Posted over at my forums - FCC LPAM Petition

I think this is very good....but it's for a licensed class but non business, still hobby?
The llicense should be affordable,and obtainable, or it would defeat the purpose.
At least I see some positive action here with wanting to change something unlike talking for almost two years at how we are asking for this and that and talking about petitions but never is anything done.
It mentions above 1700 but radios don't tune there.


Mark

You might be right TheLegacy, if people were all absorbed in the Yahoo petition. Maybe they could help you now, I'm guessing that more than one petition can be submitted per topic, right?

I feel the license should cost little to nothing, a token as a bow to access for all. The big corporations can get into competitive bidding and spectrum auctions, but the Treasury doesn't need low power community operators' money!

I've had the idea for a while, that the radio band is like a shopping mall, more stores in the mall attract more people to come there, if you have most of the mall empty it seems to be dead.

Community broadcasters would be like small homey stores with more personal, intimate service as compared to the national chains. Stations could be focused and unique.

I look at the Sirius/XM model, with all of the stations tightly defined, a hundred stations for any taste or format you might want to hear at the moment. It's the same with on line radio, people are looking for that choice. By comparison, radio seems boring, fewer choices.

TV did it well, I get 4 times the stations now, compared to what analog had, with over the air digital TV, and I think it's never been better.

If the NAB really doesn't want to see 'competition' on the AM band from small radio stations, I think they're making a grave error and thinking in an old way!

Boomer

I think the grammar errors as I have told Thelagacy many times is a very important part of any petition or submission to the FCC.
It has to look "professional" to be taken seriously.
Even something like saying the "hole" thing instead of the "whole" thing will make the reader not take you seriously. One letter in a word wrong changes the meaning completely, even if you know what is meant.


Mark

Any sort of proposal to the FCC is in reality a sales proposal - you are attempting to convince the FCC to 'buy' your product (i.e., proposal).

Any sales person worth their salt asks themselves - who are the ultimate decision-makers? In this case, the FCC techies, or management?

Then you have to ask - what are the real decision-makers looking for? What are the arguments that could be used to convince them that this is a good idea? These arguments have to be backed up by fact. If you say that the public wants more community-oriented radio stations, then you'd better have the surveys to back that statement up. And you'd also better be able to link this to the FCC's goals and objectives (i.e., the reasons the FCC exists in the first place).

The general format of the document should then be:
1. Executive Overview - tell the FCC what you want, in as succinct a manner as possible, and demonstrate to the FCC why they should want it as well (i.e., how it fits into their mandate). It should be noted that most decision-makers only read this section, skimming the rest, and it should only be several pages in length.
2. Arguments - Expand upon the Executive Overview, providing technical and other justification as required. NOTHING should be introduced here that is not touched upon in #1 (but obviously in much less detail in the overview). It is this section (and the Appendix) that is read by the techies, but, of course, the decision-makers will want their blessing on it. However, the go-no go decision is not made at this level.
3. Summary - Basically say what you just said.
4. Appendix - This is where you put in the bulk of the technical detail (a lot of the existing proposal, unfortunately).

A few rules of thumb.

It is far more difficult to write a little, concisely and effectively, than it is to write a lot. Particularly if you are technical and are most comfortable with technical detail.

The world is full of bulked-up proposals (I call it Baffle Them With B***S*** proposals) that are never read and sit on decision-makers shelves.

If you don't grab the decision-maker's attention within the first few paragraphs, your proposal has little hope of succeeding. That's why the proposal has to be written with decision-maker's objectives in mind. While the proposal is obviously in your interest, it will also help the decision-makers solve their problems (while not introducing new ones).

The road to a successful sale (a YES) is running a gauntlet of potential NO's.  Your proposal has to address everyone's concerns.

So, think like the 'buyer' (i.e., the FCC). Why should I 'buy' this product (proposal)?

The new radio Revolution realizes that there was errors in our petition are rough draft petition that is. Like for example the word ruff as a dog barks.

Some of these errors we did purposely to see if anyone actually read our petition and not just time management read it. This was to try and fix any issues in the proposed petition before submission to the FCC.

Again we do take all of this very seriously and we may still go forward with our petition as we feel that there are more things meant for the hobby Community radio broadcaster in our proposal. I am not against a minimal fee but when I say minimum I mean anything from say 20 to $50 for the license. Otherwise the FCC could say okay you can have a license but it will cost you $100,000 to process your request making it next to impossible for a individual to legally broadcast.

I'm not sure when the Yahoo group was even originally set up but I do think that it was set up after we had already started ours. There were some things that was very similar to ours but then suede dramatically away from our idea. It makes me sort of wonder if this wasn't a plan to do so because of the fact that some people didn't like the way our group was doing it.

Now that this petition is out in the public we should try and get things settled before the FCC makes the decision on the petition which could be detrimental to our hobby at Large. Keep in mind what is been said about a sales pitch how does this help the rest of the radio band including commercial broadcasters?

One Surefire way to sell the FCC is to mention the fact that there is currently pirate radio activity and what they are trying to accomplish when they do pirate some unused frequencies.

Again not all Pirates are bad it's just the fact that well it's not legal and above board.

Selling the FCC the fact that making a licensed affordable for those who are really interested and radio and would like to have some exposure and serve a small community would alleviate some of the problems that is currently plaguing both am and FM radio.

Also the fact that white space devices have been mentioned but has not been clear as to whether or not someone could legally broadcast an FM signal down on 87.7 or 87.9 with a certified white space device. Also keep in mind that there has not been mention of the fact that the user could even choose one of those frequencies which is currently receivable on many radio today.

I realize that we're talking about lpam here so the fact that 1710 killer hurts should have been mentioned as a possible frequency for hobby AM radio broadcasting. However with this in mind there needs to be a proposal with that assuring the FCC that it could alleviate some interference with the larger more powerful license radio stations.

Making a separate service other than part 15 is finally the right step in the direction that should have been noted when anyone made a petition to the FCC. As we have stated plenty of times when talking to the agent that the agent did emphasize that part 15 should be left alone and that anyone proposing a petition should concentrate on proposing a new radio service totally as a separate entity of Part 15.

This is where texting causes a communication gap where as voice communication is more personal and groups can actually carry on a thought trading process.

I have actually created a free phone conference line that could have held 50 people. I do believe that Free Conference HD allows for web access as well. Yet when I had mentioned it it was totally ignored thus much of our thought processes or not easily exchanged.

Yes Yahoo groups did exchange many things through email. Which again was something that David C had mentioned. But again I still think that voice communication would have been a better way of doing it and having regular meetings two update everyone on the process of the petition's success.

I do hope that this does not cause issues for us in the long run as now our group might have to just concentrate on FM and shortwave because too many petitions under the same topic might cause the FCC to just throw out the whole mess and not even consider any of our proposals.

It is better for one huge group to impact the FCC's decision by coming up with a good sell then it is for many individuals to constantly post their version of what they want. Reason for so is that it shows disorganization within the hobby radio broadcasting community as a whole.

This is the very thing that the FCC might well be afraid of in the first place and therefore may disregard any proposals based on that fact alone.

So now is the question what do we do to fix this issue before everything backfires in our faces and something that we don't want to happen could happen?

Now it's time to start a major activist group and get serious and have meetings on a regular basis and communicate by voice not text to come up with a Surefire rebuttal and sell to the FCC.

Druid Hills Radio, if I ever gave the impression that I was pooh-poohing your example of a petition, I deserve a slap to the back of the head.

I think that example and potentially others are great tools. However, one danger is that you may write a new petition to exactly match an example, as opposed to focusing on your ideas.

Actually writing a proposal is just word smithing, difficult enough in itself, but not the most important part of the process. Creating the proposal is the key. That is, you have to come up with your ideas and arguments and general layout and organization before you can sit down and write.

Carl is entirely, 100% correct and accurate, when he talks about assumptions and his 'community' example (I was going to bring the same example up).  It's taken as a given in the original proposal that everyone wants community radio.  It's talked about here all the time.  But what, exactly, is a community?  And what does community radio mean?  How does it differ from existing licensed stations, and provide value both to potential listeners and the FCC?

That original proposal started in by talking about a desired low power AM service with maximum 35 watts and an antenna length.  If I were an FCC decision-maker,I would ask - where did that come from?  It appears to come out of the air, or at the very least from the wishes of the proposal writers.  If they had talked about community radio first, and defined properly what the goals and objectives of it were, then a power limit and/or antenna limit falls entirely out of that.  You require sufficient power and an antenna system to cover your defined 'community' with a reasonable (which again would have to be defined) signal.

And if I were an FCC decision-maker, I'd want to know - exactly who desires community radio?  Obviously, the proposal writers.  But is it really wanted by the public?  Would it be listened to?  How would it affect existing licensed stations?  Plus, how would it affect the FCC and its ability to regulate the airwaves?

Put yourself in the FCC's position.  And start asking questions.  Once you have the answer to those questions, and arguments supporting them, then you can sit down and write a properly formatted and organized proposal.

And once that is done, you can submit it to the FCC.

Even though this is about a petition surrounding low power, hobby type broadcasting, it ain't all about hobby broadcasting.  There are many stakeholders involved, and each has to be carefully considered.

Oh, I have seen some doozies in my day! Frankly, MANY are NOT educated in the grammar and punctuation (let alone SPELLING) of the English language. I see sentences with a plethora of dots, Greater Than signs, Stars...and all unnecessary! I have actually seen (an adult mind you) the word ARE in place of OUR! What school taught that? OK, also we have "there, their and they're" mistakes; a LOT, in many things I read. Run-on sentences, copious exclamation points, unnecessary capitol letters, it goes on and on. 

Please don't be angry with me for pointing this out. I make mistakes too. I am nearly blind. I have to copy/paste everything in Wordpad and blow it up to 20. Some days, I run spellcheck and it works. Just trying to shine a light on the true problem that is rampant in writing. On the Internet, newspapers and in some documents! :-)

Doug