Call letters for Part 15 - can we use them?

[rickityone]

Can anybody clarify wether or not part 15 AM stations may use call letters?

If so, might one use call letters that may also be being used by an LPFM many thousands of miles away from where we are located.

By the way, myself and another fellow operate a Part 15 in Jerome, AZ (for the last two years) called GulchRadio (named after the neighborhood we broadcast from). Currently we are on 1670. We'll be moving down dial to 1500 - many locals don't have AM radios that tune the expanded dial.

We are on the air 24/7 and we stream at: gulchradio.com

We are using a Hamilton Rangemaster and currently in the process of upgrading our audio chain. We have some live shows, one, every morning from 5 to 8 AM MST, friday evenings from 6 until 9 MST, irregularly on saturday afternoons at 6. Sundays from 4 to 6 with a live very oldie show - the GeezerRock Show©™ - mid fifties to mid sixties rock. We are also pleased to carry Tom Fallon's Motown Memories on Sunday nights for two hours and on Saturday mornings for two hours.

I am asking because we are seeking to carry some programming that the program provider would like call letters to identify the station with on their website. We'd like to use the call letters of the defunct, since 1946, station that served our community.

The Rangemaster is a mini-powerhouse. Our signal works it's way into the mountain canyons we are surrounded with and reaches the community below us, Clarkdale with at least a good car listenable signal five miles away. It covers the whole town well during the day. The signal is audible nine miles from our transmitter site.

Thanks for any help. Check out the website, tune in if you like. We'd be pleased.

Rickity
gulchradio.com

 

[Marathon Don]

You can use call letters IF they're not assigned to a licensed station. If you're not sure, make up something unlikely or impossible, like QABC or KABCD.

 

[Black_Shire]

Try to keep your current frequency if you can (the whip antenna will be less efficient at 1500 kHz). If you advertise, you could give out new 530 kHz - 1700 kHz pocket radios imprinted with your sponsors' logos (or with logo decals, in return for them paying for the radios) to your listeners who lack expanded AM band receivers. This would be a way to help your listeners *and* promote your station at the same time.

Regarding call letters, four-letter call signs are okay *if* no licensed AM, FM, LPFM, TV, or LPTV station has the same call sign. An easier and totally safe way to go is to use a five-letter call sign.


-- Black Shire

 

[DarkStarPDX]

Unfortunately, per the FCC rules, you cannot use any type of call letters that could be confused for a licensed callsign. This doesn't mean that you can choose a callsign that isn't in use as the similarity of a licensed call sign will cause you to receive a notice from the FCC. Please don't take my word for it... Ask your lawer to look over the FCC rules (http://wireless.fcc.gov/rules.html) and make a determination for your company.

With websites that like to list affiliates, they'll have to eventually change how affiliates are listed as more and more internet only stations appear, so going with the more descriptive name GulchRadio would be most appropriate for your purposes.

 

[rickradio]

Well, the Rangemaster website says that the FCC's take on the matter is that whatever station ID is desired may be used, as long as 1.) propriety is observed (in other words, profanity- and obscenity-free) and 2.) your "call letters" aren't confused with an actual FCC call sign belonging to a licensed station, which is basically what DarkStar said in his first two sentences. However, I would say that if the call letters aren't being used by a licensed station, why not? Who's gonna complain or know the difference? Gut feeling plays a part in it too for me. Having said that, in my station IDs, I do state after the call letters and communities I serve, that it's an "FCC Part 15 (AM or FM) station" so that no one gets the idea that my stations are licensed...but then, no one knows the difference unless they're radioheads like us, anyway.

The problem with using call letters you made up (even if the FCC hasn't issued them) is that you're streaming online. There, you could (and very well may) run into a problem because if the FCC DOES issue the letters you want to use, and your namesake station decides to stream online too, THEN, YOU'LL HAVE TO COME UP WITH SOMETHING ELSE, like a term or phrase, such as "Surfside 1640." But if you weren't streaming, then it would be moot.

 

[Tom Wells]

I have been using 1550 AM for since 1988, but now experimemting on the expanded band, I find real increase
in distance on 1630, whether due to lack of other signals or better propogation.
It's a tradeoff between a clear signal vs older radios.

I seldom crack a microphone, but have occaisionally IDed as W-nuthin-nuthin-nuthin, nowhere.

 

[Black_Shire]

I have been using 1550 AM for since 1988, but now experimemting on the expanded band, I find real increase
in distance on 1630, whether due to lack of other signals or better propogation.
It's a tradeoff between a clear signal vs older radios.

I seldom crack a microphone, but have occaisionally IDed as W-nuthin-nuthin-nuthin, nowhere.

Be careful--that's not far different from the name of a pirate radio book ("Forty Watts from Nowhere"), and an FCC field agent hearing your ID might wonder how much power you're running from "nowhere" and decide to investigate...


-- Black Shire

 

[Tom Wells]

I have been using 1550 AM for since 1988, but now experimemting on the expanded band, I find real increase
in distance on 1630, whether due to lack of other signals or better propogation.
It's a tradeoff between a clear signal vs older radios.

I seldom crack a microphone, but have occaisionally IDed as W-nuthin-nuthin-nuthin, nowhere.

Be careful--that's not far different from the name of a pirate radio book ("Forty Watts from Nowhere"), and an FCC field agent hearing your ID might wonder how much power you're running from "nowhere" and decide to investigate...


-- Black Shire

I am very careful, and watch that regulation of voltage and current are spec.

In my neighborhood, it's a matter of a 1-2 hundred feet before it's totally gone.
I use it as an in house audio modulator to the various radios in use, fed by the stereo or laptop.
I guess there could still be a few hundred possible listeners, as if anyone tunes around for weak signals besides me.
This is a very densely-packed city neighborhood.

I did once operate a pirate, but that was back in my wild bachelor days.
My wife first heard me on the radio, on shortwave. But that's another story.

 

[KeithE4]

Can anybody clarify wether or not part 15 AM stations may use call letters?

If so, might one use call letters that may also be being used by an LPFM many thousands of miles away from where we are located.

AFAIK, the FCC doesn't care so long as it isn't being used by a licensed station in any service (no ham-style callsigns like WX7AAA on a broadcast frequency, for example, even if it isn't assigned) or is similar to a station in your own area, such as a station in Chicago using WGGN or WLSX.

I'd think 5-or 6-letter calls would be OK as long as the last 2 letters aren't FM, TV, LP, CA, or DT. Decades ago, the FCC assigned 5-letter calls for aircraft (and the Wxxxx and Kxxxx blocks are still listed in the FCC regs as aircraft calls to this day), but I don't think they've been issued since the '40s. Something like WABCD would probably be OK (but not in the Northeast since it's too similar to WABC).

 

[KeithE4]

AFAIK, the FCC doesn't care so long as it isn't being used by a licensed station in any service (no ham-style callsigns like WX7AAA on a broadcast frequency, for example, even if it isn't assigned) or is similar to a station in your own area, such as a station in Chicago using WGGN or WLSX.

I'd think 5-or 6-letter calls would be OK as long as the last 2 letters aren't FM, TV, LP, CA, or DT. Decades ago, the FCC assigned 5-letter calls for aircraft (and the Wxxxx and Kxxxx blocks are still listed in the FCC regs as aircraft calls to this day), but I don't think they've been issued since the '40s. Something like WABCD would probably be OK (but not in the Northeast since it's too similar to WABC).

To update (since it's too late to modify my original post), the FCC callsign blocks are in 47 CFR 2.302 (PDF File linked here)

 

[PhilJSmith67]

When I was running a Part 15 I consistently ID'd as "W###-Part15" and the city, at the top of the hour. The callsign at the time was not in use by any service (AM,FM,TV) according to the FCC's Callsign Reservation site.

http://gullfoss2.fcc.gov/prod/callsign/prod/main.html

If you really want to use a 4-lettter call, check this site early and often. Punch in your desired four letter call. If it comes up in green as Available, and your Part 15 station is obeying all technical regulations, you have the law on your side.

 

[Neil E.]

AFAIK, the FCC doesn't care so long as it isn't being used by a licensed station in any service (no ham-style callsigns like WX7AAA on a broadcast frequency, for example, even if it isn't assigned) or is similar to a station in your own area, such as a station in Chicago using WGGN or WLSX.

I am interested in knowing the source from which you make this conclusion.

Part 15 operators are not required to identify at all. It does seem that there are questions regarding the propriety of inventing callsigns in a "real radio station" format which are subject to debate as we are doing here.

Perhaps the best thing to do is to not use callsigns at all and invent your own unique identifier which in no way can be construed as the callsign of a licensed station, be it real or imagined. After all, what purpose is served by a W--- or K--- fake callsign?

Neil

 

[KeithE4]

AFAIK, the FCC doesn't care so long as it isn't being used by a licensed station in any service (no ham-style callsigns like WX7AAA on a broadcast frequency, for example, even if it isn't assigned) or is similar to a station in your own area, such as a station in Chicago using WGGN or WLSX.

I am interested in knowing the source from which you make this conclusion.

47 CFR 73.3550(l) states: [blue]Users of nonlicensed, low-power devices operating under part 15 of this chapter may use whatever identification is currently desired, so long as propriety is observed and no confusion results with a station for which the FCC issues a license.[/blue]

The broadcasting section is an odd place for a rule pertaining to Part 15 devices, but there it is. What I wrote in my previous post is my interpretation of that rule, but I have read similar statements from other people, both on this board and other websites. Plus, there are many Part 15 stations who use broadcast-style callsigns and don't get in trouble with the FCC.

Link: 47 CFR 73.3550(l)

Part 15 operators are not required to identify at all. It does seem that there are questions regarding the propriety of inventing callsigns in a "real radio station" format which are subject to debate as we are doing here.

True, although the FCC does recognize the fact that many do, as stated above. Four-letter callsigns are familiar to the public and that's probably why many Part 15 operators use them even when they don't have to.

Perhaps the best thing to do is to not use callsigns at all and invent your own unique identifier which in no way can be construed as the callsign of a licensed station, be it real or imagined. After all, what purpose is served by a W--- or K--- fake callsign?

Or use a callsign format that's not already being used by the FCC or haven't been assigned in many years. As I said earlier, 5-letter-or-more calls are probably OK so long as the last 2 letters aren't FM, TV, CA, LP, or DT.

 

[Black_Shire]

I have been using 1550 AM for since 1988, but now experimemting on the expanded band, I find real increase
in distance on 1630, whether due to lack of other signals or better propogation.
It's a tradeoff between a clear signal vs older radios.

I seldom crack a microphone, but have occaisionally IDed as W-nuthin-nuthin-nuthin, nowhere.

Be careful--that's not far different from the name of a pirate radio book ("Forty Watts from Nowhere"), and an FCC field agent hearing your ID might wonder how much power you're running from "nowhere" and decide to investigate...


-- Black Shire

I am very careful, and watch that regulation of voltage and current are spec.

In my neighborhood, it's a matter of a 1-2 hundred feet before it's totally gone.
I use it as an in house audio modulator to the various radios in use, fed by the stereo or laptop.
I guess there could still be a few hundred possible listeners, as if anyone tunes around for weak signals besides me.
This is a very densely-packed city neighborhood.

I did once operate a pirate, but that was back in my wild bachelor days.
My wife first heard me on the radio, on shortwave. But that's another story.

Now *that* could be the plot hook of a based-on-a-true-story romance novel! -- Black Shire

 

[Neil E.]

KeithE4,

Thanks for digging into this and for providing the quote from 47 CFR. I thought I had seen that before, but couldn't find it when I posted earlier.

I think that really clarifies the issue and answers the original queston.

Neil

 

[phatdaddy]

Another option is to use a 4 letter call that doesn't start with W or K. On my Part 15 I use the letters GEZR. Since my playlist is mostly 60's, 70's, and 80's, my sweepers use imaging based around "The Geezer". My TOH announcement gives the callsign, and a Part-15 statement.

 

[KeithE4]

Another option is to use a 4 letter call that doesn't start with W or K. On my Part 15 I use the letters GEZR. Since my playlist is mostly 60's, 70's, and 80's, my sweepers use imaging based around "The Geezer". My TOH announcement gives the callsign, and a Part-15 statement.

Despite the fact that callsigns starting with "G" are assigned to Great Britain, you can probably get away with this since British broadcasters don't use callsigns, and your station won't be heard there anyway. The only thing I'd avoid is using calls starting with CF-CK if you're near the Canadian border (say, in Detroit), or XE-XH if you're near Mexico (such as in El Paso or San Diego).

And if you're experimenting on a shortwave frequency like 13.560 MHz, definitely don't use a callsign that's assigned to another country. If the sunspots are right, even a milliwatt-level signal could be heard overseas. Stick with a W or K in that case if you need to use a callsign at all.