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Post by outbackradio on Apr 3, 2017 11:58:15 GMT -7
I want to share my Rulemaking Petition submission to the FCC, you can review it at this link: www.fcc.gov/ecfs/filing/1033184229072On Page 15 I have a typo where I meant screen grid modulation with regards to carrier suppression for asymmetrical modulation and controlled carrier modulation, thinking carrier suppression I apparently wrote suppressor grid modulation, but I will deal with this small matter later on. I hope all in all that you will like the petition and please pass the word on and watch the FCC to see when they pick this up.
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Post by Variety 1560 AM on Apr 3, 2017 12:51:39 GMT -7
Disseminated to all the part 15 forums i am a member of :-) you will have to contact the webmaster (Bill Defeliece) at this site,,, www.hobbybroadcaster.net/community/me and him had a falling out and don't see eye to eye thus i am banned from his forums. I have posted at Part15us The Initiative forums TheALPB Forums Rangemaster Forums LPAM Forums
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Post by outbackradio on Apr 3, 2017 15:31:34 GMT -7
Disseminated to all the part 15 forums i am a member of :-) you will have to contact the webmaster (Bill Defeliece) at this site,,, www.hobbybroadcaster.net/community/me and him had a falling out and don't see eye to eye thus i am banned from his forums. I have posted at Part15us The Initiative forums TheALPB Forums Rangemaster Forums LPAM Forums Thank you, I will also go and check out this link you suggest and add this there to. I would also be interested in input as to things that might be added and submitted as public comments if the FCC moves to preceed with this and ask for comments.
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Post by Variety 1560 AM on Apr 4, 2017 9:12:22 GMT -7
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Post by outbackradio on Apr 5, 2017 23:10:38 GMT -7
Thanks, also I was looking for some Part 15 information on Google today and saw that same thread and clicked it on and was surprised.
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Post by outbackradio on Apr 5, 2017 23:20:30 GMT -7
I want to detail how I got to submitting this petition to the FCC.
My first interest in a Low Powered AM service came through listening to various talk shows on shortwave around 1998, who pointed me to look for free speech advocacy groups for further information. This is what provided me with the vision for a LPAM service that was unincorporated, and yet allowed commercial advertising while run as a private individual operation, and hence such stations would not in all cases be a small business operation but could be if they chose to be or developed along those lines. Mostly the vision that people had then of which I obtained and still have, is for a LPAM service that meets with the needs of providing a non corporation owned zone for free speech broadcasting. Open to private individuals to utilize the Rural Band Segment.
Some years back, before I had cataracts and then eye surgery, I was interested in writing a rulemaking petition and had joined LPAM on Yahoo where I encountered people from the Amherst Alliance who wrote RM-11287 back in 2005. Looking at how that rulemaking petition suggested the Mediumwave band be chopped up into various suggested channel spacing widths, all departing from the 10 kHz spacings I first began to see that the people who put this together had little experience with channel assignments on Mediumwave and the shortwave HF bands. And that the whole thing was inconceivable requiring remaking allot of rules instead of just creating a new service that would easily fit within the Mediumwave band. Furthermore I saw that they wanted to create the LPAM service in the image of the LPFM service which barred most everyone as a private individual from obtaining a low powered FM station and served mostly the interest of tax exempt non profit corporations.
Some of the suggested channel spacings would have been fine for amateur radio using single side band, where you only need an audio channel bandwidth to 3.8 kHz. However we are talking broadcast quality AM and need to have a channel equal to +/- 5 kHz wide.
When I began to read this prior submission it was back when the FCC was engaged in one of their Task Force initiatives of which the Amherst Alliance wanted to use to launch another rulemaking petition, and the LPAM group apparently had us all thinking that it was only during times when the FCC issues some notice that we can submit rulemaking petitions which is not true, you can submit one at any time you have one prepared. Notices are issued for Proposals relating to grants but not for rulemaking unless the FCC has decided that they need to have some new rules and must require public comments.
Anyways I could see why RM-11287 went no wheres. Secondly I could see that a rulemaking petition devised through these collective groups would likewise go nowhere, in addition there was a lack of agreement within parties and lack of true radio vision, and the attorneys residing in the group wanted an all corporation owned LPAM service without commercial activities and hence make it another service for the tax exempt non profits instead of for we the people, and hence would be modeled after the LPFM service.
I ended ceasing to write a rulemaking petition through them. I decided that if I ever worked on it again I would do it myself and submit it myself.
What is true about such things as this, is that there is no way you can appease and accommodate all possible interest. There is no reason that says we have to. If we however leave all of this up to groups devoted to creating another corporate owned broadcasting medium this leaves out the private individual and disenfranchises them, and so since in most cases in the past it has been the corporation owned voice that has obtained most of the broadcasting spectrum in the USA, I just had to separate them out of this rulemaking petition on the grounds that they are not interested in fairness and balance with regards to private interest in broadcasting. I wanted to include the private individual who wants to broadcast merely because they have it in their blood, or have the bug as some say, just the same way amateur radio operators have the radio bug.
My experience then has been with people who mostly talk but never do anything. Groups exist that claim they will do something someday but are more involved is selling you Part 15 equipment than in writing a rulemaking petition. Regardless of what happens with my petition, it is true that if one fails someone else can submit another petition and keep this all rolling along and public until something is finally accomplished. But never settle for someone or some group that says they are going to do something but never does.
Corporations come up with reasons they want the rules changed or amended about every other week and submit a rulemaking petition as often as they feel needed, and so can the private individual.
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Post by thelegacy on Apr 9, 2017 12:10:36 GMT -7
Aside from the grammar and spelling errors I have a beef with the fact this petition makes it almost impractical or impossible for a budding low powered hobby station wanting to cover say 5 miles (North, East, West, South) with your transmitter in the middle. I'll go into some of my issues and this is a copy paste of what I wrote in the public section of The New Radio Revolution site:
(1) it absolutely screws apartment dwellers. If you live on the 15th floor of a building and want to set up a community hobby station this proposal puts an end to this. (Why rejoice in something that will ream fellow hobby broadcasters in the butt).
(2) The proposal mentions that the coax MUST be buried to stop radiation and again this helps range. This you can tell was written by a radio broadcaster who probably works for an NAB affiliate and thus wants to put a kibosh to the hobby Radio operator.
(3) The proposal prevents a quick emergency set up due to the huge elaborate ground radial requirements.
(4) The proposal prevents a simple 8 Ft ground rod set up. Remember it talks about 30 ground radials at a precise wavelength that itself kills that.
(5) Telling the FCC they have the right to charge whatever they very well want is an open invite for them to charge steep and non affordable fees to the hobby individual clearing the way for only the rich to operate.
(6) Making a limit to only one station stops any possible future development of say an FM hobby station for that individual should one ever exist in the future. Again this was well thought of to KEEP the hobby operator from FM.
(7) because of these kibosh's to the hobby Radio operator on this service don't think you part 15ers will get away willy nilly either because the FCC may make stiffer requirements to you as well.
(8) The mention of part 15 (how many times do we have to tell you that the FCC said NOT to even mention part 15 in the petition)? Obviously certain folks don't listen to what our research has taken us.
(9) If the transmitter already has a modulation limiter similar to what is used in CB transmitters and Ham units why require an expensive O scope to be always in line? Again this raises the price BIG TIME and you guys complain that I wanted to have the FM transmitter scan first to make sure the frequency is blank? Yes I understand this would help to prevent interference but again this leaves things super wide open.
(10) Nothing was mentioned about certification of the transmitter itself or rather kits would be allowed. The agent is free to go willy nilly and ban you because he sees your transmitter was not certified and approved before manufactured and thus put on air.
(11) A starter station must start at a 6 meter antenna and then later after 6 month reapply for an extended antenna. Again this could cost you another 100K if the FCC chose to charge 100K for the application in the first place.
(12) This will not might cause more folks to say bump it and just run Pirate because this petition was not well thought of and did NOT take other groups in consideration before posting to the FCC. This was obviously a one-sided decision making process by a group who again had an elite access only which is exactly what we did only thing was we published our group and offered our access to those who was serious about the hobby. This petition does not have a hobby broadcasting friendly feel to it at all.
So before rejoicing because they done theirs before us you best read and let it sink in all the stipulations these folks are imposing upon all of you. This petition was a very one-sided way to squash Hobby Broadcasting (Legally that is).
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