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Author Topic: FCC Response To Request From Congressman Green For Waiver On Part 15 Limits  (Read 1197 times)

Offline ChrisSmolinski

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September 1, 2020

The Honorable Mark E. Green
U.S. House of Representatives
533 Cannon House Office Building
Washington, DC 20515

Dear Congressman Green:

Thank you for your letter regarding Part 15 unlicensed devices and their use by houses of
worship during the COVID-19 pandemic. These devices can be useful in providing a way for
churches to continue to connect with congregations during this period of social distancing.
However, one of the fundamental responsibilities that Congress placed on the Commission under
the Communications Act of 1934 is the protection of licensed stations. To this end, the
Commission long ago established carefully calibrated rules regarding the specifications under
which licensed and unlicensed FM stations may operate. For example, when granting
applications for new FM stations or for modifications of existing FM stations, our rules require
that applicants demonstrate that their proposals would not cause harmful interference, and
applications must be supported with detailed engineering information to make this showing.
Additionally, our rules provide for public notice of these applications, and afford potentially
impacted stations the opportunity to object to these applications if they believe that they will
receive interference.

Because of these requirements, Part 15 devices must stay within the strict confines of our
rules in order to protect licensed stations from harmful interference. A waiver of these
requirements would undermine the Commission's goal of ensuring the integrity of alreadycrowded FM radio spectrum, and would deny existing licensees the opportunities to defend their
costly investments.

I am proud of the work that licensed broadcasters have done during the pandemic. They
have been providing vital information to listeners, while facing an unprecedent challenge from
loss of advertising revenue. Moreover, as the recent tropical storms in the Gulf of Mexico and
the Atlantic have demonstrated, licensed broadcasters provide up-to-the-minute information on
natural disasters and are required to participate in the Emergency Alert System. These services
and many more could be adversely impacted by providing waivers to allow churches to operate
Part 15 devices above the current power limits.

I understand that this makes it more challenging for churches during this difficult time,
but I want to emphasize that there are options available. Churches can contact local broadcast
stations to see if any would be willing to air their weekly services. Indeed, many local stations
partnered with house of worship to broadcast Easter services. Churches also could explore using
multiple Part 15 devices to cover a larger area if they continue to provide "drive-in" style
services. Or churches could look into "call-to-listen" services where congregants would only
need a phone to hear the service. Finally, if congregants have access to broadband at home, there
are multiple, free streaming services that could be used (and have been used across the country).
Please let me know if I can be of any further assistance.

« Last Edit: September 18, 2020, 1138 UTC by ChrisSmolinski »
Chris Smolinski
Westminster, MD
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Offline Rob.

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The last paragraph has a undertone of "it isn't 1990 anymore, there are other (better) ways of reaching your audience".  :)
- Rob

CT/MA border
Email: n1nte.rob@gmail.com
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Offline Radio Station

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The Starlink satellite internet system will make over the air (AM FM TV HF) radio and TV much less important since people will be able get radio and TV to underserved areas around the world. It will be interesting to see in the future how well over the air broadcasts will survive in the long term as more people around the world get connected to the net.

Radio station

Offline JimIO

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