LPFM CP Application Question...

[edarmsttrong]

Question-

If we are a non-profit organization, presently running a Part 15 Type Certified AM Transmitter, complete with a 3 meter antenna, coax, and ground lead, at the top of a 30 Foot metal mast...
are we automatically disqualified from applying, due to the ammeded provisions contained in the latest version Local Community Radio Act? (Specifically Sec. 632(a)(2)).

SEC. 2. AMENDMENT.

Section 632 of the Departments of Commerce, Justice, and State, the Judiciary, and Related Agencies Appropriations Act, 2001 (Public Law 106-553; 114 Stat. 2762A-111), is amended to read as follows:

‘Sec. 632. (a) The Federal Communications Commission shall modify the rules authorizing the operation of low-power FM radio stations, as proposed in MM Docket No. 99-25, to--

‘(1) prescribe protection for co-channels and first- and second-adjacent channels; and

‘(2) prohibit any applicant from obtaining a low-power FM license if the applicant has engaged in any manner in the unlicensed operation of any station in violation of section 301 of the Communications Act of 1934 (47 U.S.C. 301).



Just curious....

 

[knowbetter]

Question-

If we are a non-profit organization, presently running a Part 15 Type Certified AM Transmitter, complete with a 3 meter antenna, coax, and ground lead, at the top of a 30 Foot metal mast...
are we automatically disqualified from applying, due to the ammeded provisions contained in the latest version Local Community Radio Act? (Specifically Sec. 632(a)(2)).

SEC. 2. AMENDMENT.

Section 632 of the Departments of Commerce, Justice, and State, the Judiciary, and Related Agencies Appropriations Act, 2001 (Public Law 106-553; 114 Stat. 2762A-111), is amended to read as follows:

‘Sec. 632. (a) The Federal Communications Commission shall modify the rules authorizing the operation of low-power FM radio stations, as proposed in MM Docket No. 99-25, to--

‘(1) prescribe protection for co-channels and first- and second-adjacent channels; and

‘(2) prohibit any applicant from obtaining a low-power FM license if the applicant has engaged in any manner in the unlicensed operation of any station in violation of section 301 of the Communications Act of 1934 (47 U.S.C. 301).

Just curious....

are you operating the type 15 legally....

have you been cited by the FCC?

if not, I would make sure you are operating legally, and since you have not broken any laws, my guess is that you would be okay...

 

[RadioTheNet]

Part 15 is not illegal broadcasting. You can apply. And if someone on the board has a piracy background, dump them from the non-comm board and you can file.

Erik Anderson
LPFMhelp.com

 

[rfry]

Part 15 is not illegal broadcasting.

It is not illegal only if the rules pertaining to Part 15 FM actually are met.

And if they are, then the useful coverage radius to a typical indoor FM receiver from such a system probably won't be more than 200 feet -- which most likely doesn't conform with the concept of "broadcasting."

Using an FM transmitter operating at the 10+ milliwatts of output power provided by many commercially available FM transmitters with even the simplest Z-matched transmit antenna virtually guarantees that such a system is non-compliant with FCC 15.239.

The FCC has issued numerous citations to such operators, who probably thought that they were compliant with 15.239.
//

 

[edarmsttrong]

Part 15 is not illegal broadcasting.

It is not illegal only if the rules pertaining to Part 15 FM actually are met.

And if they are, then the useful coverage radius to a typical indoor FM receiver from such a system probably won't be more than 200 feet -- which most likely doesn't conform with the concept of "broadcasting."

Using an FM transmitter operating at the 10+ milliwatts of output power provided by many commercially available FM transmitters with even the simplest Z-matched transmit antenna virtually guarantees that such a system is non-compliant with FCC 15.239.

The FCC has issued numerous citations to such operators, who probably thought that they were compliant with 15.239.
//

Our non-profit is using an AM Transmitter, not FM. Is it illegal to mount it 30 feet in the air, on a metal mast?

Recent enforcement actions, such as those taken against 'KENC' in Oregon seem to point that this type of installation would break the rules.

Would Ken Cartright's non-profit group, if he had one, be disqualified from applying for a LPFM CP as a result of the recent enforcement action? It would be disapointing to learn that the group would be disqualified, since an operation like his had been serving the local community better than any licensed stations in the area.

3rd adjacent protection was a smokescreen...it already was gone for translators, many of which use more ERP than a licensed LPFM facility. It was a no-brainer. I think the NAB really pushed hard for the 'anti pirate' amendment, and that was the real reason why it took so long to get the 2010 LCRA through. It was repealed in the original 2010 LCRA. Sad, because some who may have operated an unlicensed station even before LPFM existed, would be disqualified, even though many of them would have the skills to operate an LPFM station effectively.

I'm also curious what ever happened to LP10 stations? There was never an application since the inception of LPFM.

If you ask me, LPFM is a bad joke anyway...it's just another way for not for profit special interest groups (including religious ones) to snatch as many frequencies as they can. Pathetic. It would be interesting to see how many of the Prometheus Project's founders, have a background in piracy. I guess it doesn't matter, though...since they are not a licensee. Anyone can see, that if the government really wanted real community radio, they would loosen up some of the Part 15 intentional radiator rules.

 

[rfry]

Our non-profit is using an AM Transmitter, not FM. Is it illegal to mount it 30 feet in the air, on a metal mast?

In function it would not be illegal as long as the total length of all radiating conductors did not exceed the 3-meter length permitted by the FCC under paragraph 15.219(b).

However the long "safety ground," program audio and power wires running up to the elevated transmitter in many/most such installations can radiate strongly, and in effect are part of the antenna system.

And if the transmitter r-f ground terminal connects by a short "ground lead" to the top of a grounded metal structure such as a tower, pole, roof mount, building frame, billboard steel etc then that path can radiate more than the ~ 3-meter whip considered to be the entire antenna. This is due to the fact that the tops of such conductors are not a functional r-f ground.

Installing one or more r-f filters at the top of such conductors has been done, but in a recent case was found by the FCC to be ineffective for the filter that was installed.

A recent post on a Part 15 website suggests the use a "safety ground" of insulated wire, installed on insulated standoffs along a conducting metal pipe used to support an elevated AM transmitter+whip. That writer states that the safety ground wire is connected to a buried ground rod, and the transmitter is not connected to the top of the metal pipe. In that writer's opinion this configuration should be allowed by FCC inspectors because it is "good engineering practice."

However good engineering practice is a subjective concept -- which by any definition does not remove or supersede the objective requirements of 15.219(b).

Reality for the system described on that other site is that the safety ground will radiate very strongly, even though the wire is insulated, and is installed on insulated mounts. That writer appears to recognize this, because he adds that r-f filtering that conductor may be needed if the inspector requires it.

Would Ken Cartright's non-profit group, if he had one, be disqualified from applying for a LPFM CP as a result of the recent enforcement action?

Difficult to answer. It would depend on what awareness the part of the FCC that considers LPFM CPs has of the previous activities of the applicant, and as to whether or not the applicant met all FCC requirements to be an LPFM licensee.

 

[RadioTheNet]

If you ask me, LPFM is a bad joke anyway... Anyone can see, that if the government really wanted real community radio, they would loosen up some of the Part 15 intentional radiator rules.

Sorry for such a late post. But I am confused as to why you believe that LPFM is a bad joke while loosened Part 15 rules would be a good thing? Right now, it seems that "a Part 15 station" is not really viable as a fully compliant operation would really not service more than a couple neighbors without the use of a bunch of transmitters.

 

[edarmsttrong]

LPFM is only going to benefit special interest groups, with deeper pockets than the average citizen. The criteria is too restrictive for common citizens to acquire a license. Part 15 radio could be true community radio, and revising the restrictive field strength limits of Part 15 FM would really open up avenues of expression for citizens of a local community. A Part 15 operation, within a well thought-out bandplan, and with a reasonable ERP, even well below 1 watt could be operated by hobbyists, with no need for the bureuacratic red tape involved with securing, and maintaining a license. The definition of 'community', I think, is where the disconnect is. What about concerned citizens of a community being able to exercise there constitutional right to free speech over the airwaves? This is permitted for folks in New Zealand, but not in the good ole' USA. And, the residents of NZ don't even have a constitution to gaurantee that right! Not everyone wants to hear what the church or religious group down the street with the LPFM license is broadcasting. But, unfortunately, I would be willing to bet that is where the lion's share of LPFM licenses will end up, due to the ability of these types of groups to raise the cash to secure a license. Isn't that what happened last time licenses went up for grabs? Times are changing, and after there's only one company who owns the modulation scheme for all of broadcast radio, you'll see my point....and wish that there was a way to express an alternative viewpoint on the radio airwaves.

 

[Chuck]

I would be willing to bet that is where the lion's share of LPFM licenses will end up, due to the ability of these types of groups to raise the cash to secure a license. Isn't that what happened last time licenses went up for grabs?

Actually, "No." It had very little to do with cash. The license and the application were free. The FCC even provided a "frequency finder" web page to help applicants find an open channel. The application form was intended to be a "do it yourself" form. They didn't do very well on that, but then your income tax is supposed to be "do it yourself" too, yet most people hire a tax preparer or purchase the appropriate software to get the job done. Government forms are often difficult to comprehend. For someone with no engineering background, the LPFM version was as confusing as any other government document.

The FCC did require that the applicant be a bona-fide non-profit, but not necessarily a 501(c)(3) nonprofit. That meant if you weren't one, you needed to establish one before applying. It wasn't all that impossible to do. One successful applicant was called something like "The Brotherhood of the Holy Hip-Hop." Evidentially, they were able to prove an educational purpose.

It is true that churches got the most licenses. That's because they were organized. The general public was not. Still it wasn't impossible or expensive to be a successful applicant. There were plenty of things to complain about regarding the rules that pertain to LPFM, but cost was not one of the big issues.