The FCC is asking for comment on RM-11767 brought by Expert Linears to strike the 15dB rule, namely 97.317(a)(2). I urge all to comment and to also write your Congressional rep. Below is a prototype comment and a boilerplate letter to your representative. Chuck w8mqw ########################### FCC################################ Comment on RM-11767 I support this revision of 93.317(a)(2) proposed in RM-11767. The future default HF amateur radio station is not a 100-W transceiver followed by a grounded-grid amplifier, but instead a high quality, low power, direct digital sampling transceiver driving a high gain solid-state amplifier---all enclosed within a predistortion closed loop. This very modern approach is not only inexpensive but yields transmitted signals of spectral purity heretofore never seen in the amateur service. There are now many low-power software-defined radios (SDRs) available to amateurs that far surpass the performance of the traditional superheterodyne designs, but at a fraction of the cost. These affordable SDRs could provide a large portion of the amateur service with superior reception and transmitted purity were it not for the barrier of the 15dB rule of 97.317(a)(2). The typical 5--10 watt output power of these SDRs now condemn them to a small niche of the amateur fraternity, to the rarefied ranks of "QRP." Of course there are 100-W amplifiers for these QRP radios, which in turn can drive a 1.5-kW amplifier, but the transmission spectral purity of the SDR is lost in such an (expensive) cascade. Moreover, because of the SDR revolution, American manufacturers have regained the advantage in amateur transceiver manufacture, with concomitant spillover into commercial and military contracts. This advantage should be promoted. The 15dB rule has become a weight slowing progress in the diffusion of superior technology into the amateur service. ###################Congressional representative ################ Please ask the FCC to rule favorably on RM-11767, a change to 97.317(a)(2). The present rule is a barrier to the diffusion of modern technology into the amateur radio service. In brief, because of a decades-old fear of the misuse of high-power amateur radio amplifiers by outlaw citizen's band users, the FCC restricted the gain of amateur amplifiers to 15 dB. This is obviated by modern computer lockout. Meanwhile, radio technology has suddenly moved into the digital realm such that far better (inexpensive) transceivers are now available with far superior spectral purity. The wide acceptance of this new software-defined radio (SDR) technology is being blocked by rule 97.317(a)(2). Moreover, the SDR revolution has enabled American manufacturers to regain dominance in amateur radio manufacture with concomitant spillover into commercial and military contracts. This technology should be promoted. Please light a fire under the FCC. Thank you for your service to our State.
Speaking as a very proud QRPer I will only say this....I do NOT support nor would I..Biggest thing slowing progress is people not learning to use what they have.....Their brains and skills..I have talked around the world on my Yaesu Ft-817nd and do so with nothing more then a Buddipole and Buddistick..I talked to a man about 3 months ago that proves my point when I say "Powermongering" will turn the ham bands into a fancy CB junk..He was a Tech and only wanted to upgrade so he had a reason to buy a 1.5KW amp..So taking away the block of turning qrp rigs into kilowatt rigs by simply plug and play would just make things worse...example B: 14.313
But the question is not QRP v. QRO—that is a religious debate that will never end. The question is should people that choose to use smaller, lower power radios be hamstrung by the 15dB rule if they choose to run higher power. If one wants to use higher power, they are going to do it. The fact that they may not be able to do it with the radio they prefer is immaterial to if they should be able to do so. BTW, at least from my recollection with other Requests for Comments, the place to send your comments is to the FCC. Writing to your Senator or congressional representative will most likely do no good as there is no bill for them to act upon. The OP asks in his letter for his representative to"light a fire under the FCC". They requested comments. That is how the system works.
I want more power not less, qrp sucks, tried it been there and I don't want to do it seriously, maybe for local work but long path DX on 40 SSB in the mornings is not QRP worthy. I build my own amps using Freescale/NXP LDMOS devices and to keep within the FCC archaic rules I have to add over 9db of gain reduction just to meet their silly rules. This is not efficiency if I have to throw away several db of usable gain just to meet an old archaic FCC rule simply because the FCC could not rein in the CB nuts years ago. An how about eliminating the stupid rule as to how many RF power amplifiers a ham can build in a given year too, I believe that this idiotic rule is still on the books. An how about raising the maximum limit from 1.5 kw to 2 kw, after all Cuba has a 2 kw limit and I also believe that Canada has a similar max power limit above us poor Americans so is the FCC telling us American hams that Cuban and Canadian hams get it better than us American hams, why?
That rule only applies...and has always only applied to commercially manufactured linear amplifiers. There is NOTHING to restrict anyone from building their own high gain linear amplifiers.
We already have a plethora of "credit card hams" that have big budgets but small brains. You don't need a linear to work DX. If you think you do then please return your ham license to the FCC and take up knitting. I agree, it will turn the bands into CB.
QRP--Right now I use a THP amp to take QRP to 50 watts, and various 3cx800 amps to go QRO. Concatenated. As W0TRS says, I am using my brains and skill...
And how much would you gain (no pun intended) by running 2 kW vs. 1.5 kW? (Of course your Electric Company would be happy.)
It's not about gain or that extra 500watts, I just want more or equal to what Cuba and other countries are allowed even If I won't even use it. I don't want the nanny state FCC TELLING me that any other countries hams are allowed more than me either. I don' have time to sit in front of the radio for 8 hours just to have to wait for propagation peaks to make a 5 second contact either. I want be able to turn my radio on to 40meter SSB during any time when long path is in and not have to wait hours for that one rare peak just so the long path DX can hear me for 5 seconds. I want to QSO with long path contacts for as long as the band stays open and there is no way that QRP will work. Also it's common courtesy to not make the poor DX station on the other end have to struggle and strain to hear you through the ever increasing noise floor with your crappy crummy whiny QRP signal.
It just means the CBers will have another source for leeeneyers! If you want to do QRP, do QRP. Otherwise pony up for the 100-watt Flex radios.
My SDR setup is a Flex 1500 --> THP HP-45 --> grounded-grid linear when needed. I can continue to do fine with this, but the option of skipping a stage - and using pre-distortion closed loop circuitry - would be very appealing. I don't see this as having anything to do with either the QRP-QRO debate, the "credit-card hams" ( that's a new one for me), or anything else. Some folks seek novelty and some avoid it. In a large enough population it evens out.
This is the comment that I sent the FCC regarding RM-11767 on Expert Amplifier company wanting to open the way for 5 watt input giving full legal limit output and increasing the power output to an unlimited amount greater than 1500 watts. -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- Dear Sirs: I am making a comment on this file because the person making this petition, Expert Amplifiers, is just trying to market their product line to a niche that has no legal market share and would be used illegally by Citizen band operators. 1.) They contend that with their amplifier that a low input to their amplifier, the drive wattage, should be allowed. In reality, most amateur radios are manufactured with 100 watt output. If you are a low power operator, QRP, then you are not interested in an amplifier in the first place. What Expert amplifier is trying to do is to capitalize on filling illegal amps to the CB, Citizen Band community. Italian companies have many amps that are wide banded that have not been approved for import legally into the United States because they do not comply with emission standards. Just look at the E-bay listing under linear amplifier. Please do not open the door to these imports that take less than 5 watts drive for full legal output on the amateur bands. CB ops will illegally operate them and make RF interference and greatly exceed their operating privileges. 2.) Expanding the 15DB limit on amplifiers, 1500 watts is not necessary. My logic is people have worked all over the world on low power, 5-100 watts. Yes 1500 watts is the legal limit but it is not even necessary. When one considers the jump from 100 watts to 500 watts output, this increase is the most important jump in power, 3Db more puts you at 1000 watts and another 2db puts one at 1500 watts. So for going from 500 watts to 1500 watts out, or about 6db max gives about 1 S unit on the dial. It is not noticeable to most people operating amateur radios today. To the ear, no, to the S meter it is even questionable. Propagation is the common denominator. If a person can't get through with 500 watts the extra 1000 is not going to make a difference. Therefore, I greatly oppose the increase of the output being increased to 1500 watts. The additional engineering of station set up to run 1500 watts cleanly and not causing RF interference is of great concern. Factually, having run both power levels, 5-100 and 1500 watts, I can say that 1500 is not necessary. To take an amplifier from 1500 watts to 3000 watts will increase the cost 3 fold on todays market. Monetarily, $3000 for a tube amp that runs 1500 watts to a tube amp that runs 3000-4500 watts will increase the cost to $10,000. It is just not necessary. The electrical system in house to run this power level requires about $1000 to $2000 additional wiring to safely implement the usage of these high power amps. Additionally, at certain frequencies, the cable feeding the antenna will break down, RG8/RG213, and RG8X is dangerous to flash over at these levels on 14-30Mhz. Standing Wave Ratio on the Antenna and Feed system will be crucial as power changing to heat will melt some cable creating a fire hazard. The average amateur radio operator has little if any knowledge what they are up against when they want to run 1500 watts. Another concern is the RF interference from poorly made amplifiers. Transistors are broad banded devices as are transistor amplifiers they are used in. End stage filter schemes are needed to eliminate/suppress the garbage from being transmitted. With a clip of a wire here and there and or some software hacking the Expert Amplifiers (the petitioner) can be made to operate on Citizen Band Frequencies. If one operates at 1500 watts as I have done then the near field interference that is possible is highly problematic. With close spaced houses in urban neighborhoods this will not engender good will to the amateur community. Alarm systems, intercom systems, telephones, stereo systems, LED lighting, all are subject to nuisance from high RF fields. With 1500 watts into a Hy-gain TH7DXX antenna at 70 feet, I could light up the second floor incandescent light bulbs in my neighbors house to nearly full brilliance and with side band operation would modulate the intensity as I was speaking. Granted he had some loose grounds in his wiring system which was part of the cause but, if I dropped my power to 1000 watts it did not happen and to 500 watts he could not tell I was even on the air. His wife had a cochlear implant device for her deafness. When she used a curling iron on her hair, getting the coils of the iron next to her head, she to could hear me on her implant. This really did happen. I was the bane of the neighborhood. I worked and worked with the neighbors affected. Spending $2000 of my own money to solve their problems. In the end just dropping my power to 500 to 800 watts solved all problems. And yet, few amateurs would put the time and money in to solving other peoples problems as I have. Therefore, my conclusion, having been an amateur radio operator for nearly 50 years, is that, greater than 1500 watts is nonsense. If one really wants to talk and have effective communication, it is far cheaper and way more efficient to invest in good antenna systems. It will cause less interference and be more effective in the long run. 3db loss per 100 feet of coax takes a 1500 watt output down to 750 watts, and turns the coax into a 750 watt heating element that will eventually melt the coax and short out the system. In non-resonant antenna systems that are being marketed this will only compound the problem of power loss and RF interference. We don't need more powerful amplifiers, we just better antenna systems. I support the abolishment of HOA restricting antenna systems, and ordinances restricting antenna systems. If the FCC implements the increased power output from amplifiers, thinking that it will increase communication capability, they are wrong, in fact it will cause more problems with RF interference and possible life endangerment due to electrical hazards associated with running excessive power. Thank you for your consideration in the matter. Sincerely, Morgan Bailey NJ8M
Have you counted sunspot numbers lately? They are approaching zero. One definitely needs maximum power to work stations on almost closed bands. The 3 dB difference between 750 and 1500 watts makes a big difference for narrow bandwidth modes. That translates working lots more stations at the noise level. We are approaching the bottom of the sunspot cycle. Many of us OT's will never see another sunspot max where one can work the world with a 5 watts and a wet noodle antenna. "Desktop dB" are a heck of a lot easier to maintain than antenna dB for us OT's. Arguing that better antennas are the solution, just doesn't fly in this era of HOA's and CC&R'S.
