In his reply comments, William C Walker gives the impression that REC is trying to do away with Part 15.
''In addition, REC Networks wish that the Commission should not take into Part 15 AM broadcasters into consideration is foolish. Displacing these legal unlicensed broadcasters is likely to anger many and lead to a greater problem with pirate activity on the FM band. Part 15 AM is an honest outlet for people bitten by the broadcasting bug but don't have the financial means or otherwise to build or buy a licensed radio station. Please do not do anything to take Part 15 AM away from these people or hamper their ability to broadcast.''
Read our comments carefully. We are not wanting to do away with Part 15 AM, if anything we want to improve it. Specifically, we are a signatory on the Radio Ready To Grow petition to increase the power level or field strength of intentional radiators in the 525-1715 kHz band.
What our comments read is that we do not feel that these intentional radiators should be given a primary or equal status over the new LPAM service. The FCC has never defined truly what a part 15 broadcast station is. If the FCC was to even use any of the rules that we have today, then only those who are broadcasting on college campuses would be afforded any protection and most of the folks using Rangemasters from their home will be out of luck.
The only way that the FCC would even consider affording Part 15 AM broadcast stations any protections (of any kind) if it was a radio service licensed or authorized anywhere other than Part 15. TIS stations are a part of the Public Safety Radio Service in Part 90 and therefore are eligible for protection from LPAM. To full power AM stations, TIS is secondary. Now, if Part 15 wants to move to it's own radio service licensed by rule, let's say a part of Part 73, 74 or 95, then it would subject to a lot of restrictions and would open the door for a lot of new applications ("hear your IPod a mile away!", etc.).
Part 15 operations currently fly just under the radar right now. If we want to protect what we have now, we must recognize that Part 15 broadcasting is just an intentional radiator like garage door openers, wi-fi cards and baby monitors. Any attempts to remove Part 15 AM operations would be met with strong resistance from the universities who have a lot more money for attorneys than you and I have.
Therefore, I would not worry about Part 15 AM stations going away any time soon.
