Docket 20777 and Johnny Johnston: interesting comment pops up on QRZ.com

[Tom WA3KLR]

Guys,

You can’t just selectively ignore some frequency components of a transmitted signal at the transmitter!  You can do this at the receiver of course if you wish.  With an AM transmission, the carrier is there and if the carrier out is 375 watts, the PEP signal is at least this amount.   With modulation, on AM, the total power rises above this.  No amateur math tricks will get you past professional engineers at the FCC.   The PEP rule is total power independent of bandwidth, not sideband energy only, for all modes.

The output rule is based for interference purposes, it isn’t that “they” don’t want to keep you from communicating afar. (There is no limit on ERP!) If “they” did, you wouldn’t have the Amateur License privilege.   On the low bands, the bandwidth is relatively low and regardless of the mode, any mode, the signal is allowed to dwell at 1500 Watts maximum.  Even with voice AM we are talking about dwelling at 1500 Watts for a few milliseconds.  Appliances that are sensitive to r.f. will see this.  There is no trick or averaging here; the appliance’s electronics have wide bandwidth.

Obviously it is difficult for many to grasp the properties of time-varying transmitted modulated r.f. signals, but let’s not be silly about AM and PEP theory.

TOM

[K3ZS]

Maybe Tim's definition of AM PEP would serve us better, the FCC doesn't agree with this definition.    The total of the carrier and the peak power of both sidebands is what the FCC defines it as.

[Tom WA3KLR]

The definition is Mother Nature's definition not the FCC's.  This is called Physics.

[K3ZS]

For once the FCC agrees with Mother nature and physics, unlike things such as BPL propagation or the range of DTV transmissions.

[Opcom]

so what do you guys do when you have a 1KW carrier AM BC rig and need to carve the power down a bit? Reduce operating volts? Reduce drive?

[Ralph W3GL]

YOU KEY UP THE CARRIER FULL BLAST AND SPEAK SOFTLY!

[k4kyv]

Guys,

You can’t just selectively ignore some frequency components of a transmitted signal at the transmitter!  You can do this at the receiver of course if you wish.  With an AM transmission, the carrier is there and if the carrier out is 375 watts, the PEP signal is at least this amount.   With modulation, on AM, the total power rises above this.  No amateur math tricks will get you past professional engineers at the FCC.   The PEP rule is total power independent of bandwidth, not sideband energy only, for all modes.

But that whole idea is based on the long-debunked premise that the amplitude of a modulated carrier is actually varying up and down in step with the audio.  The ARRL handbook and slopbucket promoters of every ilk have long pounded into our heads that this is a false premise, a theory that was dismissed in the 1920's.  The carrier is steady, unvarying, and any additional power resulting from the modulation is contained in sidebands, independent of the carrier.  This is clearly displayed on the scope of a spectrum analyser.

The output rule is based for interference purposes, it isn’t that “they” don’t want to keep you from communicating afar. (There is no limit on ERP!) If “they” did, you wouldn’t have the Amateur License privilege.   On the low bands, the bandwidth is relatively low and regardless of the mode, any mode, the signal is allowed to dwell at 1500 Watts maximum.  Even with voice AM we are talking about dwelling at 1500 Watts for a few milliseconds.  Appliances that are sensitive to r.f. will see this.  There is no trick or averaging here; the appliance’s electronics have wide bandwidth.

It is the average, or mean power that determines the loudness and thus the interference-producing potential of a signal, not the amplitude of occasional voice peaks.  If you work a transmitter into a light bulb dummy load, it is the average power that determines the brilliance of the bulb, not the instantaneous peak power.  That same average power that lights up the bulb determines how loud a signal is at the receiving end and how much interference it causes.  With voice modulation the maximum p.e.p. occurs only infrequently and even then dwells only for a few milliseconds at most. Thus, it contributes little, if any at all, to the interference generated by the signal.

The only useful purpose of p.e.p. is for determining the maximum undistorted output capability of an amplifier.  When the amplifier reaches saturation point, whether it be 100% duty cycle or only for a nanosecond, it has run out of headroom, and there can be no further increase in output power.  If you try to exceed the headroom limit of the amplifier, distortion and thus spurious products outside the normal bandwidth of the signal will result.  The concept of p.e.p. was created to define the saturation point, or headroom limit, of an analogue system.  It has nothing to do with the effective quantity of power.  The concept caught on in amateur radio circles in the 1950's because it allowed the manufacturers to inflate the power ratings of their factory-built slopbucket leen-yars when they ran their ads. 

Actually, the 2:1 ratio of peak-to-average power (remember the "2 kw" slopbucket leen-yars?) was based on two-tone test modulation.  With the human voice, it is more like 8-10:1.  An undistorted slopbucket signal running 1500 watts pep will typically run 150-200 watts average output power.  The way the slopbucketeers who actually bother to observe the 1500 watt limit jack up their output power, is by driving the leen-yar well past its headroom capability and into saturation with resultant splatter (as evidenced any time you tune across the phone bands), or else by using heavy "speech processing" that may contain the bandwidth, but result in a nasty, irritating, distorted signal that is painful to listen to.  So the pep power limit penalised SSB stations running clean undistorted signals as much as it (allegedly) did for AM.

And, regarding those "wide bandwidth' appliances, they are not supposed to receive radio signals, period, at any power level.  If they do, it is due to some kind of malfunction of the appliance itself, not the fault of the radio signal.  There is no justification in reducing the power of a licensed radio service because of the shortcomings built into devices that were never intended to be radio receivers in the first place.  Look at the  label on any Part 15 device: "(1) This device may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation."

The PEP rule is total power independent of bandwidth, not sideband energy only, for all modes... Obviously it is difficult for many to grasp the properties of time-varying transmitted modulated r.f. signals, but let’s not be silly about AM and PEP theory.

I would venture to say that fewer than 50% of to-day's licensed hams could even explain what pep is, beyond "what the meter kicks up to when I talk".  Try putting enough selectivity in front of your pep meter to allow it to discriminate between the sidebands and the steady, unvarying carrier, and as you tune across the passband of the signal you will get exactly the same readings as displayed on the spectrum analyser as it reads the actual power output from the transmitter. 

If you are running 1000 watts of steady carrier output, and modulate that carrier with 500 watts of (instantaneous peak) sideband power to achieve 100% modulation, where does all that total power, in excess of 1500 watts, come from? 

It is pure fiction, "phantom" power that shows up only because of limitations inherent to the measuring instrument.

[Tom WA3KLR]

For those who are interested, here is a thread from 4 ½ years ago in which Don is on the same soapbox:

http://amfone.net/Amforum/index.php?topic=3615.0

Don, I wonder if you ever did contact Johnny Johnston as I recommended then or are you going to continue to complain about him behind his back how he screwed us over until you are gone?  I’m not a Johnny Johnston fan, nor do I know him, but I do find it hard to believe that he was able to act autonomously in the FCC.

You never mention that the 1500 Watt PEP rule affected all of ham radio and that CW gained, SSB gained a hair, and the VHF and microwave people gained a great deal of output power in the 1500 Watt PEP output rule change.

There is no limit on Effective Radiated Power (yet).

I said “You can’t just selectively ignore some frequency components of a transmitted signal at the transmitter!  You can do this at the receiver of course if you wish.  With an AM transmission, the carrier is there and if the carrier out is 375 watts, the PEP signal is at least this amount.   With modulation, on AM, the total power rises above this.  No amateur math tricks will get you past professional engineers at the FCC.   The PEP rule is total power independent of bandwidth, not sideband energy only, for all modes.”  This is all true Don.

PEP is solely a voltage versus time measurement.  There is no distinction of the frequency sub-components.  The net voltage seen at the output of the rf transmitter is the sum of all of the rf and modulation functions together in one net time-varying voltage function.  (For every mode the PEP level, the average or mean power, the frequency components, the properties of the components are different   This is why they are classified as different modes!)
 
Quote from Don ”But that whole idea is based on the long-debunked premise that the amplitude of a modulated carrier is actually varying up and down in step with the audio.  The ARRL handbook and slopbucket promoters of every ilk have long pounded into our heads that this is a false premise, a theory that was dismissed in the 1920's.  The carrier is steady, unvarying, and any additional power resulting from the modulation is contained in sidebands, independent of the carrier.  This is clearly displayed on the scope of a spectrum analyser.”

Here you go off on an erroneous tangent as usual.  I never said anything about a varying carrier did I.

Don said “It is the average, or mean power that determines the loudness and thus the interference-producing potential of a signal, not the amplitude of occasional voice peaks.  If you work a transmitter into a light bulb dummy load, it is the average power that determines the brilliance of the bulb, not the instantaneous peak power.  That same average power that lights up the bulb determines how loud a signal is at the receiving end and how much interference it causes.  With voice modulation the maximum p.e.p. occurs only infrequently and even then dwells only for a few milliseconds at most. Thus, it contributes little, if any at all, to the interference generated by the signal.”

This is full of errors, I won’t even address them all.  Mean power transmitted has very little to do with loudness at the receiver.   Today the rest of us use good receivers with AGC and so the loudness is dependence on the modulation characteristics not the mean power received.  You keep bringing mean power into every argument of yours.  I assume that you feel that we can gain an edge in the old AM power argument by “using” mean power. 

In the old thread http://amfone.net/Amforum/index.php?topic=3615.0
I mentioned that the range of the mean power of the 1500 Watt PEP SSB signal is below or above the present AM legal limit signal, highly dependent on the speech processing of the SSB audio.  The AM signal, due to the high percentage of the carrier power, is pretty well boxed in on its mean power.

You keep saying that interference is based on mean power, but you never provide proof of this.  First of all, we must go back to the word interference.  I said that the FCC rules are based on limiting interference.  Interference is a broad term.  Interference can be to Amateur radio from other Amateurs, Amateur transmissions interfering with non-ham radio equipment, Amateur transmissions interfering with non-radio equipment and we know that non-radio appliances cause interference to Amateur radio reception.  But here we are referring to the power of r.f. transmitter output. 

One interference I have gotten from AM’ers is the sidebands of sibilant energy 16 kHz away from the carrier of a wide AM transmission.  This energy at 13 to 16 kHz away from the carrier is completely unnecessary and was about 10 dB below the carrier signal level when it occurred.  It definitely was quite an interference to reception by almost everyone on our net.  By mean power measurement, there would be little power there but the interference was quite significant, proving that this interference is not solely based on mean power but in this case is based on short-term energy only and its relative frequency placement.

Interference can be possibly due to mean power or can be due to the envelope voltage peak, not just restricted to the mean power of a transmission as Ed Hare ARRL RFI chief mentioned the thread 
http://amfone.net/Amforum/index.php?topic=3615.0 . 

Don you have never stated what time constant is to be used in your AM versus other modes mean power comparisons.  What is your time constant number? 5 milliseconds, 50 milliseconds, 500 milliseconds, 5 seconds, 50 seconds (to allow for the non-speaking periods to fudge the mean power number down further)?

The SSB signal is in the same boat as AM in regards to your view of disparity between the Peak Envelope Power and the mean power.  This is just basic physics of the signals and every mode has different PEP to mean power ratio.  I venture to say that virtually no one in Amateur radio has a true mean power meter.  No one in their right mind uses a spectrum analyzer to accurately measure actual transmitter power levels either.

Since the SSB signal has no carrier, the PEP to mean power level varies even more widely than it does for AM.  Why don’t we hear any bellyaching at all for the SSBers Don about output power?  Their maximum mean power level is typically the same as the legal limit AM signal.

Don, to settle this matter of the apparently unjustly underpowered AM power limit what would you do?  Would you have everyone get a “mean power” meter?  What is the mean power level number you would declare as the legal limit?   What is the time constant implemented in your measurement?  Is the 1500 W PEP SSB signal the reference level?  What would you declare as the mean power level of a 1500 W PEP SSB signal?  Then finally what would the carrier level of this new legal limit AM signal translate to?

Don, if you had the “power” to implement these FCC Amateur output power changes, would it stop your belly-aching?

Seriously Don, I want to see you post power number answers to all of the previous questions I just posed.

[w3jn]

Not to speak for Don, but I think a valid point is made by the fact that there's confusion between the two of you that the old 1 KW measurement method was simple and easily understood whereas the PEP method isn't, particularly with AM.

The old way?  Plate (or collector, or drain) current * B+ <= 1000.  Easy to measure, easy to understand.  ANd lots of classic rigs were built with this standard in mind. 

Then suddenly there's a "benefit", foisted on us for a reason unknown, that's not widely understood and not measurable with existing metering in the rig.  Even now PEP wattmeters aren't universally used amongst the ham population.  And in the process, suddenly classic rigs became illegal and AMers were kinda shafted.    Or so it seems to me.

[k4kyv]

Don, I wonder if you ever did contact Johnny Johnston as I recommended then or are you going to continue to complain about him behind his back how he screwed us over until you are gone?  I’m not a Johnny Johnston fan, nor do I know him, but I do find it hard to believe that he was able to act autonomously in the FCC.

I discussed this and other issues, including Docket 20777 in person with him at several Dayton FCC forums and he never would give a straight answer, but always sidestepped the issue with irrelevant responses.  I also submitted numerous formal comments and reply comments to the FCC while this and other AM-related proceedings were pending, so I am sure he was well aware of my take on the issue.  Various others AM'ers reported approaching him at other FCC forums and at hamfests and received essentially the same brush-off.   Other than off-the-record comments I reported him making at hamfest forums at which I was in attendance, all allegations (limited to his official acts as head of the amateur radio rulemaking division of the FCC) that I ever made concerning Johnston, are for things on public record in official FCC documents.  I have a paper file several inches thick on the subject. Johnston is in his mid 80's now, long retired and no longer connected with the FCC.   What would be the point in trying to resurrect or continue this debate with him now?

You never mention that the 1500 Watt PEP rule affected all of ham radio and that CW gained, SSB gained a hair, and the VHF and microwave people gained a great deal of output power in the 1500 Watt PEP output rule change.

How much did AM gain?

One interference I have gotten from AM’ers is the sidebands of sibilant energy 16 kHz away from the carrier of a wide AM transmission.  This energy at 13 to 16 kHz away from the carrier is completely unnecessary and was about 10 dB below the carrier signal level when it occurred.  It definitely was quite an interference to reception by almost everyone on our net.  By mean power measurement, there would be little power there but the interference was quite significant, proving that this interference is not solely based on mean power but in this case is based on short-term energy only and its relative frequency placement.

That interference was due to the spectrum distribution of the sideband energy in the signal, either due to the audio bandwidth of the signal modulating the carrier, or due to spurious distortion products from the transmitter.  If the carrier could have turned off without affecting the sideband spectrum (perhaps by turning off the DC plate voltage to a plate-modulated upside-down tube final), you would have noticed no difference whatever in the sibilant energy causing interference 13 to 16 kHz away from the carrier (or suppressed carrier) frequency.  Yet without the carrier, the p.e.p. would have been drastically reduced.

Don you have never stated what time constant is to be used in your AM versus other modes mean power comparisons.  What is your time constant number? 5 milliseconds, 50 milliseconds, 500 milliseconds, 5 seconds, 50 seconds (to allow for the non-speaking periods to fudge the mean power number down further)?

For AM and SSB power measurement using voice modulation, I would suggest a time constant identical to that of the standard VU meter used in audio work. A VU meter is designed to have a relatively slow response. It is driven from a full-wave averaging circuit defined to reach 99% full-scale deflection in 300ms and overshoot not less than 1% and not more than 1.5%. Since a VU meter is optimised for perceived loudness it is not a good indicator of peak performance.

Since the SSB signal has no carrier, the PEP to mean power level varies even more widely than it does for AM.  Why don’t we hear any bellyaching at all for the SSBers Don about output power?

. 
They didn't get a "power reduction" imposed on them that purported to reduce the historic power privilege they had enjoyed ever since the mode came into existence, or that may have rendered some of their equipment obsolete.  Besides, I wonder what percentage of the QRO SSB crowd, particularly contesters and DX'ers, bothers to strictly comply with the power limit, even if they had the means to accurately measure it.  As I said before, I would wager that fewer than 50% of the present-day amateur licensees with HF privileges could explain what p.e.p. is, beyond "that's what my meter kicks up to when I talk".

Don, to settle this matter of the apparently unjustly underpowered AM power limit what would you do?  Would you have everyone get a “mean power” meter?  What is the mean power level number you would declare as the legal limit?   What is the time constant implemented in your measurement?  Is the 1500 W PEP SSB signal the reference level?  What would you declare as the mean power level of a 1500 W PEP SSB signal?  Then finally what would the carrier level of this new legal limit AM signal translate to?

I would set the power limit back to what it was before, using average rf output, instead of DC input.  For AM, CW, FM and other full carrier modes, that would be 750 watts carrier power.  For SSB and other suppressed carrier modes, I would set it at 750 watts average (mean) power output, using a meter designed to reach 99% full-scale deflection in 300ms and overshoot not less than 1% and not more than 1.5%.

But now that modes like CW, FM and RTTY gained a 100% power increase with the p.e.p. BS, to avoid taking back privileges previously granted and to still maintain a level playing field, perhaps those figures should be doubled.

It didn't take rocket science for the Canadians to come up with an equitable output power limit:

The holder of an Amateur Radio Operator Certificate with Basic and Advanced Qualifications is limited to a maximum transmitting power of:

    * (a) where expressed as direct-current input power, 1,000 W to the anode or collector circuit of the transmitter stage that supplies radio frequency energy to the antenna; or
    * (b) where expressed as radio frequency output power measured across an impedance-matched load,
          o (i) 2,250 W peak envelope power for transmitters that produce any type of single sideband emission, or
          o (ii) 750 W carrier power for transmitters that produce any other type of emission.

Scroll down to paragraph 10: Restrictions on Capacity and Power Output

[ka3zlr]

And after digesting all this once again, and knowing Don has experienced that I know of no dealings with the Crown and with his well produced signals I monitored many times...I Kinda Think The Fella Knows what he's doing...and I still support Timmys statement for Change...it should be drafted and sent in concert with Dons Writings to the Crown(FCC) and pushed for change....and soon.

73
Jack.

[Tom WA3KLR]

Don,

Thanks for your answers on Johnny,  I guess at this point we’ll never get the true inside story.

You have abandoned the mean power path apparently and now stand for “return to old rule” for the AM power level.  This would match the Canadian AM level.  The Canadian rule appears to have a 1.25 dB “grace” margin for AM PEP versus SSB PEP.  Applying this 1.25 dB or 1.3333 X margin to our 1500 W PEP rule would yield a 500 Watt carrier output level for us.

Again I consider this a silly argument (“another country does this”) and not based on any technical merit. But you are free to propose this to the FCC.  If they pass it, it would be a only a “nicety” on their part.  But this would be 500 W carrier out, not 750 W carrier out.  So you have 2 goal options here.

A few milliseconds is a long time in electronics, and I still believe that any professional engineer at the FCC is going to stick with 1500 W PEP output for all modes as an equitable rule.  Good luck OM.

[k4kyv]

You have abandoned the mean power path apparently and now stand for “return to old rule” for the AM power level.  This would match the Canadian AM level.  The Canadian rule appears to have a 1.25 dB “grace” margin for AM PEP versus SSB PEP.  Applying this 1.25 dB or 1.3333 X margin to our 1500 W PEP rule would yield a 500 Watt carrier output level for us.

Returning to the old rule, but expressing power levels in terms of rf output power instead of DC input to the final, essentially means defining output power in terms of mean power rather than peak power. 750 watts of mean power output without consideration of the p.e.p. would actually be a big increase for SSB over the present rule.  It would be a slight decrease for AM, since the hypothetical unmodulated carrier power would be 750 watts, so to be precise, the AM carrier power would have to be reduced slightly to keep the mean power of a modulated signal under 750 watts.  So maybe to better preserve the original AM power level, AM power should be defined in  terms of carrier output, just like AM broadcast stations.  Why hasn't the FCC redefined AM broadcast output power so that WLS, WSM, WOR and WBZ could say they are running 200 kilowatts instead of 50 kw?  It seems that the Canadians took a simple approach that works, without reducing anyone's privileges or unnecessarily complicating anything.  750 watts carrier output would essentially have left the old power limit intact.

Years before the 1983/1990 rulings, ever since Johnston had taken over the helm as chief of the division or bureau in charge of amateur radio rulemaking in the early 70's, proposals began rolling out of the FCC to use some form of p.e.p. as a power standard.  The first time, in the early 70's, as part of a "restructuring" docket, they proposed p.e.p. output. In that one, the proposed figure was 2000 watts, since that represented "approximately" the maximum allowable output power under then-existing rules, citing that as the maximum power attainable in the case of high level plate modulated AM running 1 kw DC input. Then, in another proposal a few years later, they switched to p.e.p. input as an "interim" standard to use until they could further study and address the power issue in a separate proceeding.

Again I consider this a silly argument (“another country does this”) and not based on any technical merit.

What is silly about it?  The Commission's stated objection to the AM community's comments and petitions was the purported difficulty they would have had in writing a short, simple rule that would cover all modes while maintaining existing power levels for everyone.  This was a recurring theme in numerous responses to petitions and comments.  If the FCC personnel were incapable of figuring out how to do it, but a neighbouring country managed to figure it out simply and eloquently, what is wrong with citing their success and borrowing from their ideas, particularly in light of the FCC's apparent admission that the learning curve was too steep for their personnel?  I'd say the Canadian rule has more technical merit than the U.S. one.

A few milliseconds is a long time in electronics, and I still believe that any professional engineer at the FCC is going to stick with 1500 W PEP output for all modes as an equitable rule.

What professional engineer?  During the power limit proceeding, one of the arguments the FCC used against any form of special provision that would protect the pre-existing AM power level was that since users of AM were such a small minority in the amateur radio community, they couldn't justify the extra expense for training their field inspectors to measure AM to a different standard than SSB. A "professional engineer" would need no "special" training to figure out how to measure the carrier output of an amateur AM transmitter because these principles were well known dating back for decades before this power issue came up, and especially since FCC inspectors routinely verify AM power outputs up to 50 kw at standard broadcast stations.  What a bunch of bogus hogwash!

As far as accurately measuring mean, or average power output, check this:

Bird APM-16

[Tom WA3KLR]

What professional engineer? 

The engineer at the FCC who will have to evaluate your Petition and have a big influence on deciding whether to implement your NPRM (and its resulting costs) or not.  I did not intend for this guy to be the technician that you picture as going on field enforcement calls.

[W3SLK]

Tom said:

The engineer at the FCC who will have to evaluate your Petition and have a big influence on deciding whether to implement your NPRM (and its resulting costs) or not.  I did not intend for this guy to be the technician that you picture as going on field enforcement calls.

Tom, I fear that you view the world through rose colored glasses. I beleive that professional engineers no longer exist at the FeCeCe. I think the organization is inundated with lawyers and business types who attempt to sell frequency segments to the highest bidder and damn the amateur radio weenies!

[Pete, WA2CWA]

Tom said:

The engineer at the FCC who will have to evaluate your Petition and have a big influence on deciding whether to implement your NPRM (and its resulting costs) or not.  I did not intend for this guy to be the technician that you picture as going on field enforcement calls.

Tom, I fear that you view the world through rose colored glasses. I beleive that professional engineers no longer exist at the FeCeCe. I think the organization is inundated with lawyers and business types who attempt to sell frequency segments to the highest bidder and damn the amateur radio weenies!

FCC Office of Engineering and Technology
http://www.fcc.gov/oet/

[Opcom]

Just get one of these and call it done.

[W3SLK]

Pete posted: http://www.fcc.gov/oet/

I do not know Mr.Knapp and never had any dealings with him. This is what I found on a quick Google search. Note: emphasis made by me.

Julius Knapp Named
Chief, FCC Office of Engineering and Technology


Last week Julius Knapp, a career FCC employee was named by the Commission as Chief of OET, succeeding Ed Thomas who left last year. Consistent with recent FCC practice, there was no public announcement and the OET website, as of this posting, shows the position as "vacant". My congratulations to Julie on this well deserved promotion that recognizes his long contribution to public service at FCC and excellence in engineering, technical policy, and management.

Julie served as the Chief of the FCC laboratory from 1992 to 1997 where he was responsible for the FCC’s equipment authorization program. He has held a variety of other positions during his thirty years with the FCC, including heading the Frequency Allocations Branch in the late 1980’s where he was responsible for FCC frequency allocation proceedings for the cellular service, private land mobile services, and mobile satellite services.

He is the winner of the 2001 Eugene C. Bowler Award, presented annually to an outstanding government employee. He has also been the recipient of both the FCC’s Gold and Silver Medals for his outstanding service and commitment to the Commission. Julie received a Bachelor's degree in electrical engineering from the City College of New York in 1974. He is also a member of the Institute of Electronics and Electrical Engineers, Inc. Electromagnetic Compatibility Society and is a Fellow of the Radio Club of America. (Source of background: Part-15.org)

[Tom WA3KLR]

Hi Mike,

I have perceived a lack of "professional" engineers in AMerica for many years now.  The lawyers at the FCC usually have an engineering degree as far as I know, like Knapp.

God forbid an agency of the federal goverment should try to promote commerce.

[k4kyv]

As far as I know, it's been years since any of the commissioners themselves have been anything but lawyers.

Most of the technical standards and rules that cover the various services are formulated in the bureau that governs that particular service.  On regulatory details and technical matters the five commissioners normally defer to the expertise of the bureau personnel (who usually are engineers), and rubber-stamp the decisions as presented.

If Petitions for Reconsideration are submitted by the public in opposition to a rulemaking decision, the same people who formulated the rule are the ones who act on the petition.  Very rarely do the FCC's career civil servants* rule against their own decisions. Bureau personnel get to be judge, jury and executioner in matters such as amateur radio rulemaking.  The full Commission rubber-stamps the bureau's decision, and if the matter is taken up in federal court, the judge can be expected to "defer to the expertise" of the FCC.  With few exceptions, the bureau chief and his assistants are free to act as petty dictators whenever there is public opposition to their decisions.

The Administrative Procedures Act requires the release of a rulemaking docket followed by a comment period, but the rulemakers are under no obligation to pay any attention to the comments received if they choose not to. Usually, the comments do have an impact; a good example is the rejection of the bandwidth proposal in Docket 20777.  But I recall that the comments the FCC received regarding the AM power issue, including those from ARRL, were overwhelmingly in opposition to reducing AM power, and a Commission employee reportedly remarked that the Private Radio Bureau people were "in shock" at the number of comments received on the subject, which outnumbered the comments they received pertaining to the hot-button amateur radio proposal before the Commission at the time, the No-Code Technician licence.

It is usually futile to attempt to seek relief through congressional representatives, since FCC decisions on issues involving amateur radio usually affect only an insignificant minority of the total population, and members of the Senate and House have bigger fish to fry, such as whatever war happens to be going on at the time, the economy, major social issues, the next election, etc.  About the only action they can be expected to take is to forward your letter to the Commission, which is forwarded on to the bureau in charge.  The bureau personnel formulate a response to the member of congress, who then forwards that response to the complaining constituent.  Again, it is the same people who originally formulated the rule who ultimately act on the complaint.

*This is how Johnston described himself while presiding over one of the FCC forums at the time when the power issue was pending.

[N3DRB The Derb]

YOU KEY UP THE CARRIER FULL BLAST AND SPEAK SOFTLY BARK IN THAT MIKE UNTIL THE MUNKY METER SLAMS THAT PEG!

fixed it for you.    You guys like to argue too much. ham radios supposed to b fun. 

[k4kyv]

It not arguing; it is called public education.  A lot of the guys on the air to-day think the power limit was always 1500w p.e.p., totally unaware that it ever was anything else.

Oceania is at war with Eurasia.  Oceania has always been at war with Eurasia.

[Rob K2CU]

Tim,

Unfortunately, the FeeCCee rules on power refer to the PEP supplied to the antenna feedline from your transmitter, and does not exclude the carrier. A rig such as the Johnson Kilowatt or an old 1KW AM broadcast transmitter will easily do 3KW of PEP output. The PEP output is the peak vector sum of the RF voltages coming out of the transmitter, carrier plus any sidebands. But, you know this all already.

Better to promote A3H with SSB AM for 375W in the one sideband (twice the talk power) and 1/2 the receiver bandwidth for a total of 6 dB over DSB AM.

[N3DRB The Derb]

yah I know. I'm glad Don's been carrying the heavy load on this for so long - without people like him we'd have nothing today. I've only been on AM since late 1984 which makes me a short timer at 25 years. I cant imagine waging war against the ignorance for as long as he has.

being a advocate for anything is very tiring at times.

and numbers are your enemy when the people you are trying to go your way see a larger number "for them" than "for us" regardless which side you're on.

i would throw a carrot in there for the slopbuckets - our objective should be to get the 1kw DC rule back for AM. But amer's dont constitute enough of a force by themselves. In politics you must engage the larger group in coalitions that may not care about your specific concerns to advocate for you, but if you make them part and parcel of your concerns by throwing them a bone, they will advocate for themselves on your behalf.

I would increase the SSB power limit to 2500 watts, make it plain that ssb will be measured by a PEP standard, and that the old 1 KW DC input standard saying nothing about pep at all;  would be restored for AM as a package proposal.  As long as you get what you desire, throwing them a bone so they will advocate for you as well as themselves is how you make such a change happen.

less technical, more political, guys. Not one in a hundred hams know or will ever understand (or care) why AM got a raw deal. But they do understand "yeah baby, more power is good!"

[k4kyv]

Unfortunately, the FeeCCee rules on power refer to the PEP supplied to the antenna feedline from your transmitter, and does not exclude the carrier... Better to promote A3H with SSB AM for 375W in the one sideband (twice the talk power) and 1/2 the receiver bandwidth for a total of 6 dB over DSB AM.

I totally disagree. If you are concerned about the PEP output that includes the carrier, it would be far better to reduce the carrier and run most of the power in both sidebands, than to transmit that bogus A3H crap which is nothing more than slopbucket with poor sideband suppression.  If you are going to do that, you might just as well run regular slopbucket and get it over with.

Much better to run 1500 watts double sideband, and transmit just enough pilot carrier to give a synchronous detector something to lock onto.  If you want to spend a tidy sum of money, the Sherwood SE-3 will demodulate DSB with the carrier reduced 15 dB or so, and it will sound identical to full carrier AM, complete with full fidelity and no selective fading.  You could  run the upside-down tube circuit and the listener at the receiver would not be able to tell the moment when you dropped the DC to the final from full carrier to -15 dB or so, except maybe by  looking at the S-meter.

For those who don't want to pay the price for an SE-3, there are several software defined synchronous detectors available, that reportedly cost only about $20 or so, if you don't mind having your receiver tethered to a computer.

But still, the FeeCee's definition of  p.e.p.,  §97.3(b)(6): The average power supplied to the antenna transmission line by a transmitter during one RF cycle at the crest of the modulation envelope taken under normal operating  conditions.  How can you have "one RF cycle" of carrier, plus the rf cycles of USB and LSB all at the same time?  This implies the mistaken belief that existed early in the 20th century before the theory of sidebands had been fully explained, that the amplitude of the carrier wave varies up and down in step with the modulation envelope. To make it mean what the FeeCee apparently intended, it would have to read something like the peak vector sum of power supplied to the antenna feedline, including all carrier and sideband components, at the crest of the modulation envelope.

Looking at it from another perspective, why isn't W1AW in violation of the rule when they simulcast on several bands for their information bulletins? Strictly in terms of transmitting power, what's the difference between having a carrier, one each simultaneous USB and LSB that happen to be adjacent to each other in the same band with an unmodulated carrier in between, compared to having three each simultaneous LSB's on 1.8, 3.8 and 7.2 mHz, plus three each simultaneous USB's on 14.2, 21.4 and 28.8 mHz?  Or even simultaneous CQ's from the same station at a Field Day site? Wouldn't the vector sum of all those simultaneous transmissions add up to more than 1500 watts as indicated by a nearby non-selective field strength meter indicating the instantanous peak field strength?

But, alas, maybe someone would say that the unmodulated carrier in between USB and LSB is illegal, so let's call the AM signal an A3H signal with a SSB suppressed carrier signal adjacent to it.