The overthrow of the 15 dB rule

Discussion in 'Amateur Radio News' started by W8MQW, Apr 29, 2016.

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  1. W8MQW

    W8MQW XML Subscriber QRZ Page

    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.
    Last edited by a moderator: Apr 29, 2016
    NZ5F, KD7KCP, KF7PCL and 1 other person like this.
  2. W0TRS

    W0TRS Ham Member QRZ Page

    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
    K7KE, WW3JR, WB6CSH and 14 others like this.
  3. NY4I

    NY4I XML Subscriber QRZ Page

    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.
    K7KE, KF7PCL, WW3JR and 5 others like this.
  4. WB8VLC

    WB8VLC Ham Member QRZ Page

    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?
    AA5IT, W6ERM, WZ2Z and 1 other person like this.
  5. KL7AJ

    KL7AJ Ham Member QRZ Page

    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.
    KD5TNC, KC9BNW, KF7PCL and 13 others like this.
  6. W1YW

    W1YW Ham Member QRZ Page

    Just do what the amp manual sez....

    K9ASE, KD2BBC and KK6GUN like this.
  7. W1YW

    W1YW Ham Member QRZ Page

    I love QRP...

    but I love QRO by 25+ dB MORE!

    (This would make an awesome T shirt at Dayton:)!
    W0PV likes this.
  8. K4PIH

    K4PIH Ham Member QRZ Page

    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.
    N8YA, WW3JR, W6REG and 10 others like this.
  9. W1YW

    W1YW Ham Member QRZ Page

    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...
  10. WA9SVD

    WA9SVD Ham Member QRZ Page

    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.)
    SA6CKE, W0LSB, K9SS and 1 other person like this.

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