasters abandoned the shortwave spectrum several years ago, the bands have been starkly empty. Shortwave is now a more endangered species than broadcast AM. Giving Part 15 operators the ability to broadcast license free at a 10 watt power level, with the potential to be heard in a two or three state radius at various times of the day, would be the shot in the arm the shortwave service now desperately needs. More research will be required to see how much U.S. domestic broadcasting in the shortwave bands would be compatible with international agreements. At this stage, we have not determined whether a Part 15 operator could stay on a single frequency around the clock, or whether he/she would have to broadcast on a "day" frequency at night and on a "night" frequency during the day to keep excess skywave from being heard beyond U.S. borders. Also, frequencies designated for amateur, aircraft, and marine communications should be strictly prohibited from Part 15 broadcast use at any power level.
7) Finally, start initiating common sense laws that will put the AM broadcast band back on a more even footing with the FM broadcast band. Due to our tiny, vulnerable signals, cleaning up AM interference and audio is even more important for Part 15 broadcasters than it is for licensed AM broadcasters. These common sense laws must include the following:
a.) Decommission IBOC AM HD broadcasting. It has been a colossal failure and even Ibiquity is begrudgingly starting to admit it. The only advantages IBOC on AM has is during a thunderstorm when it eliminates all the static if the digital signal kicks in. Also at night, if a distant station is coming in under a strong local, the digital signal has no interference from the weaker station. But these situations are the only two exceptions. Every other aspect of AM IBOC has been an unmitigated disaster. It's time to go back to the drawing board.
b.) As a direct result of the imposition of AM IBOC HD standards, the receiver manufactures have, over the past 12 years, designed the AM sections of their radios to be so narrow in bandwidth that the audio of the analog signal now sounds worse than a unequalized 1950's phone line. Furthermore, since large scale receiver manufacturers have always been indelibly lazy and greedy, they now use this narrow band design on all their AM radios, whether the specific model is HD capable or not. The solution is to make the AM high fidelity AMAX standards of the 1990's MANDATORY for every AM receiver produced or imported into the United States. Also, if a radio or tuner is capable of receiving analog FM stereo, it should, by law, be required to receive C-Quam analog AM stereo as well (the official FCC approved AM Stereo system). If receiver manufacturers want to continue offering HD on the AM band, they should be free to do so. But if they do, they should be required to include a duplicate AM band that conforms to AMAX standards and is capable of AM Stereo if the receiver has analog FM stereo.
c.) Impose a "get tough" policy on the manufacturers of any device that causes significant interference to AM radio. Any device causing interference to one or more AM broadcast frequencies at a distance of three feet or greater must not be allowed to enter the American market place. We must demand proof that every electrical and electronic device entering in or produced in the United States has passed a series of rigorous tests at an FCC approved compliance testing facility.
d.) Crack down on automobile manufacturers who not only install factory radios with terrible, narrow band AM sound, but also poorly shield the AM section from the various computer processes running almost constantly in any car produced over the past 12 years. I have experienced car radios where the usable range of AM stations on certain frequencies is as little as 20 percent of what it normally is, thanks to this lack of shielding. This is unacceptable! If the average desktop computer can limit the interference it causes on most AM channels to less than three feet, then why can't an automotive manufacturer stop all computer based AM radio interference, even with all that natural shielding and an antenna placed on the rear of the roof?
For the sake of our grass roots culture, economic justice, fair competition, and the survival of AM and shortwave radio, we, the undersigned, urge you to initiate these changes in current FCC rules and policies. Part 15 radio needs to be more than just a hobby. It needs to evolve into a true public service and one that has full legitimacy in the eyes of the FCC.
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