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A Middle Ground Between Unlicensed Micropower & LPFM?

Michael Gaines contacted us after doing some research about the potential for very low power FM radio–something under 100 watts, but higher than the milliwatts permissible for unlicensed Part 15 transmissions. After an email exchange on the topic–which revealed we both worked at the same college radio station in New Jersey–I encouraged Michael to share his thoughts with Radio Survivor readers in this post. -Paul Riismandel

by Michael Gaines

Radio can be magical. Growing up in the 70s and 80s with New York radio both on AM and FM, the radio was filled with so much amazing programming: music, comedy, radio dramas, and sports. In the days of only a handful of channels on TV, radio filled in the gaps. I loved radio so much that when I got to college, I became a DJ at my college radio station WTSR at The College of New Jersey (then, Trenton State College). Being a DJ was an amazing experience, one that I’ve never been able to duplicate, even after ten years of podcasting.

After the shift to the digital realm, I found my interest in radio waned for a long time. I would listen to it every day in the car, but that was the extent of it. There’s so much entertainment on the internet that I had forgotten about radio. A few years ago, the DJ bug started to bite again and I started looking into what it would take to put together an internet radio station. After a time I wondered if it was even possible to create a low-power station in town. Radio seemed to be owned by the big corporations, but could a town have its own voice?

I started with FM simply because the audio quality is undeniably better and the band is much more popular than AM. Starting a station from scratch was close to impossible for me, but I found LPFM which is a class of service which is designed to bring radio to communities by using low power. I thought this was great for what I wanted to do, but I learned that the application window closed, and probably won’t reopen anytime soon.

If the window were to open again, I’d definitely apply, but I’d request enough power to cover a small distance – maybe a mile or two. LPFM allows stations to go up to 100 watts, but that’s more than I’d want, both in distance and responsibility at this point.

Jumping into an LPFM station may be intimidating for some people and may be too much to handle when you’re first getting started. There should be a way to serve a town without having to wait many years for the application window to open again.

My town isn’t very large, about a mile across and a mile and a half long. Optimally, I’m looking at setting something up with a 4000–4500 foot broadcast radius, but how do you do that legally? And with the LPFM application window closed, how do you do that before 10–15 years have passed?

My research brought me to the FCC’s Part 15 rules, which are designed for unlicensed, short-range transmissions. The rules are strict about how far a Part 15 FM signal can go–a maximum of 250uV measured at 3 meters from the transmitter. (Note that Part 15 rules for FM do not specify transmitter power, only signal strength as received at three meters. However, meeting this limit typically means using less than .1 watt of power. -ed.)

It’s rumored that a Part 15 FM signal can only go a few hundred feet, but I prefer testing things out myself instead of listening to rumors. (According to the FCC Part 15 permits “an effective service range of approximately 200 feet” on FM. -ed.) I bought a Whole House 3.0 FM transmitter which seemed like the best device to do my testing with. Using the transmitter in its default low-power US mode, I was able to get a decent signal between 600 and 800 feet in my car, with the transmitter sitting on the window sill on the second floor.

I’m sure it would cover more ground if I were able to raise it higher. So many factors decide how far a signal can go: obstructions, receiver sensitivity, the antenna, weather, and line of sight. Still, even if I did put the transmitter on the roof, this device wasn’t going to cover the 4500 foot radius I needed to get the signal out to the majority of my town.

Being I have a background in math and physics, I started working on numbers. Many people tell you how far Part 15 FM should go, but nobody talks about what you need to hit a certain distance. So I had to figure it out myself. Would transmitting with several times the maximum unlicensed Part 15 power limit that show that a new class of stations can be created and not cause serious disruptions to licensed stations? I found that by the numbers, it seems possible.

In Canada, their equivalent of Part 15 rules (BETS) is a maximum of 1000 uV received at 3 meters from the transmitter, and there haven’t been reports of any serious problems there. I determined that under optimal conditions, a small town like mine could be covered with a transmitter that put out a signal that measures about 1600 uV at three meters. However, that wouldn’t fit under the original design of Part 15 FM transmissions which are not intended to go far.

Asking the FCC to extend unlicensed Part 15 FM limits to either my suggested 1600 uV standard or even the Canadian 1000uV standard may work, but you don’t want the airwaves cluttered because of so many unregulated devices spewing FM signals that can go ¾ of a mile. After some thought, I decided that extending the range of Part 15 might not be solution. Instead I think it would be better to create a class which will allow a station to cover an area large enough for a small town, like a mile or two.

My idea is to have a new class which I call Community Low Power FM (CLPFM). The intent is to be between LPFM–which may be too powerful and for which new applications are not being accepted–and Part 15 FM, with coverage that is far too short to be of any use.

Since its purpose is to serve a community, the station would have to be non-profit, and have a worthy amount of local coverage. The station would have to be licensed so that the organization running the station would make sure that they don’t run too much power, don’t bleed into adjacent stations, and that they’re held accountable for their community programming. If the station were to be unlicensed, one town could see several people competing for space on the dial, and that would just get too chaotic.

Kids and adults could use the station to learn how a station works and spin records that the big stations never play, exposing more people to different forms of music easier than any internet service. It’s also a far more personal experience. Who wouldn’t love to hear their friends and family on a local radio station? It could bring a community together far better than something you’d find on the internet because you know these people personally. They’re not strangers.

I realize that in this day and age a town can run their own web site and stream their own content, but people still listen to the airwaves, and there’s a serious gap in the airwaves for the voice of a town. I think it’s time that towns get that voice on the air.

Michael Gaines runs the D20 Podcast Network.

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19 Responses to A Middle Ground Between Unlicensed Micropower & LPFM?

  1. Bill DeFelice July 21, 2015 at 9:04 pm #

    The author implies that Part 15 FM coverage can provide a useable range out to 800 feet. As a broadcast engineer of more than four decades I have to wonder what criteria Mr Gaines used to quantify this result as being “decent” as he states I use a Potomac FIM-71, a field intensity meter often used by FCC field inspectors verifying station compliance in the FM broadcast band. Assuming the transmitter under evaluation were elevated, in an unobstructed, free air environment and emitting the maximum legal field strength of 250 µV/m @ 3 meters the available signal at 800 feet would be slightly more than 3µV/m. It wasn’t noted whether the signal was in stereo or not, as any multipath interference would make such a signal unlistenable or, in worst case, force the radio’s blend circuit resulting in a mono signal of questionable listenability. It’s improbable that the average table and boombox radio would receive an acceptable signal at this distance when factoring attenuation from various employed building materials.

    I’ve encountered many who are unfamiliar of why the FCC limits legal coverage under Part 15 regulations, especially on the FM broadcast band. This lack of knowledge is often demonstrated by the purchase of non-compliant transmitters of 500 milliwatt and greater power output often offered on popular auction sites. Besides being uncertified for Part 15 use, these imported devices frequently emit spurious emissions that cause harmful interference to other licensed broadcasters and other radio services. If these people lack the technical understanding of Part 15 regulations how would they be able to successfully operate a licensed station under much stricter regulation?

    On the FCC website page entitled ‘Minimum Power Levels for Licensed Broadcast Operation’ the effective radiated power specified ranges from 1.0 to 100 watts. The available cited power levels in combination with the type and height of a companion antenna system would have to be able to produce the required 1 millivolt/m (60dbu) contour at 5.6km to be considered for current LPFM licensing. Fighting for a new class of FM broadcast service with reduced ERP requirements might be noble, but its fate seems doomed if you look at the potential lobbying efforts against it by the National Association of Broadcasters and their member stations. The current litany of FM pirate radio activity the FCC must act upon in areas such as the five boroughs of New York would also contribute ammunition against such a proposal ever making fruition.

    Many Part 15 operators are quite content with pursuing their hobby broadcast interests as just that, a hobby. Those who desire large coverage areas on the FM band would be better served by pursuing acquisition of a legal LPFM license allocation during an available filing window. At least two of my forum members successfully graduated from Part 15 compliant low power AM operation to LPFM and are now serving their local communities with both licensed stations and active community involvement.

    Bill DeFelice

  2. Michael Gaines July 23, 2015 at 1:12 am #

    Why am I not surprised that you posted a reply to this? It’s well known that you constantly remind people about 250uv @3m, etc. etc. We know it. We understand it. Nobody’s trying to bend any rules here. As I’m sure you read, I already posted about the legal field strength in my article. There’s no need to repeat it. Also, this test was just to see how far the signal went; not with a specific device, but just to see. An experiment. When people tell me “that’s the way it is”, I tend to not believe them until I run my own experiments. The internet is filled with too many armchair quarterbacks. I arm myself with facts, not here-say from so-called “experts”.
    You imply that the WH3 is not FCC compliant. It most certainly is, as found on their web site under an FCC ID search which you can find under Grantee code XOA.
    You also ask people to file for an LPFM construction permit when the window opens. You know very well that it might not open for more than a decade, if ever. Life is way too short to just sit and wait around for that to happen. Fifteen years (at minimum) is a long time to sit around and wait when you have the power to make change happen yourself. You consistently cite passages on your website as to why expanding Part 15 or creating a new class won’t happen. You tell the people on your site about how we’re going to fail. Look at the many, many things that have changed in the United States over the last year alone. Things that people would think would never happen. People said that pot would never be legal, and yet it’s starting to become that. It wasn’t even about money or lobbying, it was about common sense.
    Part 15 hobbyists might enjoy what they do and that’s fine, but who wants to broadcast across a few blocks when they can do something better for their whole community? Doesn’t it seem illogical that there’s a big gap between Part 15 and LPFM? That’s a gap that can be put to good use. Why NOT use it? Because the FCC said so? I don’t roll over and just accept things the way they are because someone just “says so” when it seems illogical. People and organizations change their minds all the time, it just takes the right argument to persuade them to do so.
    If the FCC doesn’t agree with us, that’s fine, but I’d rather spend the next 15 years trying to get a signal to go a little farther legally than sit on my butt waiting for the next LPFM window to roll around. Canada’s equivalent to Part 15 (1000uV @3m) is just fine for them, so why not at least try to adopt that?
    If people didn’t try to change the rules, at least for a logical reason, then nothing would change. Think of all the good a stronger signal can do without having to wait over a decade for it to happen. I suppose some people are willing to just stick their head in the sand. I am not one of them.

  3. Dj Troy July 23, 2015 at 12:11 pm #

    Ok I’d like to add to this as well. First of all this is only FYI here and I’m not telling you to break the law. There is a town in Michigan called Frankenmuth, Michigan which is a Christmas town. They run Christmas light shows 24/7 365. Now one of these places used an FM Transmitter and for several years for that matter. Rather it is 250 uV/M is questionable as I could hear this FM Transmitter (In Stereo) for ¼ mile away from it. Now this has happened for a few years and I know I’m gonna hear “Oh God he’s a Pirate!” but really that is not what even a true Pirate considers to be worthy of the status of Pirate. Many Real Pirates are running anywhere from 7 Watts up to 100 or more. Now again I’m not saying lets all run 2 Watt stations but certainly I don’t believe one is going to spend the money for Mixer’s, Audio processing to only reach to the end of their driveway or across the street at best to the house across it. Keeping this in mind you have to ask yourself and the statement was made that part 15 FM is barely usable due to the poor quality of the new portables and home stereo’s made now days. That in itself is reason enough to increase the limit (Never mind any other reason). That and weigh in the fact that yes some transmitters are in gray areas where they might have been certified at the 500mW level (certified means a grant) and later certification was possibly removed. So those buying and using these transmitters are buying in good faith. The field strength rule as it is is not measurable by common people (Though you may have a Potomac FM-71). Rather than field strength it would be far better to allow 500mW to 1 Watt into an inside antenna (Rubber Duck or telescoping antenna) or antenna that is made with the transmitter. This may cover 1 mile to a home Stereo and I’ve seen this on Youtube. One should not be afraid to speak up and ask for this as many agents don’t see an issue with a station covering a Neighborhood (as was even stated on hobbybroadcaster by Radio Brandy 100 acres). Now Legal or otherwise this is how some of the members of the FCC feel (We know the written 250 uVm rule here). Being that as it may be allows for a possible change for Micro Powered (Not the full FM blow torches going 5-10 miles) station. Again look at New Zealand which already has a Watt. Lots of data can be obtained from this as well. Now take into the account of the possible expansion of the FM Band. As was done in New Zealand a few frequencies (87.9 for one) could be dedicated to Hobby Micro broadcasting. I think you as a hobby broadcasting website operator should encourage not discourage legally asking for change. This would eliminate the “Pirates” as you call these micro broadcasters who are not willing to settle for a static prone AM band to play bedroom DJ on. Lets work together instead of against one another. Even if you are a member of the NAB we’re willing to work with you and we’re not going to Kill Radio because if I play a song a listener doesn’t like they’ll change to one of the many NAB stations. One may buy a Radio knowing they can hear their friend or neighbor on it but it doesn’t mean it will be glued to that station 24/7 365. It only makes more people buy a Radio.

  4. David Chamberlain July 23, 2015 at 12:41 pm #

    I also have to wonder just what Bill DeFelice has to gain by his comments on the article. In particular, casting doubt on the range testing done, as well as the transmitter used in the tests.

    It is well known in the field of Part 15 broadcasting that Bill runs a website that is oriented towards Part 15 AM. That’s great. And if he doesn’t feel that a CLPFM service is justified, then he’s entitled to his opinions. But that’s it.

    If Bill is the broadcast engineer that he claims he is, then he knows perfectly well that an FM signal of around 3uv can be heard quite comfortably by good car radios (which have a sensitivity of around 1uv and even under with SNR ratios of approximately 20db). A car radio was used in Michaels’s tests. In fact, while there are a whole host of factors that affect Part 15 range, it is entirely possible to hear that signal out to a range of 1000 feet, line of sight, with good car radios, or home stereos with outside antennas.

    The results reported by Michael have been duplicated by many other Part 15 broadcasters using legal and certified FM transmitters.

    As Michael states, the Whole House transmitter is certified by the FCC and is legal to use for broadcasting.

    So I have to ask again, just what does Bill Defelice has to gain? If one goes to his website, you find that there is a great deal of talk about FM pirates. They seem to see them around every corner, and in fact, every Part 15 FM installation, regardless of its legality.

    Bill has to be more careful in the future in allowing his obvious biases impinge upon the realm of mathematics, physics and science.

  5. Dj Troy July 23, 2015 at 1:12 pm #

    And if you ever read when I started the campaign that I wanted to new high powered and maybe all new transmitters to have a scan feature that would scan the fundamental frequency that is intended to be used and then one adjacent frequency above and below it. Say if you want to use 96.3 Mhz it would scan 96.3 Mhz and the one below it 96.1 Mhz and the one above it 96.5 Mhz. If these frequencies are not blank it won’t transmit. And if there is no empty frequencies in your area you are out of luck. Plus the transmitter would do a scan once per hour to make sure a temperature inversion has not changed things. Also if the transmitter is used in a car it would have a proximity sensor and if it detects movement it would drop to the output of -45dbm (18 nano watts). The reason the NAB had issues before was because of the folks in cars. So to alleviate the issue we now have my proposed mandatory scan and proximity sensor (hey smart phones have them). Again we are willing to work with you folks at the NAB so please stop trolling and play nice with us and good things can happen.

  6. Bill DeFelice July 24, 2015 at 4:24 am #

    @Michael: Your glossing over my comment of how you qualified the reception of signal at 800 feet makes me believe you may be ill equipped to defend your case with the FCC. If you plan on presenting your proposal for their consideration you’ll need accurate data and not obscure references. The hornet’s nest such a proposal presents could have both commercial and noncommercial broadcasters alike looking to poke holes in it anywhere they can. My queries are simple when compared to the ones that will undoubtedly come from licensed stations and lobbyists with full time legal council and friends in ‘DC should things progress that far.

    @Michael & David: Regarding the Whole House 2 and Whole House 3 transmitters, it’s been well documented online that that the manufacturer has either supplied accessories or provided methods by physical and/or electronic means to increase the field strength of said transmitters beyond the legal limit defined under Part 15.239. You might want to review the publicly accessible certification documents for each and note that neither the questionable accessories nor RF mode switches for either model transmitter were disclosed in any portion of their respective certification paperwork, including the submitted operating manuals. The impression that the manufacturer concealed these undocumented features from inclusion in the certification package delivered to the FCC Office of Engineering and Technology appears pre-meditated and deliberate. And Michael, as to why I “constantly remind people about 250µV/m @ 3 meters” on my site? Because I don’t want anyone to question that I only promote legal and Part 15 compliant FM band operation, unlike other sites. The FCC often visits my site for which I’ve extended an open invitation to them for a representative to participate, should they so desire.

    @David: While a car radio might receive a 3µV signal 800 feet in an unobstructed space would you expect someone to sit in their stationary vehicle to listen to a transmission of this quality possibly riddled with multipath interference? Are they going to have any chance of receiving such a paltry field strength level indoors using Walmart-quality clock radios or boomboxes in typically constructed home or other buildings? What rationale supports the justification not only for a proposed field strength increase but for how interference mitigation would be determined and addressed? Regarding Part 15 FM transmitters: I’ve personally documented field strength variations in different samples of certified transmitters of the same manufacturer and model, so how can you assume the samples used in the conducted experiments have been vetted for proper field strength output? I have calibrated field intensity measuring equipment of recognized accuracy with no assumptions made about any transmitter’s actual field strength. And, to address your allegation, the only bias I have is against those who parade their FM transmitters or “stations” as being Part 15 compliant when they’re not.

    @DJTroy: Do you truly believe pirates will suddenly go away if your proposed increase in field strength were accepted? The former forum member you cited as stating they had a 1 mile coverage had their claim refuted in subsequent posts. That brings to mind that you also stated above “… many agents don’t see an issue with a station covering a Neighborhood … this is how some of the members of the FCC feel.’ Can you cite those FCC members who, on record, feel this way? Commissioner O’Rielly’s recent comments would seem to contradict your assertion. As far as a transmitter frequency proximity scan feature goes, if somebody were able to devise a working subsystem as an interference preventative measure at what field strength threshold would it have to operate at to be considered adequate? I’m certain this technical qualification as well as the methodology used to determine same would be important to the FCC as well.

    @All: Have you ever pondered the reasoning to why the FCC re-wrote the former Part 15.120 more than a quarter-century ago and cut the legal Part 15 FM field strength to half of its former allowance? If there wasn’t any problem why would they have gone to the bother to reduce it? In any case, you and your troupe are certainly welcomed to pursue your attempt but I believe you’re not open minded to the cold, hard reality. Licensed broadcasters, especially the larger corporate groups with a big stake in their local operations, aren’t simply going to rest on their laurels – especially if they sense your proposed field strength increase has any hint of a potential threat to their revenues. Consider the lobbying power these broadcasters have, not only with their local and state associations but NPR, PRI, Corporation for Public Broadcasting and the National Association of Broadcasters. Factor into all this that FCC Commissioners O’Rielly and Pai have gone on record, as recently as a week ago, against pirates and it would be highly improbable such a proposal would sway either of them. If you believe your group can secure the requisite war chest to proceed then go for it. The past petitions for a Part 15 AM power increase never reached fruition which makes it appear you’re in for nothing but an upward battle.

  7. AP in DC July 24, 2015 at 6:40 am #

    Michael, a key piece of your editorial is missing: where is the town of which you speak?

    If you were in Middlesboro KY, a service such as you suggest – if made legal – could be viable. But if you are still remotely near Trenton NJ, where the RF is so thick you could butter your toast with it, then no; the interference problem then escalates and the commercial biggies descend upon your door.

    I’m an educator as well as a broadcaster so trust me: Kids won’t listen to other kids on the radio unless it’s homework; not when they have their portable digital electronic doodads. They WILL listen to their friends hosting a stream or podcast, as long as they are playing the one-note drumbox dreck they now live by … at least for the 30 secs or so it takes before they yawn and click away to something more interesting. They will absolutely do the same to an FM receiver.

    Other than the glory of calling one’s self a “station owner” or “operator”, it actually makes more economical and logistical sense (in a case such as yours) to shun an RF plant and create a streaming station with a stout but finite number of listener connections. Whoever does that first in your town and promotes it properly will be the winner. It pains me to say that as a 37-year broadcaster AND low-power proponent, but reality is reality.

  8. Michael Gaines July 24, 2015 at 9:13 am #

    I didn’t do the experiment and JUST that experiment as the only thing I’m going to use to go to the FCC with. It was just. an. experiment.

    There’s a lot of work to be done, and one experiment isn’t going to be the defacto argument we use. I’ve already stated that, there’s no need to continue on with poking holes in everything when there’s no solid document yet.

    You talk about “open minds”, yet you’re closed to even trying. So the FCC cut the amount in half – 25 YEARS AGO. In the meantime, Canada runs FOUR TIMES the uV and it hasn’t caught fire yet, has it? So, just because the numbers changed here doesn’t mean it was for a reason that makes sense today. If you said only 5 years ago that pot would be legal in this country, people would laugh at you.

    I don’t know why you’re on such a crusade against FM, to the point where you push against people trying to make a change for the better. You haven’t once posted why you think it’s a bad idea. In fact, I’ll bet you can’t. You just regurgitate what was said a quarter of a century ago without looking at the bigger picture. Times change.

  9. Dj Troy July 24, 2015 at 10:30 am #

    Bill I’ll try and answer your questions as best I can. First I want to answer the question of the field agent or agents who feel the same way we do. I’m only stating what was on your site by Radio Brandy. Plus the countless stories of when agents have came to the residence of some part 15 stations who were a little over and was simply asked to turn the power down in which they did and the FCC agent chatted with the operator. I’m sure the person who was talking about it at the private ALPB meeting was asked to keep the agents name a secret because if that were to have gotten out his job could have been in jeopardy. I have no problems with trying to make the reception of a part 15 transmitter (at full legal field strength) known accurately. We have one of our members who does have a Patomac FM-71 which was the same field strength meter the FCC uses to bust part 15 operators who’s been operating over the limit. I do want accurate data before we do this petition because I know that there is a difference between certified transmitter to certified transmitter. I’ve even stated a fudge factor seems to be in play here and some manufacturers are worse than others and the tests that Tim wants to conduct will show this. As far as will an increase make Pirates go away? Your answer to that is (Some not all) but its a start. Again I’ll refer to the Christmas light shows which often could be using what you call Chinese imported transmitters that cause harmonics. If again as I have stated all new transmitters made from now on were required to have that scanner prior to transmitting a lot of what happened before with the interference to commercial stations would not exist. There are many folks who just want that ¼ mile range which by the way is the same range you AM part 15 stations now enjoy. So yes if the rules were rewritten or even if our proposal were presented to the FCC this would be the first thing I would propose right off the bat that all new transmitters both AM and FM be required to scan the band first with a sensitivity level of the old 70s Stereo’s and German Radio’s which had the same sensitivity as a car Radio. Then I think your issue with Johnny Punk jamming legal stations would be nil at best. Maybe make a requirement that the higher power operator can only use a certified transmitter and if they are caught using one that is not they get a fine. Again I’m quite aware as to why they lowered the field strength as I too have done my homework and read the NAB’s and NPR’s complaints. The field strength would have never had to be lowered if they had implemented my safe guards as I’ve described on countless times. You have mentioned the fact that the whole house FM transmitters both have the secret High Power mode and the antenna accessory to improve range. My answer again legal or not is that these companies are in business to supply the demand Just like the NAB they need to make money and at 12 inches from the antenna won’t make them any money. Just look at the Belkin FM Transmitter total piece of junk in its stock form. They have numerous customers who complain that their transmitter has to be practically touching the receiver’s antenna in order to receive the signal and because of the NAB breathing down their neck I’m sure they made their transmitters well below 250 uV/m (remember these units are mass produced). If they were to have made it 250 uV/m for every transmitter they would have to pre tune each one by hand. That in mind could cause them to do things slightly under the table to please their customers. And even if every customer does put those transmitters at high power I have to ask did the sky fall? I’m quite aware of the transmitter hacks on line (with full video’s in the how to’s) again legal or not the FCC is not going to cite everyone who operates well below a watt and yet is above part 15 though they will bust a few and use them as an example. All I’m trying to do here is make it safe and legal for everyone and 500mW to a rubber duck or telescoping antenna will not make the sky fall. But the fact that the piracy drum keeps beating could kill part 15 as we know it. This should be every part 15 operators concern AM or FM. There will be the opposite side of the fence where a few law enforcement officials may try and arrest a legal part 15 operator because they feel that any unlicensed Radio operator AM or FM is a Pirate and this I feel will happen with all the attention drawn to Piracy and what seems like a cheer going on from what should be a pro hobby Radio site. I realize New York and areas where there are a lot of foreigners have Pirates, but look at the reasons behind that. Plus New York is the place where you’ll find a very diverse culture of folks from all races and who came from the states from many different walks of life. Radio for them is precious and apparently there is a missing element that causes the Piracy in Radio to be quite welcome by the citizens of New York. But really back to the topic of reception of a part 15 station. Digital receivers have better sensitivity and selectivity than a $5 analog dial Radio. This is why I want to see what true 250 uV/m will do even hear the recording of the reception. Also Canada allows 1,000 uV/m at 3 meters as was tested on a Decade MS 100 could get close to that ¼ mile I want for part 15 FM to make it equal to AM. This would be a really nice way to promote my Streaming Radio station to the locals who may happen to hear my station. Increased part 15 Radio would be a great companion to ones Internet Radio Station. You asked me personally if we were to put these safe guards to prevent interference what field strength would be adequate? Well at least 1000 uVm as is in Canada’s BETS level. However I’d like to see it 1600 uV/m @ 3 meters or the equivalent of a 500 mW transmitter into a Rubber Duck antenna (As I’ve mentioned numerous times hence I’ve asked for 500mW into a stock rubber duck). Again since its illegal in the USA to conduct such a test I’d need one of our members of the ALPB in New Zealand who has already got a legal 1 watt station to if he can turn his down to 500mW test it with a rubber duck the same as the SainSonic AX-05B. Once we have the field strength when read by a Patomac FM-71 I can say X @ 3 meters. However I think just requiring a rubber duck and 500 mW should be sufficient, but hey we’re talking about the US government here who doesn’t seem to want to think of the easy way. So it just means at this point I need to have that data before I can shoot of a number off the top of my head. However science so far shows by the data we do have that 1600 uV/m @ 3 meters could be a good start. It should cover a ¼ mile range into a portable boom box and 1.5 to 2 miles on a really good Car Radio. Yes The NAB will cry foul play but with my safe guards Johnny Punk can’t transmit on his 500mW transmitter if it is occupied and he can’t put it in his car and start to move for the very fact he backs up will throw the transmitter down to 18 nano watts. Again we need more field strength data to throw that number but worse case scenario we may only get 1000 uVm wich covers around 1,000 feet and may get a block or so on a boombox (Digital I don’t count analog Radio’s to me they are junk). Bill you have a good valid point about the broadcaster’s who worry about us killing off their revenue. Well maybe we could mention that Hey if you want to hear Country listen to X or if you want to hear Britney Spears listen to X If you want to hear Rap listen to X. But The Legacy plays only Album Rock so if you request something that is not in our format you’ll be sent to one of the many local stations we have here. Plus even though my station don’t get far during severe weather I already talk about different local stations. If anything just like I said family, friends and other locals may buy a Radio just to try and hear a bedroom DJ simply out of curiosity and in the end could help all stations on the FM Band. I hope I have answered all your questions to the best of my knowledge. As far as we know you could be a member of the NAB or have close friends who are and that is OK too as we really need to come up with a civilized solution to this issue.

  10. David Chamberlain July 24, 2015 at 12:53 pm #

    Bill, I appreciate you clarifying your comments, even if I don’t agree with most of them.

    The fact that the Whole House transmitter packaging includes modifications, if you will, to increase its field strength is really a red herring and has nothing to do with the experiment that Michael conducted. He used an unmodified Whole House 3 transmitter, fresh out of the box from an American supplier, and certified to U.S. standards. Many certified FM transmitters can be modified relatively easily to exceed the rules – even the original C. Crane transmitter (which I believe your site has reviewed, you seem to have no problems with, and many of your Forum members use) has a ‘secret’ adjustment in the battery compartment (covered with a sticker when delivered). It is true that no baseline measurements were taken re the initial field strength of the WH transmitter, as that instrumentation was not then available, but it is highly likely that if it was higher than the 250uv/m at 3 meters, it wouldn’t be by much, as it is certified (and the manufacturer could lose their ability to sell the transmitters in the U.S). It is much more likely that the field strength was LESS than allowed, because the rules only specify a maximum – if I were a manufacturer, I would take steps to ensure that no transmitter exceeds that maximum.

    You are quite right that an ordinary clock radio will not receive a 3uv signal. In fact, there are few portable and handheld radios that could. The fact that car radios can receive such a signal is significant, because statements have been bandied around that a legal Part 15 FM signal can’t be received more than 200 feet, and that is patently false, as Michael has shown (it all depends on the receiver). Yes, if the car is moving, then a signal that goes out 800 feet will only be heard for a short while. However, there are many specialized applications that involve Part 15 signals and stationary vehicles – I was involved with one for 2 years. My station on Bowen Island broadcast to a ferry lineup. And not only that, but I had plenty of listeners that told me that they drove their cars to the strip mall in which I was located to park and listen to the station, because of the very limited coverage area.

    But the major reason that range testing is important is to ascertain, for a given field strength, exactly what the coverage might be for different classes of receivers – car radios, portables and handhelds. You yourself have said that the FCC will require detailed technical information, and potential ranges will be a small part of that information. It will allow us to better determine potential interference to licensed broadcasters. I would also imagine that the NAB and others will also be very interested in exactly who will be able to receive our signals, and with what.

    Finally, I’m not sure what your and your site’s fascination with pirates is really all about. Part 15 operators are attempting to operate within the rules, and are quite happy to talk about what they’re doing. They don’t hide. Pirate operators, often on FM, make no attempt to be legal (often operating with power in the watts as opposed to Part 15 FM’s nanowatts – i.e., billionths of a watt). Pirates hide in the shadows. An article written by you for Radio World makes a plea for the FCC to not confuse Part 15 operators with pirates. So why do you?

    There is a huge difference between someone who is attempting to be compliant and isn’t because of ignorance or misunderstanding, as opposed to others who just blatantly ignore the rules. There are many Part 15 AM installations that describe their elevated transmitters on your site in the Profile section. Does the fact that they must have long ground wires (contravening the 3 meter antenna+feedline+ground wire rule of Part 15.219), or the fact that they may be grounding to a long metal mast which is acting like a long ground wire, mean that they are pirates? The same standards need to be applied to both Part 15 AM and Part 15 FM.

    You state that you want the FCC to know that you don’t tolerate pirate operations on your site and in the real world. That’s all well and good – I don’t either. But continually talking about pirates makes the problem seem much larger than it really is in the Part 15 world. Which is going to make the FCC look longer and harder at all Part 15 operators, exactly the opposite affect of what your article was attempting to achieve.

    Anyway, thanks again for your comments.

  11. Michael Gaines July 25, 2015 at 11:11 am #

    You said: “I’m an educator as well as a broadcaster so trust me: Kids won’t listen to other kids on the radio unless it’s homework; not when they have their portable digital electronic doodads.”

    Thank you so much for making our point. If people are moving from FM to doodads, then that’s all the better reason to get FM back into people’s lives, right? I mean, I might as well just make an internet radio station, right? Apple Music, Pandora, Spotify, and so many other music services out there. Who needs radio? (that was sarcasm btw).

    Maybe now you’ll understand what we’re trying to do. If I wanted to do things the easy way, I would have just made an internet radio station and called it a day. Instead, I’m trying to bring radio back to people that use doodads. Get it now?

  12. Dj Troy July 25, 2015 at 12:53 pm #

    And the crowd gives a standing ovation Bravo Bravo! I could have not said so better than that simple and to the point statement. And in the beginning was not Radio supposed to be for the People? Obviously the “People” aren’t listening to the Radio as they use to so there for the Radio is not meeting the PICN (something a first grade broadcaster would have learned in college as I did my first day at WOCR in Olivet, Michigan) interest, convenience and necessity). Now does Radio meet those needs now days? I say not really. Oh you need the weather? There is an app for that. News? There is an app for that too. Radio now is starting to become a pool of what the corporations think the community is interested in. I can’t say hobby broadcasters won’t be a little bit of the same, but at the same time if someone buys a radio out of curiosity because Doug Smith is playing a lot of the music they enjoy and maybe some other interesting content as well and they buy a Radio to listen to him Doug Smith is providing the Interest of someone in the public. Well the PI was met what about convenience? Yup that too. Obviously the neighbor seen a necessity to purchase a Radio to hear Doug Smith and his music and or show. Now that is what was meant when the FCC started to require a license for Radio operators on the FM band to begin with. Just as part 15 hobbyists need to rethink of why did the FCC allow part 15 in the first place ask yourselves as licensed broadcasters what did the FCC intend for you as a licensed broadcaster before you became a NABcaster. Good case my friend I wish that came out of me however that is what the ALPB is for us part 15 operators to improve things.

    • AP in DC August 3, 2015 at 7:45 am #

      (Quote) If people are moving from FM to doodads, then that’s all the better reason to get FM back into people’s lives, right? (end)

      — FM is already part of their lives but the paradigm is evolving. Power isn’t the answer; moving ahead and innovating is.
      You won’t find a bigger champion for radio than me, anywhere. But put low-power politics aside for a moment and think pragmatically. Research bears out that radio listenership is still strong, but wireless web devices are coming up and fast, especially among younger audiences.
      If your audience will be listening on the doodads, put the show on the doodads. Then promote the daylights out of it as any station would.

      (Quote) If I wanted to do things the easy way, I would have just made an internet radio station and called it a day. Instead, I’m trying to bring radio back to people that use doodads. Get it now? (end)

      — I get where you’re going, but ask any number of gaslamp lighters, piano tuners, stationary boiler operators, theater projectionists, milkmen, Big Band leaders and whalers what they think. “Going back” is noble and nostalgic, but not practical.
      If someone has their phone or their tablet with them, they already have a global radio, a TV production environment, a photography studio, a personal movie theater and a soapbox that can reach all corners of the world. There had better be some very compelling CONTENT on a CLPFM that would make them want to put their devices down and switch on their Kenwood. That is what needs to be addressed, not the level of power going up the stick.

      BTW, I still didnt find what city/region you were looking to launch in. Where u @?

  13. David Chamberlain August 6, 2015 at 3:54 pm #

    You’re right. Compelling programming is going to be paramount to get any sort of listenership.

    But then, if your coverage area is approximately 200 feet in radius for an ordinary radio, or about 800 feet for a car radio, as it is with the Part 15 FM rules right now, then you’re not going to get many FM listeners no matter how compelling your programming is. That’s the intent to get the rules changed – at least put Part 15 FM on the same footing as Part 15 AM, and allow it to truly serve the community (even if it’s a small community).

    And there’s also no doubt that any radio station, CLPFM or otherwise, has to put that programming ‘out there’ on those electronic doodads, from computers to cell phones and tablets. No one is saying otherwise. But there will always be a market for radio as well.

    You do what you love, but you also keep up with the times and technology.

  14. 1700 AM August 7, 2015 at 9:44 am #

    A noble idea, but the path is peppered with all sorts of landmines.

    LPFM’ers took it in the chops from commercial FMs and the NAB on their way up. CLPFMs are likewise going to take it in the chops from the same groups, *PLUS* the existing LPFM’ers. Most prospective community broadcasters wouldnt even brace for such a battle. Even then, what is to stop existing Part 15 AM’ers for applying for the same service once enacted? The rug would be out from under you even before the ink is dry.

    The service is redundant. Just based on power levels and the intent of the category itself, aren’t *all* LPFMs “community radio stations”?

    Lastly, the FCC won’t consider such a service based on little more than, “Because I wannit!” That is basically the only rationale offered in this op-ed piece. If the public can receive entertainment and information via AM, FM, cable television, text, and all forms offered by mobile electronics, what would be the Commission’s motivation to consider it?

    I commend you for your inventiveness. But if you want low-power community radio, wait for the next cycle of LPFM licensing and do it right. Or get on the AM band.

  15. Dj Troy August 8, 2015 at 10:25 am #

    I agree that Internet Radio is a great way to be heard for a hobbyist as I already have a great Internet Radio station playing Album Oriented Rock. That is not to say my station didn’t have growing pains for it sure the heck did. For one thing your going to experience right off the bat is Bandwidth issues especially if you live in an area that is not metro or a little hick town where most folks in that town are unemployed or never heard of composing a resume to go job seeking. I fought for a non interrupted upstream of what should be an easy 128K to a server in Texas (I didn’t run my own server one upstream). Well I’m broadcasting right along when all of a sudden wham my upload speed is not enough to handle my puny little 128K. What was worse when a technician came to the house they told me that a TV I never had connected to the system was the culprit. And a word of warning to all you Internet Radio station operators. Do NOT tell/let your ISP know your running an Internet Radio station or you’ll get throttled to a little more than 56K. I had to purchase a Verizon prepaid hotspot to run my station without interrupted nonsense caused by my cable provider and I paid DEARLY for 10GB/month @ $90 a pop. So it meant running my station nothing else on the net because otherwise I was spending $180 every two weeks just for BANDWIDTH!! It didn’t include the cost of a server and royalty licensing. So there is no easy road when you run an Internet Radio station either. If you do deside to run one you’ll need the highest speed your provider offers or move to a fiber optic Internet area. If you don’t live near one MOVE it is the only advice I have for you if you plan to stream 128K (required to meet the picky format such as Album Rock). If your a Rap station you could stream 32K mono Mp3 all day long and no one will care but if you plan to stream Classic Country, Classical, Old Christian music you better be top notch Stereo and Audiophile quality. This is going to cost you around $180/Month for your Internet (Minimum) in quite a few areas.

    Now look at a part 15 station and the cost:

    1. Whole House FM Transmitter 3.0 $125
    2. NestKast Dj software $199
    As you can see it is 100% cheaper to run a part 15 station than it is to run an Internet station because you have to in a lot of areas add that $180/2 weeks. For poor folks that is a car payment or mortgage payment and if you live in a military town your Electric bill can run $600/Mo or more if you live in Town which for better Internet speeds we have learned that the closer you are to the hub the faster your Internet is.

    Now part 15 Radio be it AM or FM is cheaper for the operator and the public to receive it. For the public if your on AM they should purchase a Tecsun Radio right off the bat because these boom boxes have terrible AM reception. When I get my Talking House AM transmitter set up and advertise my station I’m going to tell my listeners OFF THE BAT Tecsun is one of the ONLY Radio’s you’ll hear my station for 2 miles from it or you’ll need to purchase a pre 1984 Stereo or Radio refurbished. Or they will have to be in their car to hear it. If only I could make a deal with Tecsun. These crappy Radio’s today have no filtering so AM is all full of hydro and Buzz buzz. So it would take a 10 watt AM transmitter to go 150 feet down your driveway. But we’ll see when I get mine.

  16. 1700 AM August 12, 2015 at 9:26 am #

    DjT, your analysis is well researched and taken to heart, but some of your estimated expenses are a bit simplistic.

    Computers require electrical power to operate, whether streaming or driving a Part 15. That goes on the utility bill. Computers also require replacement parts and upgrades…more $$.

    A Part 15 transmitter requires lightning protection. The extra coaxial cable and a replaceable spark arrestor have to be factored in.

    Move beyond Part 15 power levels as Michael wants to do and the cost to run a transmitter and proper RF radiator come into play. But that isn’t relevant right now.

    A transmitter connected to a computer is what chased listeners away in the first place; it is sterile and unlistenable, and not one bit better than what is offered on any commercial station now. As stated before, Content is King, which means providing live & local interest in your community. Add in a mixer board, quality microphones et al, and the cost goes up yet again, whether streaming or 15’ing.

    You can save a buck by using ZARA (free) as your automation platform and using B.U.T.T. (free) to stream to a proper server. But there is a huge difference between a station serving a community and a vanity jukebox filled with one’s favorite music. Streaming or radiating, one way or the other, its going to cost to run a station.

  17. Michael Gaines August 23, 2015 at 3:36 pm #

    “wait for the next cycle of LPFM licensing and do it right”

    And when will that be? 15 years? 30? Ever?

    There’s a gap between Part 15 and LPFM, and someone needs to research it and get it done, and it’s getting done.

  18. timinbovey September 10, 2016 at 5:50 pm #

    I’m all in favor of Part 15, and the concept of something between that and LPFM.

    I’ve been doing Part 15 AM for three years now with good success in a very small northern Minnesota town, where I easily cover the town with my signal.

    Last fall I did tests of some Part 15 certified transmitters, Among them the certified Whole House 3.0. The unit I purchased, at retail, from a US seller, was WAY over the FCC legal limit. it wasn’t even CLOSE to legal.

    To try for any sort of accurate range testing you need to start with a transmitter that is operating at the legal limit. Which means you have to start by testing the individual transmitter that you hope to range test with.

    I also tested the latest C. Crane transmitter. It was legal. In fact, it was VERY legal, coming in far under the legal limit. So if you were to range test with one of these you would be disappointed.

    Tests were done in an open field, using a Potomac FIM-71 AND a Z-Tech-506, both units used by the FCC in the field. Results were consistent between both machines.

    I know how to test ’em. 43 years in commercial broadcast radio, currently chief engineer for three stations. SBE certified, ham, GROL license (used to be FIrst Class license). Not meaning to brag, just indicate that I’m qualified to be performing accurate tests.

    Trying to range test a Part 15 FM transmitter really needs the transmitter to be tested first! Certification doesn’t seem to mean much. I tested 4 different transmitters last fall, not one came out in the ball park of the legal limit. Two were WAY over, two were WAY under.

    I do wish the best of luck to those working for a new class of FM.

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