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Thursday, December 25, 2008

How about pirate radio in the white spaces?

Dec 25 2008 1:07PM | Permalink |Comments (12) |


I will do a longer tirade about white spaces in a few days. For now I want to reprint a letter I got from Stephen Dunifer, a spectrum radical and promoter of free radio. For now, lets think about public interest. Notice that the lower VHF band, the TV channels 2 through 6 are now sort of unloved. The phone and data companies thought they could rip these frequencies from the broadcasters, but then they realized the low frequencies require a large antenna that would make them useless for high-dollar mobile service. It turns out that there is an actual public service proposal on the table. It does not come from any high-dollar multinational corporation. It comes from Stephan Dunifer, a Berkeley radical and proponent of free radio, disparagingly called pirate radio by many people. Stephen wrote me:

I enjoyed reading your article on the FCC. As someone who has had more than his share of experience with the FCC vis-à-vis the Free Radio Movement (aka Pirate Radio), my conclusion is that it is about the money and controlling resources.   During the time the FCC was taking comments on the proposed LPFM [low-power FM radio] service I drafted a proposal on behalf of the Free Radio Movement. This proposal was carried forth by several attorneys with the National Lawyers Guild Committee on Democratic Communications as part of a larger lobbying and comment process. A good deal of what I wrote was ultimately incorporated into the final version of the LPFM service. What was not incorporated was the proposal of extending the FM band into channels 6 and 5 for strictly analog, community/free radio stations. Since the transition to digital was on the horizon it seemed to make logical sense that the public should benefit in some meaningful way from the giving away of $75 billion worth of UHF spectrum to the broadcast industry as mandated in the Telecommunications Act of 1996. Of course, public benefit (need, necessity and convenience - terms the FCC has never really understood the meaning of) is the last thing on the FCC's agenda, if it is to be found there at all.

Given the issues you raised, I believe the allocation of channels 5 and 6 for community/free radio stations should be placed on the agenda. It would not present any real technical problems, just setting a transition period and opening of service date. Receivers entering the US after a certain date would have to be capable of tuning down another 12 MHz or so. To answer the issue of administration, this new allocation would be strictly non-commercial and essentially license free with a maximum power cap. With 60 FM channels to go around, spectrum availability would not be a problem. The paperwork process would be rather simple, a single page form stating location, responsible parties, power level, etc. Submit the form, receive acknowledgement from the FCC and go on the air.

It is good to see that you are analog person as well. I enjoyed your joke about teaching analog to digital folks. Starting next month I will be teaching a series of introductory DIY electronics classes/workshops, mostly analog. For more about my adventures, just plug my name, Stephen Dunifer, or Free Radio Berkeley into your favorite search engine. Our websites are http://www.freeradio.org/ and www.radiotupa.org.

So let’s see if the FCC will take channels 5 and 6 and open it up to free FM radio. I doubt it because there is no money in it, but you never know. I know the technical part of the FCC what I call the old FCC might be all for this proposal. After all, if there was a open slice if spectrum it might keep people from broadcasting on commercial FM bands. And the political part of the FCC, the higher ups, well they are not really as crass, craven, and venal as I make them out to be. I think that they might really care about the people more than big-money spectrum auctions. At least we can hope so. All I know is that it is pretty stupid to keep shutting down radio stations when all the TV bandwidth is now available.

The whole pirate radio issue also highlights something told to me by Dennis Monticelli, a ham radio enthusiast and chief technologist for National Semiconductor’s analog group. I asked Dennis what he thought about the white space proposal and he smiled and said: “The white spaces are really gray.” There are portable microphones and other uses for these frequencies. But Shure must have smaller brown envelopes than Google and Intel, since nobody really cares that Shure was in the white spaces first.


Related entries in: Analog | 


Reader Comments



at 12/25/2008 6:17:38 PM, Michelle A. Eyre said:
I have been involved in the past and continue to support the assignment of 76-88 MHz (TV Channels 5 & 6) to a licensed Low Power FM (LPFM) radio service using existing analog technology and using radios already available in Japan. I do feel that some expansions on the existing license free Part-15 rules that specifically pertain to sound broadcasting in the 76-108 band could be in order. I do not feel that opening up 12 MHz of spectrum for an unlicensed broadcasting free-for-all would be prudent.

I feel that TV Channel 2 (54-60 MHz) should be assigned to the amateur radio service (region 2 only) with the ability to allow up to a 6 MHz wide signal. This will allow ongoing experimentation in long range television (TVDX) transmissions.

Channels 3 and 4 could be used for various short range low power license free applications. However, these channels are still used and should be continued to be used for video navigation devices that require an RF output. We would need to assure that any non-video applications that use this spectrum (60-72 MHz) would be compatible with the operation of navigation devices.

As far as other channels used for "white space", they should be done strictly on a fixed basis only, as a competing service to DSL and cable with spectrum set aside for "freenet" operations. The risk of illegal device usage outside the country is high if these device are allowed to be exported or in any other way allowed to leave the country (such as built into a laptop or other wi-fi device).

The public needs to take back the spectrum as much as they can as long as such acquisition is in the public interest of all and not just a minority of radio enthusiasts. In other words, technology should not be stifled but at the same time, it should not be done at the expense of all of the individuals who could not get access to spectrum because they were not the highest bidder.

Michelle A. Eyre
Founder, REC Networks




at 12/26/2008 6:54:04 PM, jeve said:
I say, let analog TV continue to be broadcase in channels 2 through 6. I my hometown, we were able to pick up channels 4 and 5 seventy miles from the transmitter.

Once people realize how bad DTV is in poor weather, they will be grateful to have analog TV back-especially during spring storm season in the Midwest.




at 12/29/2008 3:59:49 PM, Stephen Dunifer said:
Paul, thank you for printing my letter. In response to Michelle''s comments. First, the FCC does not have the staff to process what would be an avalanche of additional LPFM applications resulting from opening up 12 MHz of additional spectrum. Hundreds of bogus applications filed by mostly religious organizations during the last rounds of LPFM filings nearly choked the entire process. From past experience, the time lapse is at least 2-3 years from the opening of the filing window to the granting of the LPFM permit. A simplified licensing process involving a simpler form filed with the FCC would solve these problems. After all, with 60 channels available, there would be plenty of space for everyone. Retain the fundamental requirements of LPFM - non-commercial, no advertising, etc.

Secondly, bringing up Part 15 confuses the issue. For years, the FCC has raised Part 15 as a cudgel against the Free Radio Movement by saying that unlicensed broadcast stations are violating that regulatory section. Part 15 only applies to intentional and non-intentional radiators - i.e. garage door openers and computers. All regulatory sections begin with a definition of terms. No where in Part 15 do you find the term "broadcast station". Instead, Part 73 is the appropriate regulatory section since that term is defined therein. The issue is not the violation of the extremely low power levels set forth in Part 15, and incorrectly applied in a willfully deceitful manner by the FCC. The issue is whether the broadcast station licensed or not. That is the only legitimate avenue for the FCC to take when bringing legal action against Free Radio stations. Not trying to pull some sort of legal snow job by telling a judge that a station is violating Part 15 by operating at power level of several hundred thousand or more microvolts measured at a distance of 3 meters.

Finally, it must be remembered that is has always been small groups of radio enthusiasts who have engaged in activities that ultimately benefited the public good. Individuals like Chandra Bose, an Indian scientist who actually made the first radio broadcast prior to Marconi and whose work in microwave frequencies was 70 year ahead of its time. Radio amateurs in the early 1900''s created the fundamental technologies which underpin our use of the broadcast spectrum. Licensed amateur radio operators provide emergency communications services when disasters strike. KIND Radio, a Free Radio Station operating in San Marcos, Texas, was an invaluable lifeline for the community in the midst of a 100 year flood. Corporate and entrenched interests have always opposed innovation from below. David Sarnoff of RCA did everything possible to prevent the introduction of FM broacasting, attacking and undermining Edwin Armstrong at every opportunity. Finally, it was small visionary groups of both professional and amateur enthusiasts who gave birth to the computer revolution.

Stephen Dunifer



at 12/29/2008 5:56:07 PM, James Jarvis said:
Might as well let the tower of babble have free rein on the white spaces. The FCC mandated switch to digital will be judged harshly by history, as one of the least intelligent policy decisions by a government body in the last century. The only good thing coming from it is the freeing of space at 700MHz for dedicated public safety communications.

TV is suffering from an overabundance of distribution channels, and corresponding lack of content. Radio, with the notable exception of NPR, has long suffered from DJ-itis, in search of profit. Free Radio can't do any worse.





at 12/30/2008 2:45:27 AM, Joel Wilhite - KD6W said:
I'll admit, the apeal of opening up bandwidth to the less fortunate to operate a free service has a nice ring ; ).
But to be perfectly honest, clearing 12Mhz to allow community FM broadcasting that will only work on a specific receiver doesn't
sound appealing. There is also a minor problem in the Japanese market radio as the step size in the tuning dial is not aligned with the US. I believe this discrepancy cold be corrected with a small ammount of software reprogramming.

If LPFM service began showing up below 88MHz I have to admit I persoanlly won't have a problem receiving FM down there because I have a receiver that can operate that low; I'm a geek, OK? But I already listen to "free radio" on the air (college radio) and the internet. Yes I use radios to communicate but I'm also a short wave listener too. I can think of many more useful purposes of some of that bandwidth albiet along with many other commercial interests too. The ham bands ahve severe lack bandwidth in the 2 meter band (144-148MHz) and so by freeing up channel 2 we could potentially benefit from a new allocation on top of the 6 meter band as M. Eyre suggests and relieve some of our congestion.

As Michelle also points out, channels 2-6 have an interesting habit of propagating when you get the right conditions. For amateur
radio we like, no love this condition. So skip for LPFM is a teeny tiny issue along with the man made noise on those frequencies and one of the reasons why the TV stations are moving out of low VHF. Impulse and burst noise kills DTV reception, but FM overcomes this phenomenom along with a healty dose of power. Oops, now your not low power any more and your skipping into the next county or state.
"Clash of the LPFMs", yikes!

The LPTV and the LPFM have something in common, very little or no money. But both could benefit equally by looking at the problem
a different way. Since both seek a local audience, both could share the spectrum in one DTV channel allocation. A multiplex of voice services can be stacked up in a digital LPTV signal along with other virtual channels. For example, a DTV signal provides a 19.39Mb bitstream and a mono 64Kb AC-3 or MPEG1L2 is FM audio quality. A single LPTV station could carry +250 virtual channels of talk radio and ethnic programming assuming no video.

Add to that I know for a fact, many high power broadcasters throw some of their bit rate away in null packets that could EASILY
carry one or more radio services. Couple that with a considerable amount of power, tower height, antenna gain, engineering staff, etc. home grown radio doesn't make any sense anymore when the governement is already GIVING you money to buy the receiver they live on!

The ham bands occupy several highly coveted chunks of bandwidth that are constantly threatened by others that wish to invent the next new thing. Add to that our societies "need" for wireless or just plain connected lifestyle has slowly but perceptibly raised
the noise floor all over the place and yep, it shows in the ham bands. BPL is one recent example of a technical train wreck. The 6 meter band is right next to channel 2 and so on one hand I'm happy to say BUH-BYE to full power analog TV service so there is no fear of interfering with service on channel 2. On the other hand, who will be new next door neighbor? Please oh please not a bunch of LPFMers.
Joel Wilhite - KD6W (geek)

Jeve - LPTV (analog) will continue service into 2010. After that, Amateur TV (analog) will be left, and thus begins the rise of GeekTV. At least we have a record of being on the air when things get rough.

J.Jarvis - The broadcasters (Flaherty) pointed at the future and asked for the transition. Fortunately, it isn't all bad.

On a seperate note, I'm getting my ducks in a row to campaign for a new 4 meter band allocation for amateur radio in the US right where channel 4 used to be. Our brothers accross the pond are waitng for us to catch up with them. Wish us luck.



at 12/30/2008 3:02:55 AM, Benny Attar said:
Open up spectrum to "free access" and you end up with semi-professionals broadcasting with wobbly antennae and mismatched transmitters and spewing spurious frequencies and powerful harmonics all over the spectrum. Don't let it happen.



at 12/30/2008 8:59:21 AM, Cholo said:
We'd get spurious signals just because they're semi-pro rather than pro's?

Kinda like all the spurious signals from amateur radio operators? /sarcasm



at 12/30/2008 9:22:07 AM, Starman said:
"Radio, with the notable exception of NPR, has long suffered from DJ-itis, in search of profit." I personally oppose NPR using my tax dollars as their "profit" for broadcasting opionions contrary to my belief system. Just another example of pirate radio in the form of government largesse that no longer belongs in the million channel universe.



at 1/3/2009 3:33:10 PM, Paul Sarre VK7BBW said:
Hey, sounds like a great idea in theory. But for those in the "know", the lower tv channel frequencies, as discussed above, will become more susceptible to ionospheric propagation as the new sunspot cycle begins to show it''s ugly head ? Logistically, it would cause not only your FCC immense headaches, re interference complaints, but all over the world. We all know what can happen on 6m when it opens fully, imagine the same, on frequencies even lower.
As the world tuns it''s eyes to the much higher digital TV spectrum, the becoming vacant UHF TV band, would be a much better option for community free to air tv wouldn''t it ?




at 1/5/2009 6:01:26 AM, arclight said:
Setting aside CH 5/6 for "free radio" is unrealistic. Without the promise of commercial broadcasters in the band, mfrs will charge extra for the front-end modifications needed to the receivers (NOTHING is free in the manufacturing world), and the buying public will complain (rightly) that they are being taxed so that a small group of people may be able to broadcast. A probably better approach is to open up CH 5/6 for regular broadcast, and then set aside certain channels for "free radio". If you want to make it interesting, use the opportunity to introduce open-standards-based all-digital transmission in the new spectrum. Set spectral purity and stability limits to preclude cheap, unstabilized junk. The NAB will probably fight this to the last ditch, though.



at 1/5/2009 6:02:13 AM, arclight said:
A better use for Channels 2-6 (and 30-50 MHz, as well) IMO is for the backhaul for an infrastructure-less mobile mesh-network-based commo system for public safety (serving handheld devices operating at UHF or microwave). It's way past time to cut the dependence on "the repeater on the hill" considering how easy it is to disable it either inadvertently or deliberately.

@KD6W: Is the 2M band where you are heavily USED, or heavily ASSIGNED? Here close to Washy DC, every available repeater pair in the 2M and 440 ranges are "spoken for" but most sit idle most of the time. Huge waste of spectrum.

@Starman: Absolutely, particularly when NPR and the Democrat party start swapping contributor lists as they did a few years ago. By the way, Thomas Jefferson agreed with your position a long time ago.





at 1/5/2009 6:03:09 AM, arclight said:
Hate to keep writing, but this site chops my comments into little pieces.

@Dunifer: It's quite OK to not like the FCC, but saying the FCC is willfully misapplying 47 CFR 15 is not accurate. 47 CFR 15 is quite clear that (a) the purpose of Part 15 is to cover devices that are not otherwise licensed under some other part, and (b) the definition of "intentional radiator" covers all devices designed to intentionally radiate RF energy (a low-power broadcasting station is most definitely an "intentional radiator", and if it's not licensed elsewhere, it definitely is covered by Part 15). Again, you may not like it, but that's the way the law reads.


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