The announced closing of almost half of the FCC field
offices has many in the engineering community concerned and worried about the
future of the broadcast bands.
Based on my own four decades and more in the industry,
it comes as no surprise that many pirate stations had longer life spans due to
the lack of FCC manpower to investigate, confirm and prosecute the operators.
My own concern comes for those who operate legal, license-free broadcast
operations under Part 15 regulations yet have been unfairly targeted by field
agents for a variety of reasons.
TARRED WITH ONE BRUSH?
Besides having served as a consultant and staff
engineer for a variety of commercial and non-commercial AM and FM stations, I’m
the creator and webmaster of HobbyBroadcaster.net, an online reference for
radio hobbyists, educational institutions and businesses who want to utilize
Part 15-compliant broadcasting. The site was created as a result of building a
high school campus-limited station in the district that serves as my 9-to-5
The feedback I’ve
received from my website’s visitors and forum participants is that FCC field
agents rarely discern the difference between blatant FM pirates and persons who
make a concerted effort to operate within the bounds of Part 15.
For example, it’s all too common that pirates
purchase those sub-$100 Chinese-manufactured FM transmitters riddled with
spurious emissions on venues such as eBay Inc. In contrast, many Part 15
operators purchase FCC-certified AM transmitters costing hundreds of dollars,
with a few models approaching close to $1,000. I sincerely doubt a pirate would
buy such an expensive transmitter if their sole intention were to break the
individual was visited by an FCC field agent who had been called on him by a
group whose motives were strictly spiteful. He used a factory-fresh i.AM.Radio
transmitter that is easy to install and operate; with this transmitter, it
would be virtually impossible not to
comply with Part 15.219, the applicable regulation for which it was certified.
operator felt that this agent made some attempt to intimidate his landlord
during the visit. The inspector has a reputation for being particularly
aggressive, often treating Part 15 enthusiasts with the same disdain as blatant
15 operation on the FM band is pretty much limited to in-home or perhaps
“yardcasting,” with the limit on field strength dictated under Part 15.239.
This also was explained for the layperson in a 1991 FCC public notice,
“Permitted Forms of Low-Power Broadcast Operation.” An unlicensed FM signal
that reaches beyond a few hundred feet, at best, is likely out of Part 15
compliance. FM pirates push this tens, hundreds or even thousands of times past
the FCC limit.
in the engineering community may be under the impression that the range of a
legal Part 15 AM signal is limited to 200 feet due to the aforementioned public
notice. I personally disproved this while performing an “AM Transmitter
Challenge.” This side-by-side operational comparison of five popular Part 15 AM
transmitters was performed utilizing a by-the-book, ground-mounted Part
15.219-compliant installation (i.e., 100 mW final stage input power combined
with antenna and ground length not exceeding 3 meters). Field intensity
measurements were recorded using a Potomac FIM-41 and off-air reception judged
using various portable and automobile receivers. In spite of a local ground
conductivity of 1 millisiemen per meter, the signal of the best performing
transmitter was receivable out to nine-tenths of a mile away using a car radio.
only know of two individuals in the engineering community who have a vitriolic
response when it comes to anyone who willingly participates with Part 15
experimentation on the AM or FM broadcast bands.
hobbyists and educational institutions have described their experiences when
field agents find non-compliant installations. Some inspectors will simply
instruct an operator how to correct the installation for compliance, sparing them
from a notice of unlicensed operation. But others may take a harsh no-latitude
stance, instructing the operator to shut it all down — or else. This dramatic
outcome, appropriate to a pirate, is unfair when applied to a small,
well-intended operator who does not intend to violate the rules.
With corporate, group-owned station clusters now
engineered by outside contractors, will licensed stations blindly sue Part 15
operators if Commissioner O’Rielly’s plan is implemented? Will dispatched FCC
“Tiger Teams” be able (or willing) to differentiate between a Part 15 AM
operator who may have unintentionally strayed out of compliance and an obvious
pirate FM station, causing harmful interference or sporting a coverage area
grossly beyond Part 15 limits?
contacted both Chairman Tom Wheeler and Commissioner Ajit Pai but have yet to
receive any response to my queries. I have also sent a query to Commissioner
O’Rielly because my concerns appear topical in light of his blog post,
“Consider a New Way to Combat Pirate Stations.”
a broadcast engineer, I understand the impact of pirate stations, having
recently discovered one interfering with the first lower adjacent of a licensed
station with which I’m associated.
hope is that any change in spectrum enforcement doesn’t turn the radio dial
into the Wild West, making every Part 15 radio enthusiast or campus-limited
signal a potential target for unjustified legal actions simply because it rubs
some licensed station the wrong way.
Bill DeFelice is former chief engineer of
WMMM(AM)/WCFS(AM) in Westport, Conn., and webmaster of the History of Westport
Connecticut Radio. His Part 15 website is