Tag Archives: Chris Rumbaugh

High-Frequency Parties asks FCC to question proposed Chicago DRM broadcaster’s true mission

Many thanks to SWLing Post contributor, Bennett Kobb, who shares an FCC Informal Objection he drafted and filed together with Kim Elliott and Christopher Rumbaugh.

Click here to download the Informal Objection. (PDF)

Radio World published a great summary of the filing today:

There’s a plan in the works to build a new international shortwave radio station in Illinois, one that would use the Digital Radio Mondiale modulation system. But now several prominent members of the U.S. shortwave community are asking the Federal Communications Commission to take a closer look first.

Parable Broadcasting Co. in April asked the FCC to allow it to build the station in Batavia, Ill., west of Chicago, using the call sign WPBC. It wants to offer “broadcasting and data services.”

Specifically, Parable wrote that the station would “serve the areas of Europe that may be authorized by the commission. The planned broadcast content includes religious and educational programming, as well as data content provided by third parties.” It added that it wants to “take advantage of the recent push by the National Association of Shortwave Broadcasters to develop and provide content for the growing DRM market.”

Now three individuals, collectively called the High-Frequency Parties, filed an informal objection. It’s that wording about data content that concerns them.

Bennett Z. Kobb, Kim Andrew Elliott and Christopher D. Rumbaugh said international broadcast stations in the U.S. are intended “to be received directly by the general public in foreign countries.”

Now they told the FCC that it is impossible to tell from the Parable application whether all of the data services and data provided by third parties will qualify. [Continue reading at Radio World…]

Bennett clarified with me:

The [FCC] rules require these [broadcasters] to be 100% broadcast stations, not a cover for some other kind of service.

Because there is no established radio service for international shortwave trading, some have used the workaround of calling them “experiments”. Quite a few such “experimental” stations have been licensed, some at rather high power levels.

See for example this article.

But legally, the Experimental Radio Service is supposed to be for temporary scientific purposes, not ongoing for-profit operations. We don’t know what those stations are really up to because the FCC has kept the details secret. All we know is some technical data such as callsigns, frequencies, QTH.

Instead of experimental stations, others wanting to get into the data business — including the Turms Tech station in New Jersey, and this Parable station in Batavia IL — seem to be using the work-around of the International Broadcast service. That is, proposing an audio programming station that uses the DRM data channel for trading messages.

We are not in the 1970s or 80s. There’s not enough money today in broadcasting audio to other countries, to justify the millions spent on real estate, engineering, antennas and transmitter plant. Most SW broadcasting around the world is not commercial. So it is very peculiar for new entrants to drop major bucks in this field.

The new guys are probably not getting in to spread the gospel. That is a surface paint. There are already several U.S. HF stations with religious content, as you know, including WTWW, WWCR, WRMI, WRNO, WINB, WWRB, WHRI, WBCQ, WJHR etc. and most would welcome new customers for airtime.

No need to construct new stations.

So what is this new station really? Get it out in the open and ask them how they intend to comply with the existing rules. If they are in the business of carrying secure messages for traders, that does not qualify and will need some special FCC action to allow it. Let the public see the reasoning.

The rules that exist are very old. We think FCC needs to do a top-to-bottom review of the HF broadcast rules and scrap a lot of it. FCC should permit stations to be built for U.S. domestic audiences, and they should reduce the minimum AM power (50 kW) to lower this barrier to
entry.

And they should perhaps consider how data communications could be formally authorized. Maybe it wouldn’t be just a broadcast service any more, it could be a HF Communications Service with the old restrictions on languages and advertising discarded and more opportunities for people to try out creative ideas.

So we’re pressing the issue that this needs to be examined. Thanks for reading.

Thank you for sharing this, Bennett! We hope your filing gets its due attention. I also agree on one of your final points, that the FCC lower its 50 kw AM power requirement of a shortwave station as it places a huge barrier in front of would-be shortwave broadcasters.

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FCC Audio Programming Inquiry: Implications for HF Broadcasting

Many thanks to Bennett Z. Kobb, Kim Andrew Elliott, and Christopher Rumbaugh for authoring “Comments of the High Frequency Parties” that is now filed with the FCC.

Update: please also check out this FAQ.

Here’s the introduction:

The Public Notice in MB Docket 18-227 requests comment on “whether laws, regulations,
regulatory practices or demonstrated marketplace practices pose a barrier to competitive
entry into the marketplace for the delivery of audio programming … [and] concerning the
extent to which any such laws, regulations or marketplace practices affect entry barriers for
entrepreneurs and other small businesses in the marketplace for the delivery of audio
programming.”

The Commission’s Rules do pose barriers to entry and unnecessarily restrict the licensing
and delivery of programming by International Broadcast Stations.

These rules originated in a period when the government utilized or countenanced privately owned, high-frequency (HF, 3-30 MHz) broadcasters as voices against foreign adversaries.
The rules prohibit stations directed primarily to U.S. audiences. They impose detailed
language, announcement, advertising and record keeping practices, require monitoring of
foreign market particulars, and mandate a minimum DSB transmission power level that is
excessive for domestic service and textual and image content.

These and certain other obsolete restrictions are overdue for review and revision or deletion.[…]

Click here to download and read the full document as a PDF.

Click here to check out the FAQ regarding the HF Broadcasting Filing.

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Dear BBG: Take note of the Radiogram!

VOARadiogramImagesMany thanks to my friends, Bennett Kobb (AK4AV) and Christopher Rumbaugh (K6FIB) who wrote a letter to the BBG regarding the relevancy of shortwave radio. They make a strong point as this article in Radio World puts it: “Hey, don’t forget about Radiogram!

I also made a case for the VOA Radiogram in my letter to the BBG, but I think Benn and Chris sum it up better. Click here to download their letter to the BBG as a PDF document–I’ve also pasted it below:

Response to BBG Shortwave Committee Request for Comment

March 14, 2014

The BBG has spearheaded ‘Radiogram’ (voaradiogram.net), an entirely novel form of international high-frequency broadcasting. Radiogram is soundly premised on modern digital techniques and mitigates longstanding impediments to HF transmission. Users around the world have documented reception of fifty VOA Radiogram programs in more than a thousand YouTube videos.

BBG must not allow its own pioneering developments to wither, but should advance them toward operational status.

Radiogram should not be confused with Digital Radio Mondiale (DRM), which employs digital modulation for sound broadcasting. Radiogram broadcasts web content via robust, interference-resistant, error-detecting/correcting AM tone modulation, using standardized formats widely practiced in the Amateur Radio Service.

The user’s ordinary shortwave receiver, tuned to a Radiogram transmission, feeds its audio to a user device. These could include mobile phones, tablets, laptop and desktop computers and the new ARM-based miniature computers and embedded devices. The user device decodes the tones and displays text and imagery despite propagation impairments and intentional interference — and without Internet connection.

Placing the radio near the phone or computer is normally sufficient. No hardwire connection is required. By adding a simple audio cable between receiver and user device, however, reception can be silent and covert. No specialized hardware is needed, and the software platform for decoding is long in the public domain.

A more advanced, yet still inexpensive setup would use existing “dongle” technology that places a software-defined radio (SDR) inside a small USB enclosure. Such units are available today for a few tens of dollars and widely used by experimenters. The operating system and decoding software could also be incorporated into the device, which could boot the computer, eliminating the need to install any PC software.

The user need not be present at the time of transmission to receive content. He essentially receives a web magazine updated at will and always ready for use. The user can redistribute it by printing, USB storage, SMS, E-mail etc.

Naturally, the audio tone transmission can be recorded for later playback. Even when buried well under music or noise, the nearly inaudible recorded broadcast can nevertheless deliver 100% copy upon decode.

Radiogram’s transmission methods provide text at 120 WPM (near to the speed of spoken English) along with images. Additional languages have been proven, including non-Roman alphabets.

Sent over regular broadcast transmitters (no modifications needed), this approach effectively extends the reach of the transmitter. In other words, the digital text mode will decode in locations where the audible speech over the same transmitter would be too low for aural intelligibility. The audio recorded or captured could be replayed over another transmitter to even further extend the reach of the broadcast.

Recommendations

BBG should:

1. Capitalize on Radiogram as a circumvention tool, readily consumable by mobile devices. It should integrate Radiogram into its media strategy and networks.

2. Retain, but reconfigure as necessary its HF facilities in view of the potentially lower costs and greater efficiency of Radiogram when compared to conventional sound broadcasting.

3. Support the development and wide distribution of simple, usable, open-source Radiogram decoding applications for popular mobile devices and platforms (Android, iOS, Windows, Mac, Linux), derived from the free Fldigi software used worldwide.

About the Respondents

Bennett Z. Kobb, M.S., SMIEEE, is the communications director for an Arlington, Virginia trade association.

Christopher Rumbaugh, MLS, is a library manager and web publisher in Salem, Oregon.

The views expressed herein are the authors’ own.

Again, many thanks to Benn and Chris for submitting such an articulate letter to the BBG and for sharing with SWLing Post readers.

If you would like to decode a VOA Radiogram yourself, simply visit VOAradiogram.net for details on broadcasts targeting your part of the world.

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