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                     THE CGC COMMUNICATOR
                           CGC #782
                   Saturday,  March 3, 2007
                            ________
                Robert F. Gonsett, W6VR, Editor
                     <r.gonsett@ieee.org>
   Copyright 2007, Communications General® Corporation (CGC)
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  SPECIAL EDITION COVERING LETTERS TO THE EDITOR
  AND CORRECTIONS TO CGC #781
  During the past two weeks (February 17 to March 2, 2007),
several Letters to the Editor of the CGC Communicator were
received and some were lengthy.  Most of the letters are
reproduced below even though some violated our 100 word
limit.
  Here is the format we will use this week: First, the
Communicator story being discussed is reproduced, then the
relevant letter/s follow.  Then the cycle is repeated with
another story and more letters.
  Time did not allow us to ask the authors if they would
permit their names to be published, so no names are being
published, but most of the respondents are known to
our office.
  As an aside, there are two corrections to CGC #781.
In the Websites of Interest story, the call sign KXFM should
have read KFXM.  And in the Many Letters Received story, the
pirate in question is located in Goldfield, NV, not Arizona
as stated.
  Now, on with show.  Here are past CGC Communicator stories
followed by our readers' comments:

  STORY FROM CGC #780:
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  NEVADA PIRATE OPERATOR GETS STA
  One Nevada pirate broadcaster has reportedly received a
Special Temporary Authorization (STA) from the FCC to get back
on the air. The Pahrump Valley Times of Nevada reports that
Senate Majority Leader Harry Reid, D-Nev., intervened with the
FCC to allow the unlicensed broadcaster back on the air.  The
pirate's operation was raided and shut down by the FCC last June.
  According to the published account, the pirate can operate
with the STA until he can apply for an LPFM license in a future
filing window.  What a deal.  What a miserable precedent.
  http://tinyurl.com/2oebxl
  http://www.radioworld.com/pages/s.0102/t.1183.html
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  LETTER TO THE EDITOR #1:
  The sound you hear is me using the airsickness bag.  I'm glad
that I got out of the FCC when I did.
  FCC Field Inspector, Retired
-------
  LETTER TO THE EDITOR #2:
  Are you aware of the FCC EVER allowing the violation of their
rules at any time in the past?  I thought that your story was an
early April Fools joke.  Unfortunately, it appears that Senator
Reid wields lots of persuasion with the FCC.  I wonder how far
this can be carried.  For example, might this precedent be applied
to a broadcaster out of compliance with the FCC rules on human
exposure to RF making it okay to violate the rules until the
party responsible gets around to fixing the problem?
  RF Engineer
-------
  LETTER TO THE EDITOR #3:
  Another slap in the face of living by the rules.  It's a real
sham(e) that the FCC is no longer driven by science and the Laws
of Physics.
  RF Engineer
-------
  LETTER TO THE EDITOR #4:
  Regarding the Nevada Pirate being granted an STA by
the Commission, I'm disgusted, maybe even angry.  Decades of
standards and interference controls are being thrown out to
reward those who believe that the "marketplace" is more important
than the law and those who choose to do whatever they please.
  The flood gates have opened.  Welcome to the new age of
Federal Government, where it's perfectly okay to reward those
who choose to disregard the laws of the land.  I tell you,
it's getting worse and worse.
  Broadcast Engineer
-------
  LETTER TO THE EDITOR #5:
  Dear Commissioners,
  I can't believe you succumbed to the complaints of a
politician and are allowing an unlicensed radio station, one
you already "busted," to remain on the air.  What kind of
precedent does this establish?  We've already got judges in
the CA Bay Area who, as I understand it, are allowing illegal
stations to remain running.  Now this.
  Your reasoning, as per the Pahrump Valley Times, was based
on:
  ...Section 309(f) of the Communications Act of 1934, which
authorizes the Commission to grant the temporary allowance in
cases of "extraordinary circumstances requiring temporary
authorizations in the public interest."
  If there were such circumstances, enough to justify a radio
station in Pahrump, it seems to me that someone would have done
it by now.
  Laws were NOT made to be broken. They were made to keep
order. This gentleman seems to have the public interest at
heart; please let him wait until you are accepting applications,
then file, with the ability for others to do the same (or to
oppose the application) via the standard process.
  I think there IS justification for a low-power FM service
in remote areas like this, perhaps using the population and/or
distance to the next nearest radio transmitter or contour as a
guideline (so that the law can't be abused in areas already
with too many signals). But once this gets around, you're
going to be flooded with complaints of similar transmitters,
many, I'll wager, in LESS remote areas, all squatting on the
air so they can get a FREE license, using specious arguments
like "extraordinary circumstances" until such time as you
decide to make them go through the process like most other
potential broadcast licensees....
  Former Broadcast Engineer
-------
  LETTER TO THE EDITOR #6A:
  The Nevada pirate broadcaster in question has been assigned
a call sign, KGFN-LP. If you look up the STA in CDBS (BSTA-
20061206AFZ), there is interesting reading in the correspondence
folder.
   Broadcast Engineer
  Editor's Comment: Use this shortcut URL
<http://tinyurl.com/3dqjhq> to see the CDBS summary of
the KGFN-LP record.  Then, near page bottom, click on "View
Correspondence Folder."  Now you are into the really interesting
part where you will find (among other things) a copy of the FCC
authorization (the STA) allowing the former pirate to operate.
  You will learn that the company president's real name is
Rodney D. Moyes, whereas "Rod Moses" is just an "aka."  You will
also learn that the lack of FAA approval for the previously
constructed tower is no problem whatsoever.  The FCC just wants
the station operator to make an effort to coordinate the tower
in the future.  The only thing missing from the letter is the
sentence, "Is there anything else I can do for you today?"
  -------
  LETTER TO THE EDITOR #6B:
  The FCC rules and a law passed by Congress prohibit former
Pirates from ever getting a license so the FCC action was illegal.
  Broadcast Engineer
  -------
  REPLY TO LETTER #6B:
  That [assumption is] what happens when non-lawyers report
on legal things and get them wrong.
  The statute and the implementing regulations bars those who
were found operating without a license, were warned to cease
operation, and then refused to do so or resumed unlicensed
operation after a period of cessation.
  The warning and refusal or resumption are the key elements.
  The loophole that Senator Harry Reid of Nevada drove a
bulldozer through was that the applicant for whom he strongarmed
an STA did cease operations after warning, and was therefore not
barred from being licensed.
  Broadcast Attorney/Engineer
  -------
  STORY FROM CGC #776:
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  FROM ARNOLD TO ANGELS CAMP TO FOWLER PEAK
  A few Letters to the Editor have been received on the so
called "Arnold pirate" that we have been tracking where a
licensed broadcaster has allegedly built two unauthorized high
power FM stations to extend the programming from his or her
licensed stations into new markets.
  Our speculation in CGC #772 - that two authorized translator
signals in the vicinity of Arnold, CA may have been mistakenly
identified as pirate signals - was apparently incorrect. Two
readers indicate that the pirate stations were built at a site
called Fowler Peak near Angels Camp, CA. Whether this means
Fowler Lookout on Bear Mtn. shown on a USGS topo map is unclear.
  So far, the FCC has been silent on its findings in this
important case....
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  LETTER TO THE EDITOR #7:
  What a fantastic newsletter no matter where you do radio.
I live [near the Fowler pirate stations] and I can tell you that
the...broadcaster who put up the pirate stations is a familiar
scene. I estimate at least 10kW ERP on each station. [The party
responsible for the illegal stations] was promoting them in his
[primary] station's newsletter as new stations. He has been
doing funny facilities for years now and has an arsenal of gear.
Because he operates in this sea of FM Hispanic radio, many
English speaking broadcasters didn't notice. He was stomping
a local (English) and an SF (English) station this time, so
[his illegal stations were] hard to ignore. Maybe [the FCC]
can write him a quick STA [just like the Nevada pirate]?
  Broadcast Engineer
  -------
  STORY FROM CGC #780:
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  COMMENTS WANTED IN L.A. SHERIFF'S PROPOSAL
  On February 2, 2007, the Los Angeles Sheriff's Dept.
(LASD) filed a request for waiver of the Rule that limits the
transmission time of a manually activated garage door opener
control transmitter to no greater than 5 seconds upon release
of the activation switch.... The modified transmitters would
be available only to law enforcement organizations. If anyone
would care to research this proposal to find out what the
Sheriff hopes to accomplish, let us know.
  http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-07-729A1.doc
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  LETTER TO THE EDITOR #8:
  I am going to hazard a guess on the request for the L.A.
Sheriff to modify Part 15 to allow for more than 5 seconds
of transmission.
  Quite a long time ago, some 20+ years or so, a local security
company here in Grand Rapids, MI (Midstate Security) was asked by
several state correctional facilities for something, anything,
that a correctional office could wear, that when he pressed a
button, it would summon help. I had worked for Midstate for
2 years (long, long ago), and we had installed some simple garage
door openers with receivers in critical areas. However, you would
not know exactly where the officer was. After I had left, one of
the security technicians, Sam Nabkey, K8SN, started to install
Doug Hall voters, designed for selecting the better receiver in a
ham repeater operation, and used these voters to decide which of
the garage door receivers had the better (stronger) signal. The
signal is AM, and there were modifications made to the voters and
the receivers.
  Midstate has installed many of these units, buying some 500+
voter boards. A typical prison will have 4 to 12 receivers per
building to be protected, with the receivers spread out along the
floors and different floor levels. With this system, there is a
high probability of knowing where the officer is within a short
distance. You had better believe the officers want this system
to work, and work well.
  My guess is that the Sheriff wants to have mercury/gravity
switches that would trigger the garage door openers in a "person-
down mode." This would account for the greater than 5 second
transmission [that has been requested].
  This is my thought, reading between the lines. There are now
several manufactures of the modified garage door openers for
personal security devices. I have to give credit to those techs
who came up with off-the-shelf equipment, and modified same to
come up with a very effective and reasonably low cost solution.
  Broadcast Engineer
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  OFF TOPIC: TIGHTEN YOUR SEAT BELTS!
  Thank you for being one of our valued readers.  Now, a
little bonus item.  Tighten your seat belts, put up your trays
and hang on!
  This is an exceptionally good Web-video with viewpoints from
both inside and outside the cockpit.  When the video opens (allow
time for a 20MB download), double click on the screen for a full
field of view.  Thanks to Tony Abbott for this gem.
  http://guyrevel.free.fr/WGP/Haute-Voltige_au_Japon.wmv
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  The CGC Communicator is published for broadcast engineering
  professionals in so. California by Communications General®
  Corporation (CGC), consulting radio engineers, Fallbrook, CA.
  Typographical errors originating in FCC material are
  faithfully reproduced.
  Non-commercial Letters to the Editor are always welcome but
  must be kept to 100 carefully chosen words or less. If your
  offering is a story synopsis, include the underlying URL
  (Web address) so our readers can get the whole enchilada.
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  The views expressed in our newsletters do not necessarily
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