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Messages - tybee

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1
A little late on commenting, but that was a great little story, a very cool utilization of part 15AM.. When I originally read your post, it reminded me of something I had read before, but couldn't remember where or when, but now, found it again..It's about four colleges (Yale, Wesleyan, Hartford, Columbia, and the University of Connecticut) simulcasting licensed FM stations over their own part 15AM stations back in the 1940s:

Radio Craft, April 1942, page 456:
FM GOES TO COLLEGE
According to a recent release from Intercollegiate Broadcasting System, radio's infant prodigy, frequency modulation, has graduated from the realm of things you've heard about from friends with special receivers to things you can actually hear on your own regular set --that is, if you go to college.
The campus broadcasting systems of Yale, Wesleyan, University of Connecticut and Columbia are carrying regular FM broadcasts daily. The Columbia University station has been rebroadcasting programs of WOR's New York frequency modulation station, W71NY, since last November.
Recently Hartford's WDRC FM unit announced that permission to carry all Station W65H's programs has been granted to the Husky Network of the University of Connecticut, the Cardinal Network of Wesleyan University and the Yale Broadcasting System.
All these college radio stations, operating as members of the Intercollegiate Broadcasting System, use extremely low-power transmitters sending signals over their "wired wireless" systems.
This method of broadcasting has two significant results - no receiver outside the prescribed area of the wires can pick up the college station's programs; and, although long-wave and working on amplitude modulation, they are in effect, staticless. ___FREC Service Bulletin.


A decade later the Lincoln Tunnel  rebroadcasted local music stations (possibly FM) over its Leaky Cable AM install in the 50s, and later (70s-80s) were numerous part 15 tunnel cable installs throughout the U.S. which often used rebroadcast (Tunnel Radio). I think Atlantic Records did something similar for one of their Robert Plant promotions in the 80s. (They also had a Leaky Cable install that ran the entire length of Sunset Strip - which I can't seem to find much info about)

There's probably more such examples. Nothing new under the sun.
AM translators for FM stations..  sounds funny don't it?

2
No, this one wasn't the Crystal Cathedral, it was another. I've got a few newspaper clippings and I think with pictures, I'll post it later.

In 1971 the Cinama Radio franchise for drive-ins was formed with exclusive rights to Halsteads leaky cable. Several other companies began offer similar setups for drive-ins.

I need to correct a few things I said about the previous church story.. First off, it took place in Iowa, not Idaho, and it was their Senator, not their Congressman who they contacted...

So... It's the 1970s.. About 40 churches throughout Iowa had been using LPFM transmitters to broadcast their sermons. They had been led to believe no license was needed and apparently had been broadcasting with them for years.
In August 1973 the FCC began shutting them down. The church's, were outraged, thinking that the law had been changed, rallied together and contacted Iowa State Senator Hughes, who then contacted FCC Chairman Dean Burch concerning their matter...

The following is the complete text of FCC Chairman Burch’s response to Senator Hughes in October 1973. The whole thing is quite interesting, but don't miss the FCCs stance that if anyone is to blame for this unfortunate situation, it is the manufacturers and distributors of those FM transmitters, and it's the consumers responsibility to take them to court for misrepresentation --wouldn't that actually be a Federal Trade Commission responsibility?, I don't know, let me shut up, here's the letter:



-------------------'---------

Dear Senator Hughes:

This with reply to your letter of August 31, 1973, concerning the operation of low-power FM transmitters by a number of churches, primarily in Sioux County, lowa.

 The recent action of the Commission’s Engineer in Charge, Kansas City, advising users that their transmitters were being operated in violation of Commission rules, did not reflect a change in Commission policy; rather, it only reflected a delay in detecting and closing down these unauthorized operators.

Our fleld organization had been aware for several years that some churches In lowa were operating low-power carrier current devices in the AM broadcast band, as permitted by part 15 of the rules. These "restricted radiation devices"’ have an effective range of only several hundred feet, and normally rely on institutional wiring to distribute the signal throughout a building or cluster of buildings. Because of their extremely limited interference potential, they are not licensed and regulated as broadcast stations. However, the churches Involved in the recent investigation were found to be operating with conventional FM antennas, and with transmitter power outputs between 3 and 20 watts, thereby providing usable signals up to five miles away. These installations greatly exceeded the part 15 radiation limitations for “unlicensed” operation and, as you will appreciate, would carry an enormous potential for interference to licensed broadcast services if allowed to proliferate on a national basis.

Section 301 of the Communications Act requires that transmitting equipment of this type be licensed by the Commission. Moreover, section 319(a) of the Act requires that, as a condition precedent to licensing, a construction permit be first applied for and obtained. Since these are statutory requirements, they are not subject to waiver by the Commission.

The question thus becomes: on what basis, if any, can these operations be legalized? While considerations of efficient radio spectrum managment milttate against any general scherne of licensing characterized by large numbers of low-power transmitters, provision has been made in the educational portion of the FM broadcast band for 10-watt noncommercial FM frequency assignments.

The problem here is that to establish eligibility, the applicant must be a school college, university, or some other entity with a bona fide educational mission. Although there is no policy against issuing broadcast licenses to religious organizations, relatively few of them have a chartered educational purpose. Therefore, to the extent that they engage in broadcasting, most are licensed on commercial channels.

Any proposal to open the educational portion of the FM broadcast band to churches and religious organizations per se would involve fundamental policy considerations which could be dealt with only in a major rule-making proceeding. Because of the crowded state of the FM broadcast band nationally, the likelihood of favorabie Commission action on any such proposal is somewhat remote. In any event, a final decision on a proposal of this nature could not come in time to meet the ongoing needs outlined in your letter.

With respect to the possibility of commercial FM broadcast operation, there is, of course, no educational eligibility restriction, and it might be possible to organize a consortium of churches or denominations into a licensable entity which could then apply for an FM broadcast construction permit. Commercial FM broadcast licensing is based on a pre-engineered national table of assignments, under which specific channels are reserved for use in particular communities, While most channel assignments in north western lowa are already occupied, there is an unoccuped channel assignment for a Class A FM station at Spencer. Operating with the maximum facilities permitted for stations of this class, a station at that location could be expected to provide primary service within a radius of 15 miles, with a usable service range of up to 40 miles for listeners willing to install outdoor receiving antennas. If necessary, the usable service range might be extended by means of FM translator . stations.

As you know, there are FM broadcast stations presently operating in LeMars, Sholdon, Cherokee, Sioux Center, Spencer, and other communities in north western Iowa, which serve portions of the areas and populations which the unlicensed stations were attempting to serve. Since these licensees are expected to ascertain and meet the needs and interests of the communities served, it is suggested that audience preferences for religious programming be made known to these stations.

I am keenly aware, Senator Hughes, that the termination of these meritorious services might appear, on the surface to be arbitrary and unwarranted. However, in light of the Commission’s statutory obligations, outlined above, there is simply no way of restoring these unauthorized services as formerly constituted.

If fault is to be imputed to anyone, it should be to the manufacturers and distributors of transmitting apparatus known by them to be incapable of meeting the Commission's licensing requirements. If warranted by the seller as legal devices, the buyers of this equipment should certainly pursue their remedies in the local courts.

Please be assured of the Commission's willingness to work with the affected organizations in an effort to find a solution. If it is determined that a single, centrally located FM station Is not feasible or would fail to provide service to what appears to be a widely scattered audience, it may be that program distribution could be accomplished by the delivery of cassettes, or that arrangments could be made through the telephone company for parishioners in given areas to dial a number reserved for the carriage of Sunday sermons.

Should further information be desired please call on me again.

Sincerely,
Dean Burch

3
Right, particularly the "Philco-Phone", heavily marketed for home and business use in 1937. A simplified carrier-current system capable to "a fifth of a mile", easily set up in a couple of minutes. It was a intercom system. - On a side note, that same year Philco built its nine millionth radio set and had manufacturing plants all over the world. Their "Mystery Control" wireless remote the following year was one of the very devices which prompted the creation of Part 15.

Ive not heard about the licensed church station affected by passing traffic story, but sounds interesting.
I recall a story from the early 1970s about a large number of churches in Idaho broadcasting 10watt FM transmitters for years without a license. When the FCC eventually shut them down the churches contacted their congressman, who in turn asked the FCC why this was happening. They actually thought their operations were legal.

Around the same time, but somewhere else, a church built an additional wing on their building with a massively large window facing the parking lot. It was specifically built for people sitting in their cars to see the preacher while listening to the audio provided via part 15AM. There were others, and the Billy Graham Crusades used part15AM also.

But anyway... Before Part 15, carrier-current was already perfectly legal, both before and after the Commuqnications Act of 1934. It was a non-issue in regard to the Act.  It was not considered broadcasting and there were no rules, (so far as I can tell) concerning it, providing it didn't cross state lines.

Although created for wireless devices, induction continued to be the most popular AM method used for the next 25 years.

4
Been meaning to comment further on this...

Brown Universitys unlicensed carrier current station (via multiple phono-oscillators) began in 1936 and with its growth eventually gained national attention in Radio World January 1938 (11 month before Part 15 was even a consideration) and there are numerous other examples of ongoing operations at the time; such as wired hotel/motel entertainment programing and standard intercom systems in homes and businesses, as well as were wired remote controls and burglar alarms.

THE POINT IS; originally, Part 15 was created exclusively because of WIRELESS devices, specifically 3 new products; wireless remote controls, electric eyes (wireless burglar alarms), and wireless phono-oscillators (LPAM transmitters).  The rules were not instigated due to existing wired phono-oscillators and carrier current operations, but it did directly affect its use

5
Amateur Radio / Re: Snotty Hams
« on: November 09, 2022, 1820 UTC »
You shouldnt say Hams are snotty, It's just that you met up with a snotty Ham. People in general can be snotty regardless of their expertise or hobby.

By the way, @Rizla, this may be an ignorant question on my part, but what are "drunk zones of 80m"?

6
As we all know, the Part 15 realm encompasses far more than just intentional AM and FM broadcasting; The most predominant use of part 15 today is undoubtedly Wi-fi broadcasting.. and/or perhaps our cellphones.

I recently, (while trying to track down some 1938 FCC dockets) had a conversation with Michael Marcus, the FCC engineer who was largely responsible for creating the WIFI band. During our conversation he had mentioned that Part 15 was worth more than $90 Billion a year today...

 That stuck in my head, and though that tidbit of info has little to do with my specific research of Part 15 LPAM history, I was curious if that number was accurate (90 Billion is unfathomable number to me - like the number of sand crystals on a beach!) - While I did not really doubt his knowledge, further conformation is found at the NTCA website (which somehow is an acronym of The Internet & Television Association):

"A new report from the Consumer Technology Association (CTA) estimates that Wi-Fi and other unlicensed wireless technologies generate $95.8 billion per year for the American economy in technology sales alone...

..So what is unlicensed spectrum? The term refers to the radio frequencies set up to drive innovation—they are open to any use and by anyone, as long as devices follow certain technical rules. Decades ago, the US was the first country in the world to create unlicensed spectrum and it was one of the best decisions the FCC ever made..."

https://www.ncta.com/whats-new/what-is-unlicensed-spectrum-and-how-does-it-contribute-958b-annually-the-economy

Particularly liked their definition of the part 15 spectrum too (shown above.

7
Part 15 AM and FM Station Operation / Re: Music licensing concerns?
« on: November 02, 2022, 1807 UTC »
..I managed a talk station, but the network i ran used real music as bumpers, i had to pay music licensing.Doesnt matter if youre running talk or rebroadcast someone else, if you are broadcasting real music.. you are supposed to pay.

Something I noticed.. I like listening to the late night Coast to Coast AM program, so I'm also a subscriber so I can download the programs to listen to whenever I want. I noticed that the downloaded versions used to always omit the  copyrighted bumper music.. Well not sure when it changed but now the downloaded versions of the shows DO include the bumper music. I've been curious what changed recently (in the past year or so) to allow for it.

Another thing.. When looking back at the campus stations of the 40s 50s and 60s, I've never found reference to if they had to, or if they did, pay any royalties or not.

8
After an inquiry at https://www.antiqueradios.com/forums/viewtopic.php?f=13&t=419324&p=3583238#p3583238
I've come to realize phono-occilators had actually been around for years, at least since 1935, yet despite it being illegal they wer not causing a problem so evidently the FCC just looked the other way while they were manufactured and sold.


9
You know it's kind of interesting.. The very first part 15 devices ever sold were AM transmitters (phono-occilators), they came on the market sometime around November of1938.. about a month before part 15 was created.

So technically they were illegal. The Part 15 rules allowing for intentional broadcasting were literally created to accommodate the legal use of those tinytransmitters, as well as for the upcoming Philco remote control - which went on the market slmost immediate after Part 15 was inacted, as did also electric garage door openers.

But the original part 15 device was LPAM,

Part 15 in general is a multi-billion dollar industry today (I think 90 billion has been quoted). If it hadn't of been for a little 1938 AM transmitter with a range hardly capable of crossing the room over 80 years ago, we might not have things like wifi, cellphones, remote controls and what have you today.

I still haven't pinpointed exactly who was manufacturing phono-occilators in 1938, but they were on the market.

10
Part 15 AM and FM Station Operation / Re: Music licensing concerns
« on: October 23, 2022, 2050 UTC »
No.. I stand corrected, your right it was the 1990s- thats when Hoitie and them was promoted when nobody knew who they were

11
I seem to recall a multi-followed-up story from the 1990´s about a record company using an AM Part 15 station to promote new artists' releases by a very busy NYC roadway. This was just before the internet took-off. So, since they´ve used Part 15 as a tool themselves, hopefully, they don´t want to rock-the-boat.

You are referring to Atlantic Records part 15 install outside the Holland Tunnel but it was actually during the 1980s.. one of the new unknown artist they broadcast was Hootie and the  Blowfish.. this then unknown group grew in popularity because of those part 15 am broadcast as Atlantic Records pointed our

12
Part 15 AM and FM Station Operation / Re: Music licensing concerns
« on: October 20, 2022, 1938 UTC »
Part 15 rebroacast of licensed stattions isnt something new.. Back in the 1950s they reused the equipment first used on the George Washington Bridge in 1940 and installed a part 15 AM cable in the Lincoln Tunnel in the 1950s ( and again in the 1980s) which, unlike the prior, usually rebroadcasted music from a variety of local stations but had the capability to break in with traffic information when warrented. I presume those rebroadcast did not pay royalties (but there's no documentation to confirm that either way). in fact I've never come across any documentations ( other than at campus stations) specifically concerning part 15 broadcasts paying for music royalties - and its not, and has never been something the FCC concerns itself with anyway.. it's just not of their jurisdiction.

The Tunnel Radio franchise installed many such systems in the decades past but the subject of copyright was apparently never addressed.

In fact its worth noting there's no known circumstance (that Im aware) of a part 15 station ever being cited by  BMI, AMI, ASCAP, or whoever for not paying royalties... so if it's not happened before in the last half century, maybe it never will .

13
I was just reading a 2014 article about the FCC opening up the 600mhz band (part 15) for tv at https://www.fiercewireless.com/tech/fcc-supports-more-unlicensed-use-tv-600-mhz-bands - - I realize its completely off-topic in regard to AM and FM broadcasting, but the article made mention of something I never knew that I found interesting...

"...Commissioner Jessica Rosenworcel pointed out how three decades ago, the commission was looking at what to do for airwaves that were designated for industrial, scientific and medical (ISM) uses. The spectrum once deemed as "garbage bands" ultimately ended up being spectrum where Wi-Fi was born. Today, nearly one-half of all wireless data connections in the U.S. are offloaded onto unlicensed spectrum..."


What struck me is that control of ISM emissions is exactly the primary reason prompting the creation of part 15 in 1938 (it was not as legend has it, because of the invention of the Philco "magic-eye" remote control, although that and phono oscillators entering the market did play a small part in the decision). I also had no clue that wifi arose from utilizing freqiency bands which had prevously always been considered as completely useless for intentional broadcasting.

14
Excerpted from
https://compliancetesting.com/how-much-does-fcc-testing-cost/
Quote

Which Type of Testing Is Right for You?

The total cost of FCC certification depends on the type of FCC testing that you need... ...The most rigorous type of testing is FCC Part 15 Certification. The purpose of this testing is to verify that the electromagnetic interference, or EMI, emitted by your product does not exceed the FCC’s limits....

Average Cost of Testing.. First, keep in mind that the cost of FCC testing depends on several factors, including the type of electronic device you are selling into market and how much work is involved within the testing process. That said, there are a few average estimates that you can use as a guide.

Generally speaking, one can expect to pay anywhere between $3,000 and $5,000 for FCC testing. However, testing for modules & more complex devices can be much costlier. In addition, it is important to take other expenses into consideration, such as the cost of labor. The total cost is also influenced by how extensive the testing process is....


Armchair speculation tells me basically all that's needed for certification with 15.219 is the 100mw input at the final stage and a confirmation its not emiting spuriuos waves. What justifies a thousands of dollar price tag for that?

15
Yes.  Getting a transmitter tested for FCC approval can run into the 5 figure category.

+-RH

I didn't realize a multimeter and a measuring tape could cost so much

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