|
Post by davidchamberlain on Mar 19, 2016 8:13:41 GMT -7
I agree, but first we need to get all the ideas out on the table. We should probably set a time limit for that so it doesn't run on forever, and then move forward with deciding the details. I would vote for another week or so - people need time to think and let the ideas percolate. Plus we do need to get some more information, like the reasons why other countries have set up this kind of service, before moving forward.
|
|
|
Post by Variety 1560 AM on Mar 19, 2016 8:45:39 GMT -7
i'm thinking part 15.219 should be extended to 520 and 1710 and our proposed band should be 500,510,1720,1730 because 520 and 1710 are usually within the range of modern AM BCB receivers if we were to open up 520 and 1710 with more power beyonf 15.219 there would be a clamor for those frequencies by far too many people, and then we need to consider 1st adjacent interference to 1700 (i believe currently 2 in the USA) and 530 (not sure how many of these there are) stations.
so 520,1710 15.219
500,510,1720,1730 whatever one way experimental broadcast service we propose.
we do need to investigate 500 though. we are getting down into a proposed new ham band at 500.
there so much to consider outside of the 1720-1780 range because there is utilization outside of this range and we may run into resistance from those users. this is why i proposed 1710-1780 in the first place. but including 1710 under these proposed service is a bad idea for the reasons i laid out above.
just think how far a 1710 strictly legal 15.219 station would do there. look what it is capable of with all the qrm on the AM BCB, 1710 is quiet the ranges would be even further for 15.219 on 1710.
just something to think about. 1720-1780 is just not utilized by anything. it's empty space that could be utilized for experimentation.
|
|
|
Post by Variety 1560 AM on Mar 19, 2016 8:50:44 GMT -7
i make a motion
Extend 15.219 to 1710 and 520
propose a new higher power service on 1720-1780
all in favor.
when we get the start of a document i will make a sticky with our decisions and add to it as we firm up idea's in the steps i laid out.
i will give 14 days from today for everyone to decide where they stand on this motion. today is the 19th so close date on this motion will be April 2nd.
|
|
|
Post by Variety 1560 AM on Mar 19, 2016 8:53:29 GMT -7
we do need to decide on a chair person for this effort. i guess i am acting chair person till we decide as a group who to elect, hence my motion. we currently have 6 members registered on the forum.
|
|
|
Post by davidchamberlain on Mar 20, 2016 9:38:19 GMT -7
Some straight talk here.
I've given this a lot of thought.
I think we have to go back to first principles. Why are we doing this?
Here is my answer. As a Part 15 broadcaster, I would like to have the freedom to experiment with radio and programming with a little more usable range, while at the same time reducing the possibility of interference to licensed broadcasters.
But we have to recognize that as Part 15 broadcasters, we are the lowest of the low, with virtually no privileges currently except being allowed to exist. Interference and piracy may even take away that last right, if we're not careful.
I've agreed from the start that FM is a no go, except potentially to increase to Canadian BETS-1 levels. But that really doesn't satisfy why we're (or, at least, I'm) here. BETS-1 levels are just slightly better than Part 15.239. If you increase power much more past those levels, you increase interference. Any additional frequencies that could potentially be allocated in or around the FM band are just far too valuable to be seen as being wasted on a higher-powered Part 15 service.
As for the AM broadcast band, I believe that it still is seen as having a lot of value. You're still going to have licensed stations worried about interference with a higher powered Part 15 service, and again, why would any extra frequencies be just given away (their perception). And let's face it. Most Part 15 operators run on a shoestring budget. If a separate low power class is developed on, say, 1720-1780Khz, how many will actually have the money to properly equip a higher powered station, particularly with the appropriate test equipment. Because you're going to get a lot of people going after those frequencies, people with money who see it as a way to make more money, and not to experiment, or to 'save radio' with unique programming. I believe that the true Part 15 operators will just be crowded out as they are now.
That leaves shortwave and long wave. I truly believe that it's in those bands that we will come the closest to achieving what I believe we want to achieve. The frequencies are seen as having little to no value commercially. There's space (although less space on long wave) and really, few would care, other than the FCC. We would just have to give the FCC some good reasons to make the effort to allocate the space, and after that, not increase their workload.
I also believe that this should NOT be connected at all to amateur radio. The ARRL is probably more bureaucratic than the NAB, and has an idealistic element that would make it more difficult to deal with (the NAB is all about money). It would take forever to get them to agree to support anything, if you could get an answer at all, and I don't believe the answer would be favorable - they would want any frequencies being discussed for standard, 2 way, amateur radio, particularly if it was under their umbrella.
In terms of long wave, you are also competing with the ARRL for space - they've been lobbying for years to get frequencies in this area.
That's why I believe that the following is the way to proceed. Leave Part 15.209, 219 and 239 as they now stand alone. Opening it up would be a can of worms, everyone then gets to have their say, and the real danger is having the NAB successfully lobby to reduce existing limits.
Add another Part 15.xxx clause dealing with an allocation in the shortwave spectrum. Say, 6.2-6.5Mhz. I chose those frequencies carefully. The 'official' ITU allocation for the 49m band is 5.9-6.2Mhz, but participation with the ITU that is voluntary, and many governments have allocated space for broadcast stations both above and below that official range. So using it for broadcasting has precedent.
This Part15.xxx would be unlicensed, have a total power input to the final stage of the transmitter to be 1 watt (or whatever, I just picked that number out of the air, it would have to be seen as low), with no antenna restrictions. Allowed transmissions mode would be AM, SSB, DSB - in short, any voice mode). The intent is that this would be a domestic broadcasting service, focusing on technical and programming experimentation.
There are plenty of bands (such as ISM) that are located throughout the shortwave spectrum for domestic use - consulting the ITU is only required if the signals are likely to span internationally, and even then, it's voluntary. The FCC might, however, think otherwise, so we would have to be prepared for that.
Yes, I recognize that there are some holes in the concept. Perhaps 6.2-6.5 isn't the best band, maybe lower such as 4.2-4.5Mhz (between the 40 meter amateur band and the 60 meter broadcast band. Regulation/enforcement would also be an issue. The FCC does not want to increase their workload in a time of cutbacks, particularly for the lowest of the low.
But overall, I believe that this is the best chance we've got. Spectrum seen as little to no value commercially, somewhat redundant to amateur radio as it's close to the existing 40 meter amateur band (although they always will want more frequencies) and little to no interference with existing services.
It's the justification that is the biggest question mark. Yes, WE want it. But that isn't a justification. Nor is the fact that it won't cause interference a justification. Not giving us the space won't generate interference either. Experimentation is a valid one, but we also need something that is a door opener. Amateur radio has emergency services in times of dire need. I wouldn't say to not go for it if we can't do better than experimentation, but the chances of getting this increase greatly if we can.
Anyway, my thoughts. But I do urge this group to forsake AM, as well as FM. I will continue to try to help (as I'm doing with the ill-fated FM initiative) but the chances are very faint it will happen. Chances with shortwave are still slim, but at least there's a shot.
|
|
|
Post by Variety 1560 AM on Mar 20, 2016 10:36:27 GMT -7
there was a shortwave petition at one time around the 26-27mhz region using AM mode. i forget the wattage. the fact that CB exists @ 4 watts in an ITU controlled region is pretty interesting considering with a good stacked beams array international skip is a possibility and often achieved by CB'ers using legal 4 watt am 12 watt ssb rigs with good antenna's.
there is your precedent for some kind of HF service.
i have also just approved a new member who traces back to a very interesting organization and who could really add some constructive dialogue to this topic. hopefully this person will come out of the lurker stage and chime in on the effort.
|
|
michi
New Member
Posts: 4
|
Post by michi on Mar 20, 2016 10:58:33 GMT -7
If a separate low power class is developed on, say, 1720-1780Khz, how many will actually have the money to properly equip a higher powered station, particularly with the appropriate test equipment. Because you're going to get a lot of people going after those frequencies, people with money who see it as a way to make more money, and not to experiment, or to 'save radio' with unique programming. I believe that the true Part 15 operators will just be crowded out as they are now. 1705-1800 kHz still has radiolocation and fixed service allocations in it. Many of these are federal government and would require NTIA coordination to clear up this spectrum. ULS still shows several Alaska Fixed Service non-government licenses in this spectrum (non-issue for lower 48). Other than hobbyists with general coverage receivers, there's not much out there on the market that would tune this spectrum. In contrast, the 76-88 MHz band which in the USA is used for TV channels 5 and 6 and has been argued for over a decade for an expansion of the FM broadcast band does have many models of mass-produced 76-108 MHz receivers available, especially in light of the WIDE-FM band expansion in Japan, where the FM band has been extended from 76-90 to 76-95 for existing AM stations to obtain FM transmitters. Longwave for broadcasting has never been used in ITU region 2 and there is no allocation. Your best bet for any kind of longwave operation is the spectrum between 160-190 kHz where 1 watt is permitted with specific antenna restrictions. Of course, this will not get you very far and could wreak some havoc with the Lowfers who are running weak signal with that one watt. The rest of this spectrum is still allocated for maritime and radionavigation services.. so once again, the NTIA will be involved. The 160-190 section is the only place that is allocated internationally to the fixed service and does not have any radiolocation on it. This is completely outside the realm of the ARRL or anything in the amateur service. There is some "expansion" SW spectrum that has been made available as a result of previous WRCs and while not required, it is recommended that DRM is used. Those SW stations are operating secondary to fixed and mobile services. The 6.2~6.5 MHz spectrum is used for working frequencies in the maritime mobile services. See 80.369, 80.371 and 80.373 for information on the usage of spot frequencies in this spectrum. The ITU also puts out a periodic report that points out HF stations that are not complying with the international radio regulations: www.itu.int/en/ITU-R/terrestrial/monitoring/Pages/Regular.aspxAnother band allocated to the maritime mobile service. See those same sections for frequency usage. There's a difference between experimenting and broadcasting. Experimenting means trying new technologies. The ability to do various types of experimentation can already be done in the amateur service and for those types of experiments that go beyond the amateur service (such as specific bandwidths, emission masks, frequency bands, etc.), you can make a compelling case to the FCC and apply for an experimental license under Part 5 of the rules. Part 15 exists for short range communications and is supposed to be the equivalent of the SRD regulations in the CEPT administrations and other nations around the world. The US is one of the few places in the world that actually has any kind of permission to run short range devices in the mediumwave broadcast spectrum. For more about spectrum, read this article: recnet.com/node/721=m
|
|
michi
New Member
Posts: 4
|
Post by michi on Mar 20, 2016 11:01:01 GMT -7
i make a motion Extend 15.219 to 1710 and 520 propose a new higher power service on 1720-1780 15.219 already covers 520 kHz. See my previous message regarding 1705-1800 kHz and the fixed and radiolocation services. =m
|
|
|
Post by Variety 1560 AM on Mar 20, 2016 11:19:26 GMT -7
interesting, i actually did not realize there was anything in that spectrum. welcome to the group. we need someone here familiar with the spectrum we are talking about. now we know why 1710 was not included under 15.219 and instead was under 15.223. it's beginning to look like this whole idea of a new LPAM type (or shortwave broadcasting) service might be Dead On Arrival unless you can think of some spectrum we might be able to put in the petition.
|
|
|
Forget FM
Mar 20, 2016 11:29:22 GMT -7
via mobile
Post by mighty1650 on Mar 20, 2016 11:29:22 GMT -7
I'm beginning to see why so many of these flopped. I assume our best bet would be to expand in the ISM bands.(some of which do fall in 6mhz among others)
|
|
|
Forget FM
Mar 20, 2016 11:30:43 GMT -7
via mobile
Post by mighty1650 on Mar 20, 2016 11:30:43 GMT -7
|
|
michi
New Member
Posts: 4
|
Post by michi on Mar 20, 2016 12:30:21 GMT -7
|
|
|
Post by davidchamberlain on Mar 20, 2016 15:25:46 GMT -7
I was just throwing out some frequencies in the shortwave spectrum. There's nothing that says that a Part 15 broadcasting service couldn't be a secondary use in a slice of those frequencies. Again, you have the interference issues, but it could be done (even though the spectrum may be allocated, in reality there may be very little usage). I believe that's what the FCC did for amateur radio in the 60 meter band, back in 2003 or so.
I also realized that I was specifying a lot of frequencies for the types of transmission modes that would be used - probably something like 6.4-6.5Mhz would be sufficient - that would allow for 10 AM and DSB channels, 20 SSB channels), and possibly even less, such as 6.45-6.50. Again, just examples
The only reason I brought up the ARRL (I did agree with you that this type of service is not in their mandate, never mind getting through the bureaucracy) is that it was suggested that many Part 15 broadcasters operate similarly to amateur radio operators, but one way only. There's the desire to experiment with different transmission modes, different types of antennas, different power levels, etc. And experimentation doesn't always have to be technical. Many offer experimental type programming, i.e., programming that is not heard virtually anywhere else, whether it be music, talk, etc. Because of that similarity, the suggestion went that perhaps this kind of broadcasting service could somehow be put under the amateur radio umbrella.
I remain steadfast in my belief that there's just too much money involved in and around the AM and FM broadcast bands to get anything there, never mind existing spectrum allocation. Part 15 already can be used in both long wave and shortwave (the latter in the ISM bands). The idea would be to increase the allowable power, while minimizing interference with existing services.
I'm not saying it will be easy. Far from it. But it's the only shot I think any sort of effort like this has.
It has also been suggested elsewhere that the FCC responds positively to economic arguments. Perhaps this kind of service can be seen, in addition to experimentation, as providing local/community radio in areas which normally could not afford local radio. Areas which are too large to be serviced by Part 15 broadcasting, and yet too small to be noticed by existing radio stations. That would all have to be defined and documented and 'proven' to some extent, but it is one possible argument.
My experiences on Bowen Island, BC, showed me that the local population responded very positively to what was seen as 'their' radio station. They didn't care where it was, or even if it was legal (it was - in actual fact, they were kind of disappointed that it wasn't a pirate station, it was that kind of community). They just wanted to know how to listen, how to contribute and get involved, etc. Many drove for miles (well, several anyway, as the island wasn't all that large) to park in the coverage area and listen, although that was a royal pain. If it was on shortwave, they would have purchased shortwave receivers, particularly if the range could have been increased significantly. That is truly serving the public, which is supposed to ultimately be a mandate for the FCC (it's the focus of their strategic plan).
|
|
michi
New Member
Posts: 4
|
Post by michi on Mar 20, 2016 17:34:44 GMT -7
The other things you need to consider for a licensed service is whether the service is going to commercial or non-commercial educational.
As a commercial station, you can be owned by an individual and you can carry commercials to support the operation of the station. There are many drawbacks though. As a commercial station, you are subject to annual regulatory fees as well as filing fees when applying for new stations and changes. Mutually exclusive (competing) applications would be settled through auctions. Despite what some in the Part 15 world has said in the past, there is no way around auctions. This is statutory (e.g. act of Congress) and is something the FCC can not waive. Same with regulatory fees. In addition, commercial stations may be subject to restrictions on city of license depending on whether the FCC feels that it is necessary to assure a equal and fair distribution of frequencies per the Communications Act. Also, with commercial services, while statute allows for the Commission to enforce market specific ownership caps, they can not enforce a nationwide ownership cap. This means that Joe Hobbyist who wants to start one of these stations can be outbidded by a deep pockets mega church, speculator or corporate radio owner and likewise, all of the other Joe Hobbyists wanting to start these stations could be outbid.
As a non-commercial station, you are subject to rules similar to LPFM. Non-commercial stations will be licensed to non-profit corporations only (a 501(c) is not required) and will not be licensed to individuals. Non-commercial stations can play underwriting messages to acknowledge donors but can not play commercials. A non-commercial service can restrict ownership qualifications and number of stations owned to a single licensee.
Now, if this is a very low power service and it is authorized by rule instead of by license, then that means that anyone can have a station. This includes corporate owners like iHeart Media or even corporations that would otherwise not be in broadcasting. Could you imagine if every 7-11 convenience store in a particular town had one of these stations or every McDonalds?
The FCC has already carved out a service like the one that many are asking for... LPFM. I think the real goal should be is to (1) allow existing LPFM stations to grow to LP-250 as proposed in RM-11749. (2) open a new LPFM filing window in 2019 after the AM on FM translator windows and LP-250 upgrade window (if we ever get it) concludes. (3) push the FCC to allow for 30 and 100 watt low power AM stations in the 1620 to 1700 expanded band as previously proposed by Baumgartner and supported in modified form by REC. (4) push the FCC for some additional power under Part 15 AM and to push the upper frequency for Part 15 AM operations to 1715 kHz.
|
|
|
Post by davidchamberlain on Mar 20, 2016 19:40:54 GMT -7
What exactly is REC and what is their interest in Part 15 broadcasting?
I don't doubt that the LPFM filings would be beneficial, but don't forget that most Part 15 broadcasters either can't afford an LPFM (heck, most license holders of LPFM's can't afford them, at least right now, with all the restrictions) or an LPAM, and/or don't have the technical wherewithal to run them (so they'd have to hire people, but they can't afford to....and on it goes).
So, my response would be that everything except point #4 of your objectives is way outside the scope of what was being attempted here.
|
|