Attention Part 15 Station Owners and potential Licensed LPFM Applicants...

[WCWalker]

The following article will interest you.

http://www.wilw.com/styled/index.html

 

[rfry]

The article linked in the post above seeks bonus points for Part 15 system operators who are legally operating unlicensed stations.

An interesting aspect of this is that the larger the community served by an unlicensed Part 15 operation, the more likely it is not to meet Part 15. Might that disqualify the operator from being granted an LPFM license?

For example, an unlicensed FM operator with a system that exactly met Part 15.239 would have a radiated, free-space field intensity of 10 µV/m at a distance of 246 feet in the direction of maximum radiation from its antenna. A field intensity of 10 µV/m is about the minimum needed value for useful (mono) reception on a typical indoor radio.

If that signal was uniform in all directions, the land area it would serve would be only 0.0068 square miles, and this assumes clear transmission paths -- not through building walls, etc.

So might those claiming useful FM coverage areas significantly larger than this want to evaluate what it might mean to their FCC applications?

 

[WCWalker]

I suggest you contact the author of the Petition directly and pose that question to him. I am taking a neutral stance on this article. It does seem to me that you are "projecting" again without having sufficient evidence to justify pointing your accusing finger at other people.

 

[Carmine5]

Well, it doesn't hurt to ask. And while I am sympathetic to Mr. Schellhardt's petition I just don't see the FCC showing a similar sympathy toward part 15 radio operators (I suspect an attitude more akin to R. Fry's regarding part 15 broadcasters). If anything, they probably would be more agreeable to having ham operators segue into LPFM and award points to them.

But I do believe limiting LPFM to non-profits has been a serious problem. It has permitted godcasters to pretty much rule the service. There should be an alternate criteria for individuals who want to apply for LPFM licenses.

For that matter, I'm still waiting for the FCC to take up Mr. Schellhardt's petition regarding an LPAM service. How long has it been, 8 years, since he filed it?

 

[Tom Wells]

I'm still waiting for the FCC to notice that lamp dimmers are in no way compliant with Pt 15 regulations.

Haw!

 

[WCWalker]

Well, it doesn't hurt to ask. And while I am sympathetic to Mr. Schellhardt's petition I just don't see the FCC showing a similar sympathy toward part 15 radio operators (I suspect an attitude more akin to R. Fry's regarding part 15 broadcasters). If anything, they probably would be more agreeable to having ham operators segue into LPFM and award points to them.

But I do believe limiting LPFM to non-profits has been a serious problem. It has permitted godcasters to pretty much rule the service. There should be an alternate criteria for individuals who want to apply for LPFM licenses.

For that matter, I'm still waiting for the FCC to take up Mr. Schellhardt's petition regarding an LPAM service. How long has it been, 8 years, since he filed it?

Then he needs to direct the question to the person that wrote the document. That ain't me.

Several people had a hand in crafting the LPAM petition including yours truly. Right now it does not appear as though the FCC is going to make any kind of move on it because of the long held belief by some that the AM band is already too crowded. While that is true in many markets, it is not the case in many small cities and rural areas.

 

[rfry]

And while I am sympathetic to Mr. Schellhardt's petition I just don't see the FCC showing a similar sympathy toward part 15 radio operators (I suspect an attitude more akin to R. Fry's regarding part 15 broadcasters).

Please note that I have no "attitude" toward unlicensed users of the AM/FM broadcast bands who actually comply with Part 15. If they do comply, then such operation is their legal right.

But there are some, for whatever reason whether willful or innocent, who don't comply with Part 15, yet they identify themselves as operating under Part 15 rules. Their postings may lead others to do the same. The information that I and others have posted in some of these circumstances may help readers who do want to comply with Part 15 to investigate and understand what that requires.

 

[Goat Rodeo Cowboy]

I have tried to picture what should be the "mindset" of a licensee of an LPFM station. Are they doing what the FCC had in mind when the service was authorized? Do we have enough experience and track record yet to know what is common among the "successful" or "good" LPFM operations? Who gets to decide what is good and what is a waste of spectrum?

I have tried to picture what IS the "mindset" of a person operating a Part 15 station, or wanting and planning to operate such a station. Do we have enough experience and track record yet to know is common among the.... <choose the word of your choice here> / successful / worthy / desirable / useful / .... Part 15 station operator. Is it anybody's business what my neighbor chooses to put on his Part 15, or is the tiny sliver of spectrum so precious that the community should have some way of having input on how the station is used?

Is this the basic question being asked: Does the operation of a Part 15 / demonstrate / prove / develop skills / that guarantees the FCC that the Part 15 person should have equal standing or superior standing as a competitive applicant for an LPFM CP.

A good use of this discussion space might include: How are LPFM and Part 15 alike? How are LPFM and Part 15 not even close to being alike. Are they interchangeable in function within a community? Why should a Part 15 operator get preference in line for an LPFM? Why should a Part 15 operation go to the back of the line for an LPFM?

 

[rfry]

I have tried to picture what IS the "mindset" of a person operating a Part 15 station, or wanting and planning to operate such a station. (etc)

A good observation.

Probably the answers to it will be different from operators who actually comply with Part 15 than from those who do not, while claiming to do so.

 

[jim8230]

The "mindset" for me is the non-com status of LPFM. As far as I'm concerned, this will make for a tough sell for anyone attempting to run a station. I have a Part 15 AM that runs alternative commercial talk programming 24 / 7. This is the type of programming that is missing from the mainstream airwaves.....I wouldn't be able to do this with an LPFM. The station has been expanded with our own network that has several, original shows throughout the weekend...and, judging by the the on-line server numbers, is doing quite well.

My point is we have enough non-commercial stations crowding the FM dial as it stands now. You can only cut up those listeners so thin. I don't see the benefit of spending the money required to grab a licence, build the site and operate the station with the restrictions the FCC mandates. Now...if they allowed commercial broadcasters to file, I'd be the first in line...

http://micro1650am.com

 

[jim8230]

P. S. The Part 15 is legal (R. Fry)

 

[Goat Rodeo Cowboy]

I have a Part 15 AM that runs alternative commercial talk programming 24 / 7. This is the type of programming that is missing from the mainstream airwaves.....I wouldn't be able to do this with an LPFM.

Give us some definition of your alterntive commercial talk programming. There are some LPFM stations that do what can be described as alternative talk programming. When you add 'commercial' to that description are you saying the talk content itself would be declared to have commercial content, or are you saying that without the commercials an operator could not able to fund that kind of talk?

Do you feel that your Part 15 AM is generating that much more revenue than an LPFM can generate through fund raising and endorsements?

Does the audience you reach "over the air" make it possible for you to generate this revenue, or do you have an on-line presence that coupled with "over the air" makes your station viable?

 

[WCWalker]

And while I am sympathetic to Mr. Schellhardt's petition I just don't see the FCC showing a similar sympathy toward part 15 radio operators (I suspect an attitude more akin to R. Fry's regarding part 15 broadcasters).

Please note that I have no "attitude" toward unlicensed users of the AM/FM broadcast bands who actually comply with Part 15. If they do comply, then such operation is their legal right.

But there are some, for whatever reason whether willful or innocent, who don't comply with Part 15, yet they identify themselves as operating under Part 15 rules. Their postings may lead others to do the same. The information that I and others have posted in some of these circumstances may help readers who do want to comply with Part 15 to investigate and understand what that requires.

Major Hochstetter. I think a lot of us are tired with the way you automatically brand Part 15 broadcasters as operating outside the rules. In other words you are very QUICK to point a finger of accusation at others when you have insufficient evidence to substantiate your claims. This latest post is a perfect example. Where in that article does it even suggest that Part 15 stations NOT operating within the rules should use the Petition? It doesn't. Did you make this same kind of stink when many groups petitioning the FCC for licensed LPFM asked the FCC for amnesty for actual REAL radio pirates the vast majority of whom operate on the FM band?

A quick look at the FCC Enforcement pages shows that a much higher percentage of enforcement action is taking place against LICENSED broadcast outlets and licensees of other forms of communication devices or FM Pirates than against Part 15 AM broadcasters. Unless you have specific and concrete evidence suggesting that any potential Petitioner running a Part 15 AM outside the parameters set by the FCC is actually going to sign onto the Petition, you should keep your allegations to yourself. Your latest comments could be construed as Libelous. BTW. Mr. Schellhardt spent nearly 20 years in DC as a practicing attorney.

 

[Tom Wells]

The problem here is that a great deal of support for such proposals would most come from those who already long to exceed what is permitted. Just now on my my part 15 AM I'm dubbing a March 1980 aircheck cassette of WVVX 103.1 and
"I Fought The Law and The Law Won" by the Bobby Fuller 4 is now playing. As a former pirate who paid my
$1000 fine in 1991, being certain I am "on file", I am dis-inclined to support any proposal.

Concidence of the moment makes me think that the FCC already knows what Godcaster LPFMs have to say, but other voices are often "troublesome".

I'd be the first to argue that the elimination of music on AM is detrimental to society and I have been doing my part in commnity
service by allowing my neighborhood to experience something of the greatness of AM in the 60's and 70's.

Not that that would buy me a cup of coffee at the FCC, but I'm certain a neighbor or 2 has enjoyed something.

 

[jim8230]

Give us some definition of your alterntive commercial talk programming. [/quote]

I suppose anything that is not considered mainstream is alternative. The shows we carry from other networks have commercials in them. Therefore, they could not be broadcast on a non-com station. (AFAIK) The ad time we sell around the original shows we run on the weekend (including one that leases the hour) pays for the electricity and internet. Plus we've been able to upgrade with new processing and two new computers. However everything is automated 24 / 7.

Whether our humble operation can generate more money than an LPFM is hard to quantify. There must be some LPFM's doiong alright as well as some part 15's that probably support themselves. Frankly, I don't know the answer for sure. I do know that without the on-line presence, it would be much harder to take in revenue....but I'm guessing it might be the same for LPFM's as well.

 

[Goat Rodeo Cowboy]

>> Give us some definition of your alterntive commercial talk programming.

I suppose anything that is not considered mainstream is alternative.

Frankly, I don't know the answer for sure. I do know that without the on-line presence, it would be much harder to take in revenue....but I'm guessing it might be the same for LPFM's as well.

Since I fired off that original question, I have streamed your site for a few minutes a couple of times, and will continue to do so for a while. The first line of your response does sum it up pretty well!!!! ;D

LPFM as it is now structured by the FCC (and Congress) is NOT compatible with what you are doing. What you are doing does contain commercial content. What you are doing does not meet the expected locally produced content.

The LPFMs that are somewhat accurately but rudely called "godcasters" violate the locally produced content requirement as I see it, but the FCC apparently is content to hum and whistle while looking the other way.... for now.

I have plotted circles on maps "six ways from Sunday" in geography near where I live and have trouble finding any location in any nearby georgraphy where I have a comfort level that the over-the-air coverage would enable an appreciative audience of enough size the build on. Yes, on-line delivery, podcasting and non-conventional vehicles like cable channels and auxiliary channels on TV and other FM stations are to have to be scouted out with a creative eye. (Some of those will be more costly than the benefit they can provide in many areas.)

I think what you have to hope for is a new generation of LPFMs in the next window will demonstrate to the FCC that the idea of small stations has promise and does do something useful, but collectively the new ones along with the existing LPFMs can report back to Washington that some expansion of the allowed content and technical issues are needed. But that is a process that could take years... and whatever is around the corner for wireless devices that will follow behind the current roll-out of 4G phones may make what you and I are talking about obsolete and unneeded.

 

[radioboy]

Replying to Carmine5:

The last LPAM filing was done around the end of August 2005, I believe.

I, representing Delta Star Radio of Florida, Inc., was one of the signatories of that
particular petition.

 

[Ermi Roos]

I can see that Mr. William C. Walker is a fan of Hogans Heroes, the old TV comedy with the unlikely premise that the allied prisoners in a WWII German POW camp actually run the camp, and use it as a base operations for sabotage behind German lines. The incompetent camp staff, and other stupid and funny Nazis, such as Gestapo official, Major Hochstetter, unwittingly aid this fictional clandestine enterprise.

I watched this show, even though I never thought that the real Nazis were particularly funny. I smiled when I learned that the incompetent camp commandant had been awarded the Iron Cross Fourth Class. This was something like an inside joke, because you would have to know that, of the many degrees of the Iron Cross, the lowest and most frquently awarded was the Iron Cross Second Class. Also, when the commandant took great pride in playing the violin very badly, to really get the joke you would have to know that the actor was a noted concert violinist in real life.

To get an idea of what life in a real German POW camp was like, look at the book or movie Slaugterhouse Five. The author was actually captured during the Battle of the Bulge, and wrote about his experiences in his novel.

Comparing someone to Nazis is frequently done these days, but I don't think that it is appropriate if the person was never a member of the original Nazi Party or one of its modern incarnations. Also gratuitous accusations of libel are inappropriate if what the accused person writes is true, or he reasonably believes it to be true.

 

[WCWalker]

I can see that Mr. William C. Walker is a fan of Hogans Heroes, the old TV comedy with the unlikely premise that the allied prisoners in a WWII German POW camp actually run the camp, and use it as a base operations for sabotage behind German lines. The incompetent camp staff, and other stupid and funny Nazis, such as Gestapo official, Major Hochstetter, unwittingly aid this fictional clandestine enterprise.

I watched this show, even though I never thought that the real Nazis were particularly funny. I smiled when I learned that the incompetent camp commandant had been awarded the Iron Cross Fourth Class. This was something like an inside joke, because you would have to know that, of the many degrees of the Iron Cross, the lowest and most frquently awarded was the Iron Cross Second Class. Also, when the commandant took great pride in playing the violin very badly, to really get the joke you would have to know that the actor was a noted concert violinist in real life.

To get an idea of what life in a real German POW camp was like, look at the book or movie Slaugterhouse Five. The author was actually captured during the Battle of the Bulge, and wrote about his experiences in his novel.

Comparing someone to Nazis is frequently done these days, but I don't think that it is appropriate if the person was never a member of the original Nazi Party or one of its modern incarnations. Also gratuitous accusations of libel are inappropriate if what the accused person writes is true, or he reasonably believes it to be true.

If the shoe fits... His one man crusade against Part 15 broadcasting is something else. If he had an ounce of common sense he'd be worrying about some of the legislation being proposed in the House and Senate that will result in substantially higher fees for stations that play music and also will censor station programming and also mandate what stations can and cannot air. Licensed radio is in trouble and he and others like him that waste an inordinate amount of time with their self imposed policing of stations operating at one tenth of a watt, most of which are non commercial in nature is laughable. I don't care how much experience he has as a broadcast engineer, he is coming across as a know it all. Surely a broadcast engineer of his caliber could do something to help the licensed broadcast industry...

Fry's allegations that MOST Part 15 AM stations are not operating legally is blatantly false. Unless he can furnish documentation proving this along with some of his other allegations about the manufacturers of FCC Type Accepted Part 15 transmitters then he should wisely refrain from making these comments. Whether he believes this to be true is irrelevant. If you write something about someone that is patently false and potentially damaging then yes, these statements can be construed as Libelous. "Feelings" such as this are not going to be taken into consideration in a case of Libel in court.

Don Schellhardt and I have had our share of battles with one another over the years. But I do know this, unlike Fry who constantly tears down Part 15 broadcasting, Don is actually trying to do something positive to help the low power broadcast community even if he lacks experience in certain areas. His knowledge of how the politics in DC works is impressive and his ability to rally people of varying beliefs and backgrounds to work towards a common goal is admirable.

 

[Ermi Roos]

Take it easy, William.

Maybe you should have a calm talk with a lawyer (Schellhardt, perhaps) to find out if you actually have a libel case. To me, it doesn't sound like anything a judge would take seriously, but I'm a layman.

Best of luck!