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Elections and FCC Rulemaking




 
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Author Topic: Elections and FCC Rulemaking  (Read 7916 times)
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k4kyv
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Don
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« on: January 08, 2005, 02:31:43 PM »

Quote from: Bill, KD0HG
The Republic has survived Clinton and Bush, Newt and Tip O'Neill, Reagan and Roosevelt...
 Not to mention Nixon.
Quote
It's unelected bureaucrats and appointees that have tried to screw things up more than anything

You are correct.  Calling themselves "career civil servants", residing in regulatory agencies such as FCC, EPA, etc, these are the ones who have the real power of government under what is called administrative law.  The theory behind administrative law is that congress lacks the technical expertise to formulate specific regulations in such matters as radio communication, atomic energy and specific environmental issues.  So they set up regulatory agencies of "experts" to do this task for them, and these agencies formulate "rules" that technically are NOT laws, but carry the force of law.  This scheme effectively insulates regulatory decisions from congress and the courts.  As I recall, a book on this subject was published a couple of decades ago, titled The Invisible Government.

As individuals we have very little recourse against bureaucratic decisions.  Our constitutional guarantees and protections under the Bill of Rights are  limited, since this falls under the category of civil law, not criminal law.  When we violate an FCC rule, we are subject to a civil lawsuit and civil penalties by the government, not criminal liability (unless the violation is spelt out specifically in the Communications Act of 1934).  The federal courts offer little relief,  nearly always deferring to the assumed expertise of the regulatory agency, and rarely will a regulatory agency rule against its own previous decision.  That's exactly what happened in our case when K1MAN took the FCC to court over the AM power reduction.

Those of us who have been around long enough will remember the longstanding anti-AM bias of the bureau within the FCC that regulates amateur radio, under the leadership of Johnny Johnston.  Beginning under the Nixon administration with a "restructuring" proposal, quickly followed by the infamous Docket 20777 (which was titled "deregulation" but would have killed AM as a legal mode below 28 mHz), the "plain language" plan, and several others, the FCC continued to release a string of rulemaking dockets over the years that managed to have embedded some kind of provision to adversely affect AM, such as specific bandwidth limits and several attempts at power limit reduction.  It was only through the continued efforts of the AM community that the mode ever survived, and Johnston managed to get his long sought-after p.e.p. power limit ramrodded through in such a way as to severely limit legal AM power compared to SSB.  This appears to have been part of a consistent FCC policiy that began with the Nixon administration, and continued unchanged through Ford, Carter, Reagan and Bush I.  The FCC finally backed off from its "docket assault" only when the agency, under the pressure of fiscal restraint, essentially gave up on such trivial matters as enforcement of amateur radio and CB rules.  Johnston finally retired a few years ago, but rumour has it that he still "advises" his replacement.  Fortunately, the FCC appears to have softened its anti-AM stand in recent years.

The elected party in power appeared to have little if any influence on FCC policy during those years.  I recall when Reagan was elected under the promise to "get the government off our backs" (which later proved to better have been described as "get the government off backs and into bedrooms"), there was some hope that FCC regulatory policy would change, but the then-prevailing anti-AM bias continued unabated as "career civil servant" Johnston remained head of amateur radio regulation.  Throughout this period, there was no detectable change in FCC policy as the bureau in charge of amateur regulation (for a while called the "Private Radio Bureau") changed names several times whenever the FCC periodically "reorganised" itself.

Of course, we now have Powell as FCC chairman, and his BPL intitiative appears to be fully backed by the present admitistration.
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Don, K4KYV                                       AMI#5
Licensed since 1959 and not happy to be back on AM...    Never got off AM in the first place.

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This message was typed using the DVORAK keyboard layout.
http://www.mwbrooks.com/dvorak
Tom WA3KLR
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« Reply #1 on: January 08, 2005, 04:06:47 PM »

The switch to r.f. output power level for the Amateur service was in line with how all other services are defined.  The concept that, regardless of the mode, the maximum r.f. output power allowed is the same, makes perfect sense to the engineer side of me.   One of the reasons for rules is non-interference.

Let’s face it, AM is not the most efficient communications mode.  It is less efficient on transmit than SSB, and it is less efficient on receive than SSB.  This is a fundamental of nature.  I can’t see holding a grudge forever based on a fact of nature.

If anyone wants to enter a civilized dialog with Johnny Johnston, W3BE, he is still alive and well.  He has maintained a column in the national QCWA quarterly publication “QCWA Journal” called “The Rules Say…Q & A”.  This year he became president of the QCWA.  

Johnny solicits correspondence under 2 addresses:
John B. Johnston, W3BE
17701 Bowie Mill Road
Derwood, MD 20855-1608

john@johnston.net

It’s been about 32 years since AM was cut back 3 dB, hasn’t it?  I think it’s due time to put up or shut up on this absurd “issue”.
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73 de Tom WA3KLR  AMI # 77   Amplitude Modulation - a force Now and for the Future!
k4kyv
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Don
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« Reply #2 on: January 08, 2005, 10:32:06 PM »

Quote from: Tom WA3KLR
The switch to r.f. output power level for the Amateur service was in line with how all other services are defined.  The concept that, regardless of the mode, the maximum r.f. output power allowed is the same, makes perfect sense to the engineer side of me.   One of the reasons for rules is non-interference.


The fallacy in your argument is in how output power is defined.  It is average or mean power that determines the interference potential af a radio signal, not the maximum amplitude of occasional voice peaks.  If p.e.p. determines the loudness of an AM signal, why are 50,000 watt AM broadcast stations rated in terms of carrier power and not listed as "200,000 watts" of peak power?  The old DC input limit was, indirectly, related to the real output power of a transmitter.  A legal rf power output limit that is actually relevant to the reason for the rule, would define it in terms of carrier output, or average total rf power output, not the bogus p.e.p. rule that we got saddled with here in the U.S.

If you believe that under the present rules the maximum r.f. output power allowed is the same regardless of mode, try loading your transmitter into a light bulb dummy load.  Transmit a 1500 watt p.e.p. signal using sinewave tone modulation first on SSB, then on AM, and observe the brilliance of the bulbs.  On AM, the bulbs will glow to about one third the brilliance as on SSB.   Using an average-reading wattmeter, the output power reading will be 1500 watts on SSB but only about 562.5 watts on AM.  In terms of sideband power, the difference is much greater.  While the peak sideband power of the SSB signal is 1500 watts, the peak sideband power of the AM signal is only about 185.7 watts.  

The Canadian power limit was also redefined a few years ago, but their rules were written in a manner that did not reduce anyone's privileges, and the pre-existing AM power limit was maintained.  Modes like SSB are defined in terms of p.e.p. output, but modes with carrier are defined in terms of average rf output.  If the Canadians were able to figure out how to do it, why wasn't the FCC?  I don't think Canadians, on the average, are any smarter than those of us who happen to live in the USA.

I suspect the real reason for the change was at least partly related to personal prejudice against the AM mode on the part of certain FCC officials.  The power reduction was only the latest of a long series of docket proposals that would have adversely affected AM.  I still have a six-inch thick collection of copies of FCC rulemaking documents covering a time period from the early 70's until the mid 90's, all pertaining to AM privileges.  Many of us who were licensed prior to 1983 still feel resentful over the power limit change.

AM power was cut back 15 years ago, in 1990, not 32 years ago.
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Don, K4KYV                                       AMI#5
Licensed since 1959 and not happy to be back on AM...    Never got off AM in the first place.

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This message was typed using the DVORAK keyboard layout.
http://www.mwbrooks.com/dvorak
W1RFI
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« Reply #3 on: January 09, 2005, 11:08:58 AM »

Quote from: k4kyv
Quote from: Tom WA3KLR
The switch to r.f. output power level for the Amateur service was in line with how all other services are defined.  The concept that, regardless of the mode, the maximum r.f. output power allowed is the same, makes perfect sense to the engineer side of me.   One of the reasons for rules is non-interference.

The fallacy in your argument is in how output power is defined.  It is average or mean power that determines the interference potential af a radio signal, not the maximum amplitude of occasional voice peaks.

Not necessarily true, IMHO.  First, RFI is a non-linear problem.  So it is those peaks, not necessarily the entire emission, that can sometimes be the direct cause of interference.  I have seen many instances of power reductions curing RFI completely, perhaps with a threshold of 50 watts, so offer an example.

What this would mean in my example is that the parts of the transmission that exceeded 50 watts would generate RFI. In a voice SSB transmission, for example, this might mean that there would be interference present on the screen of a TV only on voice peaks. If those occurred every few seconds, the peak power, not the average power would cause interference.

In some cases, the average power is important. Interference occurring near the noise level, for example, or harmonic interference, which can follow the modulation in a linear fashion.

My neighbor's TV or stereo or phone doesn't care whether the PEP comes with a low or high average power -- it simply knows that PEP = more noise.

From an RFI point of view, I can see why them made the rules what they are.

Quote
If p.e.p. determines the loudness of an AM signal, why are 50,000 watt AM broadcast stations rated in terms of carrier power and not listed as "200,000 watts" of peak power?

Because for AM stations, one is always comparing power levels of AM stations.  If you say that an AM BC station has a 50 kW carrier or a 200 kW PEP signal, you are saying the same thing. (Actually, the PEP is higher because they are permitted 125% upward modulation, IIRC.)
 
Quote
The Canadian power limit was also redefined a few years ago, but their rules were written in a manner that did not reduce anyone's privileges, and the pre-existing AM power limit was maintained.

I agree in principle that a rules change that permitted more PEP to SSB transmitters than were typically permitted prior to the rules change should not have reduced the power permitted to AM stations.  ARRL made this argument to the FCC and lost, IIRC.
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k4kyv
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Don
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« Reply #4 on: January 09, 2005, 01:46:25 PM »

Quote from: W1RFI
What this would mean in my example is that the parts of the transmission that exceeded 50 watts would generate RFI. In a voice SSB transmission, for example, this might mean that there would be interference present on the screen of a TV only on voice peaks. If those occurred every few seconds, the peak power, not the average power would cause interference....
My neighbor's TV or stereo or phone doesn't care whether the PEP comes with a low or high average power -- it simply knows that PEP = more noise.

From an RFI point of view, I can see why them made the rules what they are.


But that brings us to a more fundamental question.  Is the purpose of a legal power limit to protect other licensed users who share spectrum on and in the vicinity of the authorised transmit frequency, or is it to protect devices that happen to be physically located near a clean transmitter whose spurious emissions are well within the bounds of good engineering design, i.e. to protect devices that inadvertently act as radio receivers due to design deficiencies?

To phrase it more bluntly, should our power limit be further limited to accomodate the manufacturers of consumer electronics, who are too cheap to spend a few extra pennies per unit to make their products immune to rfi from signals that lie outside their intended tuning range?

I see this question and Part 15/BPL as two aspects of the same issue.  I would throw in a third aspect, consumer junk like touch lamps, that unnecessarily generate spurious rfi throughout the spectrum yet fail to even display the mandatory FCC Part 15 warning label.

Co-channel and adjacent channel interference among licensed users of the radio spectrum is almost entirely a function of average (mean), not peak transmitter power.

-Don k4kyv
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Don, K4KYV                                       AMI#5
Licensed since 1959 and not happy to be back on AM...    Never got off AM in the first place.

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This message was typed using the DVORAK keyboard layout.
http://www.mwbrooks.com/dvorak
Tom WA3KLR
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« Reply #5 on: January 10, 2005, 02:28:32 PM »

Hi Don,

I presumed/recalled off the top of my head that the newer AM rule was cranked in about the time the incentive licensing was cranked back in (1972?).  However, the 1500 W PEP output rule was started about 1984 as best as I could research.   DSB AM enjoyed a delayed switch-over separate from the other modes that didn’t become effective until June 1, 1990, as I found out.  So you are right about 1990.  I didn’t recall it as being this late.

Since a SSB signal is merely the voice heterodyned up to radio frequencies, the average power of the SSB signal depends greatly on the amount of speech processing.  The AM signal is mostly the carrier power.  

I remember when I had a TS-820S and it had an after-market r.f. clipper-type of speech processor added.  I could turn on the processor and get about 50 - 60 watts average power out.  I remember I could see close to the theoretical maximum 6 dB gain of speech processing.  So the normal average output without processing was about 15 Watts.  About the only time people use the heavy processing like that is in the DX pile-ups.  We all know what that kind of audio sounds like.  That’s why we are attracted to AM operation.  The PEP output of the TS-820 must have been about 110 Watts.  So a SSB signal average power is typically about 14 % of the PEP.  This is not a hard number of course.  The average power can be pushed to 55 % of PEP with heavy processing.  A 1500 W PEP SSB signal is then 210 Watts normal average, and up to 825 Watts for the DX’er.

An AM signal 100% modulated with one sine wave as everyone knows, adds 50% more power to the carrier signal, +1.76 dB.  A two-tone modulation would add a little more power yet to the carrier.  Speech is not sustained solid sine waves however.  So for this analysis I will pull a number out of my heard and say that the normal speech process adds about 1 dB average power to the carrier.  This results in a 1500 Watts PEP AM signal being about 472 Watts.  This is 2.2 dB higher average power than the typical SSB signal.  Also, the 1500 W PEP AM signal is 2.4 dB less average power than the extreme SSB signal.  So AM average power is right in the middle of the full range of SSB average power possibilities, and AM has higher average power than SSB of the typical case, for the same PEP output.

Some AMers complain that their commercial baluns did not hold up to their transmissions, even though the baluns are rated for at lest 2 kw PEP SSB.  This is further proof that AM has higher average power.  Even though one manufactuer has a 5 kw PEP rated balun, it  still doesn't carry an AM rating at all!  There must be some safe level.  To be fair, part of the problem here is the transmit time on AM - can be half an hour.  Did you ever hear a slop bucketeer talk for a half hour solid?

Johnny Johnston will be 78 in August.  This is not super old these days, but he is no spring chicken.  I encourage you to communicate with him now.  I have this gut feeling that you will find out some extraordinary inside scoop.  Some of it you may be able to share with us.  Some of it you may have to hold confidential.  Perhaps some commissioners at the time were for PEP output as low as 700 Watts ( the CW case with 1 KW DC in) and perhaps Johnny fought against this?  

This brings up several points I want to make which you happened to touched on Don.  There is no rule on the limit of antenna gain or effective radiated power (ERP) for hams up to the present.  Think about it.  We are being indoctrinated for this however by the r.f. safety survey we do when we renew our FCC license and for operation in the new 60 meter band (I wish it was referred to as 57 meters).  There is no rule that says presently you can’t build a directional antenna for 75 meters and get 6 dB gain over your dipole to California with your 1500 Watt PEP AM signal.  But doesn’t interference happen based solely on the ERP of the signal?  Shouldn’t our signals be based on ERP?  That’s how the broadcast signals are regulated.  

I still believe that interference is based on peak energy rather than average power.  It does follow that with higher average power comes a statistically higher incidence of peak energy.

There is 2 kinds of interference as I see it; interference to and from other radio services and interference to and from non-radio devices.  The interference to and from non-radio devices is only going to get worse.  One thing at work against us now is the advance in transistor gain performance versus frequency; the ever increasing Ft factor.  

The new plateau in transistor Ft is fueled by the advance in hetero-junction transistors.  The hetero-junction semiconductor has a higher mobility due to the compound material (more than one element used, with or without silicon!) used forming the hetero-junction.  Higher gain and frequency of operation is the result.  An example of this is the GaAs (gallium arsenide) FET which has been around for a long time.  (LEDs are compound semiconductors also.)  ICs are starting to be made of SiGe (silicon germanium).  

The point of all this dribble is that I can see this as presenting future pressure against ham radio in “fighting” interference.  This is only one pressure point.  We have seen how the FCC has supported BPL.  This is the federal government’s policy to attempt to spur commerce for AMerica.  The push for HDTV is the same mentality although I presume most of the HDTV profit money goes out of the U.S. in reality

Long-term, I see dangerous waters for the hams.  Imagine being cut back to 100 Watts ERP on more bands and then finally on all bands.  Slamming our present and past FCC and ARRL officials only adds to the pressure points.  Now if you can prove bribery or collusion that is a different matter.

Enjoy what you have.  Things can get a lot worse.
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73 de Tom WA3KLR  AMI # 77   Amplitude Modulation - a force Now and for the Future!
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