Could this be legal?

I'm not sure what to call this but I had an interesting conversation with a son of a large ranch owner about radio. He thinks this is legal but I wonder if it is.

Here's a huge ranch, roughly 40+ square miles, owned by a family. It is in the middle of nowhere. In fact, the radio dial is blank. The fellow told me his idea: an over the air radio station designed to not radiate beyond the ranch's property. He claims if the coverage area does not exceed the area the ranch covers, it is legal, not requiring a FCC license. His reasoning is akin to closed circuit radio once commonplace on college campuses.

I noted it is not closed circuit, so not the same thing.

I work in radio managing a station but I sure didn't have an answer for him. And I'm not an engineer.

His reasoning is it gets pretty dull out there running cattle, cutting hay and such. He says the ability for the foreman's house to reach workers is a concern (I'd say getting help if somebody working out there would be a bigger deal). He reasoned some music and the ability to get news to ranch hands was something they'd like. As you might suspect, a cell phone is useless out there.

His station would need to cover an area of about 6 by 7 miles.

Those of you who know about such things please chime in. My thinking is illegal but I seem to recall something about covering private land being okay. This is just a big 'spread' if you will.

Technically it would be illegal, but as long as the radiation limits, (24000 / freq in kHz) µV/m at 100 meters past the edge of the property line for a Part 15 college AM station (FM would definitely not be allowed) are not exceeded, I don't see how the FCC could complain.

It would be worth a formal proposal for rule making, not only for his and other ranches, but places like shopping malls. And it would definitely be a test case if he wanted to take the FCC to court if they nailed him. Nobody is going to say that the FCC doesn't have jurisdiction, but the college AM rule could (and should) be extended to other large single properties.

My sense is that the radio spectrum isn't covered in normal private property rights. But then again, we're talking about Texas, and I know how you guys feel about that kind of thing. I get what he's saying, and agree that this idea is more practical that blasting music over loudspeakers. Less annoying for the cattle. But it seems to me the law is pretty clear that if you're using the spectrum, it needs to be registered.

To clarify my earlier post (I'd gone from memory), the FCC rule is as follows. Section b(2) applies at the edge of the campus/property, not at 30 meters past it, as I had stated earlier.

47 CFR §15.221 Operation in the band 525-1705 kHz.

(a) Carrier current systems and transmitters employing a leaky coaxial cable as the radiating antenna may operate in the band 525-1705 kHz provided the field strength levels of the radiated emissions do not exceed 15 uV/m, as measured at a distance of 47,715/(frequency in kHz) meters (equivalent to Lambda/2Pi) from the electric power line or the coaxial cable, respectively. The field strength levels of emissions outside this band shall not exceed the general radiated emission limits in §15.209.

(b) As an alternative to the provisions in paragraph (a) of this section, intentional radiators used for the operation of an AM broadcast station on a college or university campus or on the campus of any other education institution may comply with the following:

(1) On the campus, the field strength of emissions appearing outside of this frequency band shall not exceed the general radiated emission limits shown in §15.209 as measured from the radiating source. There is no limit on the field strength of emissions appearing within this frequency band, except that the provisions of §15.5 continue to comply.

(2) At the perimeter of the campus, the field strength of any emissions, including those within the frequency band 525-1705 kHz, shall not exceed the general radiated emission in §15.209.

(3) The conducted limits specified in §15.207 apply to the radio frequency voltage on the public utility power lines outside of the campus. Due to the large number of radio frequency devices which may be used on the campus, contributing to the conducted emissions, as an alternative to measuring conducted emissions outside of the campus, it is acceptable to demonstrate compliance with this provision by measuring each individual intentional radiator employed in the system at the point where it connects to the AC power lines.

(c) A grant of equipment authorization is not required for intentional radiators operated under the provisions of this section. In lieu thereof, the intentional radiator shall be verified for compliance with the regulations in accordance with subpart J of part 2 of this chapter. This data shall be kept on file at the location of the studio, office or control room associated with the transmitting equipment. In some cases, this may correspond to the location of the transmitting equipment.

(d) For the band 535-1705 kHz, the frequency of operation shall be chosen such that operation is not within the protected field strength contours of licensed AM stations.


The field strength in µV/m shown in §15.209, as specified for the AM band, is 24000 divided by the frequency in kHz as measured from 30 meters away. At 1700 kHz, that's 14.2 µV/m, while at 540 kHz it's 44.4 µV/m.

TheBigA said:

My sense is that the radio spectrum isn't covered in normal private property rights. But then again, we're talking about Texas, and I know how you guys feel about that kind of thing. I get what he's saying, and agree that this idea is more practical that blasting music over loudspeakers. Less annoying for the cattle. But it seems to me the law is pretty clear that if you're using the spectrum, it needs to be registered.

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This sounds like a loophole to me. Why a college campus and not a shopping mall or ranch? All are large properties. As long as no licensed station is interfered with, there shouldn't be a problem. Again, I wouldn't attempt this on FM, no matter if the band is totally dead. He'd probably have to apply for an LPFM.

The campus thing really refers to just that. When you say "campus/property", you can't separate the two. The "Commish" really does mean "educational institution <campus property>"

All that said, the FCC doesn't seem to be in aggressive enforcement mode these days, except maybe for the easy pickings in Florida and New York. If he was to keep the signal within his property lines, or mostly, they might not bother him. I don't think anyone here would put their life on it though, so if your friend does go out and do it, he's pretty much on his own. Under the letter of the law, it isn't allowed... but then, neither is pot, so...

As for "registering" a signal for your private use... forget it. There's nothing in the rules that covers that, so they won't even talk to you about the idea.

Now, if this guy was to hire someone to lash together a bunch of part 15 rigs and spread them around the ranch, that probably could be done within the rules, but it wouldn't be cheap... especially if he wanted the setup to sound halfway decent.

KeithE4 said:

This sounds like a loophole to me. Why a college campus and not a shopping mall or ranch? All are large properties. As long as no licensed station is interfered with, there shouldn't be a problem.

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I think of the Navajo Nation in Window Rock AZ. Technically their reservation isn't even US soil. Yet they applied for and received a license for KTNN-AM.

Not much of a comparison there. KTNN is a 50kW station. If the ranch owner wanted to wade through the application process, and possibly an auction window to get a frequency, he could possibly get a construction permit for a real station, but it would have to be something like 200 watts at minimum... hardly something that would be contained within his ranch. Along with that, he'd get the privilege of maintaining public files, EAS records, ownership filings and paying annual regulatory fees.

He could possibly file as a non-profit, but that wouldn't exempt him from all the regulatory busywork.

His stated goal doesn't seem to fall within the scope of an "educational corporation", so I don't know if he could swing an LPFM... maybe though. Sounds like a lot of effort, just to cure his boredom.

In any case, he is in error in his belief that he's OK if he just throws out enough wattage to cover his ranch. That rule doesn't exist, any more than the "high school football" rule does for daytimers.

We have a drive-in theater up in Hockley, that uses not one but two FM frequencies to carry the audio for each screen. Once they build the third screen, here in the short term, the operators of the drive-in will then use a third FM frequency for the third screen's audio. This theater's audio can be heard outside of the property on two 1st adjacents to actually licensed Houston class C facilities (97-9 & 99-1) as you drive in front of it on 2920, for around an 1/8th of a mile.

Since we have concluded that the ranch application would be illegal, wouldn't this use of the airwaves also be constituted as an illegal transmission on the two utilized frequencies of 98-1 & 98-9 FM?

Grounded Grid said:

Sounds like a lot of effort, just to cure his boredom.

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There has to be a reason why no one else has done it. Maybe that's the reason.

purpledevil said:

We have a drive-in theater up in Hockley, that uses not one but two FM frequencies to carry the audio for each screen. Once they build the third screen, here in the short term, the operators of the drive-in will then use a third FM frequency for the third screen's audio. This theater's audio can be heard outside of the property on two 1st adjacents to actually licensed Houston class C facilities (97-9 & 99-1) as you drive in front of it on 2920, for around an 1/8th of a mile.

Since we have concluded that the ranch application would be illegal, wouldn't this use of the airwaves also be constituted as an illegal transmission on the two utilized frequencies of 98-1 & 98-9 FM?

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If the range of each transmitter is greater than roughly a 20 meter radius, it definitely violates Part 15.

TheBigA said:

There has to be a reason why no one else has done it. Maybe that's the reason.

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I wonder if he could apply for an experimental license under Part 5, with the intent of conducting tests of a low power AM service (that's what some ham operators are doing to research a new band just below 500 kHz). Since this guy is a rancher, not a technical guy, I wonder if he'd be required to hire an engineer to actually run the tests.

Agreed. It's not much of a comparison. You're talking about flea-power to cover a normal drive-in, though Purpledevil's description sounds like they've got some issues there. I own 3 screens worth of drive-in myself, and it's not all that difficult to stay out of the way. It's another thing entirely to cover a 6-mile hunk of property.

Now that I think of it, the antenna required for this project (AM) would probably be cost-prohibitive.

Really... there's no way to compare this project to another one, and you can't point to someone else and say "he's doing it, so I can, too." It can technically be done, and the owner can rationalize it all he wants to, but there will be a risk involved because there is no rule in the book that will allow an unlicensed transmitter to cover the kind of square footage you're talking about here, and there's no cheap/easy way for the owner to do it by the book.

Not trying to rain on anyone's parade here, but the heading of this thread asked if the concept could be legal. Other than the Part-15 idea, I don't see any way it could be.

TheBigA said:

I think of the Navajo Nation in Window Rock AZ. Technically their reservation isn't even US soil. Yet they applied for and received a license for KTNN-AM.

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As far as dealing with the FCC and other Federal agencies are concerned, Indian Reservations are considered part of the United States. The tribes negotiated treaties to that effect (some good, some bad, I know), but the FCC is responsible for regulating communications on the Reservations.

They also have deals with the states that their borders are within, on issues like gambling. I'm not versed on all of the issues between the US and state government and the Tribes, but deals are in place for a good many things.

frankberry said:

Drive-in theatres use "radiating cable" to cover the parking area. They operate at a very low power which meets Part 15 rules.

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That's true on FM? I know there are rules concerning "leaky coax" on AM, but I thought the only FM rule was a field strength of 250 µV/m at 3 meters.

I told him I thought it would be illegal but it is interesting. I suggested he load up an iPod and carry a walkie talkie. I suppose if he was an entity of some educational purpose maybe but that would be sketchy.

I hadn't been to the ranch in years...over 20...and back then it was pretty much desolate. There was a phone in the foreman's truck but they had to drive to a fairly high spot away from the buildings to make a call. They had electric power. TV was whatever was free via c-band satellite and all the TVs got whatever the foreman's house happened to be watching. There was no internet at that time as this was before the personal computers became common. It was a nice escape to get got there but living there would really have gotten to me. They only went to the grocery store once a month, calling in the order and taking a bunch of ice chests when it was ready to pick up. If you ran out of something, you did without until the next trip to town although some groceries could be had at a little store that was actually in the living room of one house, sort of a tiny convenience store with a few hundred dollars in inventory. The guy did construction in town back then but when his Dad could no longer run the ranch he moved his family there and took over. His daughter went to a 2 room school for K-8th and was one of about 15 kids. At 9th grade they went to the nearest high school.

I wonder if a WiFi system(s) around the areas that folks are would work? Then he could run an internet station. He could "feed" the system internet with a satellite service ISP.

KeithE4 said:

This sounds like a loophole to me. Why a college campus and not a shopping mall or ranch? All are large properties. As long as no licensed station is interfered with, there shouldn't be a problem. Again, I wouldn't attempt this on FM, no matter if the band is totally dead. He'd probably have to apply for an LPFM.

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This rule was created in relation for (now old) unlicensed college campus carrier current stations, which utilized campus power lines and the wiring in student housing locations to transmit AM signals relegated only to the campus area.

Trying to use carrier current for an expansive ranch operation, would be a complete waste of time.

On the other hand fee simple does mean fee simple, and the four limitations to fee simple ownership do not seem to be involved in the rancher's proposal.