But isn't that exactly what the FCC already does? Yes it is. So why do we need a set of groups and sub groups running in redundantly beside the FCC? Actually it's worse than that sometimes. IRAC isn't even subordinate to the FCC. In it's own words " Liaison between the IRAC and the FCC is effected by a representative appointed by the Commission to server in that capacity." They have one guy who tells the FCC what they did. Those above mentioned subcommittees includes the following:"The basic function of the Interdepartment Radio Advisory Committee (IRAC) is to assist the Assistant Secretary in assigning frequencies to U.S. Government radio stations and in developing and executing policies, programs, procedures, and technical criteria pertaining to the allocation, management, and use of the spectrum. The IRAC consists of a main committee, 6 subcommittees, and several ad hoc working groups that consider various aspects of spectrum management policy. The IRAC consists of a representative appointed by each of the following member departments and agencies: Agriculture, Air Force, Army, Navy, Coast Guard, Commerce, Energy, FAA, Homeland Security, Interior Dept, Justice Dept, NASA, National Science Foundation, Broadcasting Board of Governors, State Dept, Transportation Dept, Treasury Dept, The U.S. Postal Service and the Dept of Veterans Affairs."
The Emergency Planning Subcommittee (EPS)
The Frequency Assignment Subcommittee (FAS)
The Radio Conference Subcommittee (RCS)
The Space Systems Subcommittee (SPS)
The Spectrum Planning Subcommittee (SPS)
The Technical Subcommittee (TSC)
*Under the FAS are a couple sub-subgroups including the Aeronautical Assignment Group (AAG) and he Military Assignment Group (MAG)
So what does all this mean? I'll give an example: KAFA-FM is authorized for operation at the Colorado Springs Air Force Academy. It is one of a handful of radio stations operated on military bases around the country. Such stations are not authorized by the FCC, but are authorized only by IRAC. they first began broadcasting in 1964 with permission from IRAC, but went silent in the 1980s. They returned to broadcasting in 1989 at 104.5 FM. In 1993 they changed frequency to 104.3 then in 2006 they changed again to 97.7 where they remain today. It operates at 20 watts presently but even earlier this year was in talks with IRAC seeking to increase power to 100 watts. More here and here. The man in charge of the station for over two decades now is Dave West. More here.
I have no objection whatsoever to the existence of KAFA. But I don't even knwo how many other stations are out there like them. There is no list that I know of (and I have looked for one before.) that said, it's a nice little local station run by student volunteers like any college station or other non-com. It's eclectic local and robust. My problem is twofold:
1. Their engineering info is private. All FCC data is on the web in a nice easy to use text format. With KAFA we don't have any info on the ERP, HAAT, or contour. My info is all hearsay. Now I' know they've been very cooperative with local stations, and engineers but that isn't the same standard the rest of us have to live up to.
2. Such stations are only authorized on a non-interference basis. As in... if it causes interference they gotta move. That's not a great way to license, which is why KAFA keeps having to move. KSTY moved to 104.5 so they had to move. 104.3 is short spaced to that so that's not a great place to park either especially with KKFN on that frequency over in Longmont, CO. So as stations creep toward the Colorado Springs metro KAFA is unable to defend it's turf. With a real FCC license thy would. However with power comes responsibility. They'd have obligations for full time operation, among other things.
They would have been a shoe-in for a LP license in that first round. Instead, they persist in a void, as they always have. From afar it's hard to prove that they really exist. The continue on mysteriously like the Yeti or Chupacapbras, existing in their very strange legal gray area known best in a small neighborhood around the USAFA and to a few bureaucrats down at the offices of the NTIA.