The overthrow of the 15 dB rule

Hmmm. The last time I checked, 6 meters was not HF.
My question is how much of a difference will 1.3 dB will make on HF?
As an avid weak signal participant, I am well aware that in some instances in the VHF/UHF/SHF world (especially with digital modes) 1.3 dB can make or break a QSO.

 

Next time you are really straining to copy, insert a 1.3dB attenuator and tell us what happens.

 

follow up-
I'm going thru this right now, relocating back to Texas. There are three categories of CC&R that you find. None, Have restrictions but no HOA/neighborhood Nazi's to meddle, and full blown restrictions with a HOA. I want to get back to D/FW by he end of the year. Lots for sale, most are sold in a day, makes buying difficult. Zillow and Google Earth are your friends. You need to see if you'd be moving in next to the Bumpus family (if you don't get the reference watch the last half hour of "A Christmas Story" written by Jean Shepherd, late K2ORS. Zillow, generally notes if there are restrictions or a HOA, though I find they are less than 100% accurate. But generally speaking if the house was built after about 1985 it's almost guaranteed there are restrictions.

 

I now have my wonderful, beautiful, featurefull, QRP KX2 --the size of an old knight kit walkie talkie--running legal limit thru a THP HL45 as a pre amp to an Alpha.

This is the future. Its available NOW.

Get rid of the stupid 15 dB rule, and get rid of the unnecessary pre-amp, PLEASE!

 

Little box ( KX2 SDR note custom knob)--BIG BOX (personally modded this Alpha--no 15dB restriction, now no pre-amp).

(Note custom steampunk paddle;-))

NO 15 DB RESTRICTION.

The future is here.

Open your eyes and look ;-)

Resistance is Futile.

73,
Chip W1YW

 

I see the ARRL has submitted a comment to the FCC (In favor)
1
Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
In the Matter of )
)
Amendment of Part 97 of the Commission’s Rules
) RM-11767
to Amend Section 97.317 by Removing Reference to )
the 15 dB Gain Limitation. )
To: The Chief, Wireless Telecommunications Bureau
COMMENTS OF ARRL, THE
NATIONAL ASSOCIATION
FOR AMATEUR RADIO ON PETITION FOR RULEMAKING
ARRL, the national association for Amateu
r Radio, formally known as the American
Radio Relay League, Incorporated (ARRL), by
counsel and pursuant to Section 1.405(a) of the
Comm
ission’s Rules [47 C.F.R. § 1.40
5(a)], hereby respectfully submits its comments in
response to the
Petition for Rulemaking
(the Petition)
filed on or about April 7, 2016
1
by Expert
Linears America, LLC (Petitioner). The Peti
tion proposes that the Commission amend Section
97. 317(a)(2) of the Amateur Radio Service rules
2
in order to eliminate the requirement that, for
a manufacturer of external RF power amplifiers to receive a grant of certification therefor, the
the amplifier must not be capable of amplifying the input RF power (driving signal) by more
than 15 dB of gain.
3
ARRL strongly supports this Petition and urges that the Commission issue a
Notice of Proposed Rule Making at an early date proposing the specific relief requested by
Petitioner. In support of the Petition, ARRL states as follows:
1
The Petition was placed on public notice by the Commission
April 27, 2016 (See, Report No. 3041). Therefore,
these comments are timely filed.
2
47 C.F.R. §97.317(a)(2)
3
Gain is defined for the pu
rpose of that rule as the ratio of the input RF power to the output RF power of the
amplifier where both power measurements are expressed in peak envelope power or mean power.
2
I. Introduction and Background.
1. The Petition proposes relief that is in th
e nature of eliminating unnecessary regulatory
underbrush, and it continues an effort started
by the Commission on its own motion in 2004 in
Docket 04-140 to do precisely that. The rule proposed to be eliminated is outdated; it constituted
overregulation when it was adopted long ago, and it now substantially limits the flexibility of
Amateur Radio operators to experiment with the
current generation of software-defined Amateur
Radio equipment.
4
Much earlier, in 1978, the Commission was faced with a major problem of
interference caused by illegally operated, 27 megahertz
Citizen’s Band (CB)
radios with external
linear amplifiers to television reception. In its effort to address that problem,
5
the Commission
enacted a series of largely redundant and overlapp
ing regulations that, in their overall effect,
unnecessarily (and inappropriately) penalized the wholly innocent Amateur Radio operators. There
was created a plethora of restrictions on manufact
urers of external RF power amplifiers. These
restrictions were highly controversial at the time in the Amateur Radio community, and the Reports
and Orders adopting them were ultimately adjudicated by the United States Court of Appeals.
6
The
Court
, while upholding the Commission’s jurisdiction to enact the rules,
nevertheless conceded that,
“(h)ad we been
the rulemakers in this case, we might have been more hesitant in encroaching on the
domain of the innocent amateur radio operators.”
7
The Commission in 2004 eliminated some of
these unnecessary regulations. The instant Petition
proposes the elimination of another of them.
2. Between 1974 and 1978, the number of licensed Citizen’s Band Radio operators grew
from fewer than 800,000 to more than 14 million. That phenomenon generated the unfortunate
4
See, 47 C.F.R. §97.1(b).
5
The Commission stated in 1978 that its actions
in Dockets 21116 and 21117 were intended to
“...stem the flow of
large quantities of amplif
iers which were being distributed for...illegal use on frequencies in and around th
e
Citizen’s Band Radio Service.”
6
American Radio Relay League, Inc. v.
Federal Communications Commission
, 617 F. 2d 875, 199 U.S. App. D.C.
293 (1980).
7
Id.,
617 F. 2d at 879.
3
byproduct of interference to over-the-air television
reception and other radio frequency interference
(RFI), caused principally by CB operators, licen
sed and unlicensed, who unlawfully used radio
power amplifiers to increase the transmitter power of their CB transceivers from the authorized 4
watts to much higher output power levels. The Co
mmission at the time cited interference statistics
ranging from 3 million to 21 million persons suffering television interference. Even before this
epidemic level of CB amplifier-caused television in
terference, the Commission had taken steps to
preclude the marketing and use of CB amplifiers.
8
Part 2 Rules adopted in 1975 included
proscriptions: (1) of the marketing of any ex
ternal amplifier capable of use between 24 and 35
megahertz unless the amplifier could also be us
ed on four other Amateur Radio frequency bands,
9
and (2) a new CB rule (then Section 95.44, now
Section 95.411) which prohibited the use of an
external amplifier by any 27 megahertz
10
CB station.
3. These rules were not found to be effective at the time in stemming the tide of illegal CB
amplifier sale and use,
11
and the number of interference compla
ints continued to rise in the mid-
1970s. In response to this, the Commission in Docket 21116 initiated in February of 1977 a proposal
to prohibit the manufacture, importation or marketing
of any external amplifier capable of operation
on any frequency or frequencies between 24 and 35 megahertz. There was no reference to minimum
input (driving) power or other restrictions. In
Docket 21117, issued at the same time, the
Commission proposed to require type acceptance (now
certification) of transmitters and external
amplifiers marketed for use in the Amateur Service, even though the number of instances of
8
Amendment of Parts 2 and 95 of Commission Rule
s, External Radio Frequency Power Amplifiers,
50 FCC 2d 310
,
amended
53 FCC 2d 66 (1975).
9
i.e. 7.0-7.3 MHz, 14.0-14.35 MHz, 21.0-21.45 MHz and 28.0-29.7 MHz. The rule adopted at the time was Section
2.815 (47 C.F.R. §2.815).
10
Initially, HF CB operation was on 23
discrete channels between 26.96 MHz and 27.26 MHz. In 1976, the band
was expanded to 40 channels be
tween 26.96 MHz and 27.41 MHz.
11
This was largely due to the resultant marketing by unscrup
ulous manufacturers of “broadband linear amplifiers”
which were capable of amplifying 4-watt signals on an
y frequency or frequencies between 7 and 29.7 MHz and
which were marketed only to CB users. These amplifiers
exhibited even worse interference potential than did other
amplifiers due to their generation of stronger spurious signals including second and third harmonics.
4
television interference cases due to misuse of Ama
teur equipment was minimal. The proposed rules
setting forth technical standards for a grant of type
acceptance for external amplifiers pertained only
to specific authorized bandwidths and spurious emissions. Then Commission Chairman Wiley noted
the unreasonableness of the proposals with respect to Amateur Radio operators:
My concern is that, in attempting to deal with the rapidly proliferating and
sometimes troublesome CB service, we may appear to be penalizing the amateur
community which, in my judgment, is one of the most “professional” and self
-
regulated services within
the Commission’s jurisdiction.
4. The Commission, on March 20, 1978, released its
Report and Order
in Dockets 21116
and 21117.
12
It adopted a series of rules calling for type acceptance of external RF power
amplifiers for use in the Amateur Service ope
rating below 144 MHz and including certain
standards for grants of type acceptance. These include
d gain limitations (which are at issue in the
instant Petition) as well as spurious emission
limits and a 50-watt minimum drive power
requirement. The Report and Order also included
a ban on linear amplifiers capable of operation
on any frequency between 24 and 35 megahertz. Of these requirements, then Commissioner
White stated in a partial dissenting opinion with respect to the
Report and Order
as follows:
The type acceptance proposal is all that is necessary, at this time, to effectuate the
Commission’s prohibitions regarding the
manufacture, marketing, importation, and
use of linear amplifiers which are capable of being used illegally with CB sets...But
the use of linear amplifiers wi
th CB sets is already illegal.
The gain restrictions and the minimum drive
power requirement, and the ban of Amateur
amplifiers that can operate between 24 and 35 me
gahertz did not apply
to individual Amateur
Radio operators who wished to construct their own amplifiers for their own use, or to modify
purchase used or otherwise acquire an RF power
amplifier. It only applied to manufacturers of
amplifiers.
12
See the
Report and Order,
FCC 78-107, 67 FCC 2d 939 (1978).
5
II. The Docket 04-140 Rule Modifications.
5. During the period between 1978 and 2006, 27 MHz CB use and CB-related television
interference dropped markedly. Both business and personal radio users who at the beginning of
that period might have used 27 MHz CB radio mi
grated to cellular, Part 90 land mobile, GMRS,
FRS, MURS and other Part 95 radio services. At
the same time, over-the-air television reception
has to a great extent given way to satellite and ca
ble video delivery services, and illegal amplifier
use with CB radio is no longer the serious television interference problem that it was when the
Docket 21116/21117 rules were adopted. As such,
in 2004, in a docket proceeding addressing a
multitude of Amateur Radio Service rules and related Part 2 rules based largely on petitions filed
by Amateur Service licensees, the Commission proposed
on its own motion
to eliminate the most
restrictive of the 1978 rules dealing with Amateur Radio Service amplifiers. In a
Notice of
Proposed Rule Making
released in 2004 in WT Docket 04-140,
13
the Commission asked whether
it should amend Sections 97.315 and 97.317 of the Amateur Service Rules in order
“
to clarify
and simplify those restrictions.
”
Specifically, the Commission asked whether it should eliminate
the disparate restrictions imposed on manufacturer
s (which were not imposed on amateur service
licensees), so as to allow manufacturers to market equipment in the United States that they may
market overseas, and whether or not to elimina
te the requirements in Section 97.315 of the Rules
that a manufacturer must design an amplifier to (1) use a minimum of fifty watts drive power and
(2) not be capable of operating on an
y frequency between 24 MHz and 35 MHz.
14
Additionally,
the Commission requested comment on whether it s
hould eliminate the definition of an external
RF power amplifier kit in Section 97.3(a)(19)
of our Rules, because the rules did not draw a
bright line delineating when any random group of electronic parts could be reasonably
13
Amendment of Part 97 of the Commiss
ion’s Rules Governin
g the Amateur Rad
io Services, Notice of Proposed
Rulemaking and Order,
19 FCC Rcd. 7293 (2004).
14
19 FCC Rcd at 7329 ¶ 85.
6
determined to constitute an ex
ternal RF power amplifier kit. There was no change proposed to
Section 95.411
of the Commission’s
Citizen’s Radio Service
rules, which prohibits Citizen’s
Radio Service stations from attaching to a CB transceiver an external RF power amplifier or any
device capable of amplifying the signal of a CB transceiver. That rule remains in place today.
6. The Docket 04-140
Notice of Proposed Rulemaking and Order
did not specifically
make reference to the 15 dB limit on gain of Amateur Radio external power amplifiers, which by
that time appeared in the Amateur Service rules
as Section 97.317(c)(6)(ii). However, that
Notice of Proposed Rulemaking and Order
did ask whether the Commission should amend
Section 97.317 generally. In the
Report and Order
15
issued in that proceeding, no further
mention of amendment of Section 97.317 was made, but the Commission decided to
“clarify and
simplify Sections 97.315 and 97.317 of the Rules
”
in several respects. The Commission agreed
with comments filed by ARRL that the requirements imposed on amateur radio operators by
those rules are in some ways unnecessary because, under the two rules at issue at the time, "the
equipment, once authorized, can be modified to transmit on all amateur service frequency
allocations,"
16
and that revising the rule "will enhan
ce use of the 12 and 10 m(eter) amateur
bands, and allow amateur radio operators to
construct equipment without unnecessary
restrictions."
17
ARRL also noted, and the Commission agreed, that before a manufacturer could
market an amplifier capable of transmitting on the 12-meter or 10-meter
18
Amateur Service
bands, it would have to have the amplifier cer
tificated under the Part 2 equipment authorization
rules.
19
The Commission also cited other comments arguing that eliminating the fifty-watt
15
Amendment of Part 97 of the Commission’s
Rules Governing the Amateur Radio Services,
Report and Order,
21
FCC Rcd. 11643 (2006), .
16
See
ARRL Comments in WT Docket 04-104, at 21.
17
Id.
18
i.e. 24.890-24.930 MHz and 28.000-29.700 MHz respectively.
19
47 C.F.R. Part 2, Subpart J.
7
minimum drive power requirement would permit m
ore flexibility in the operation of low-
powered transceivers, and that eliminating the rule will reduce the cost and complexity of
commercially produced amateur service amplifiers
because manufacturers will
not have to make
a domestic model and an export model of the same product.
7. Thus, the Commission decided to revise
its rules to allow manufacturers of Amateur
Radio equipment to market RF power amplifiers that are capable of operating in the 12m and
10m amateur bands without a minimum drive power
requirement, but to cont
inue to require that
they design such products to avoid operation on CB Radio Service frequencies. Since the rules
were adopted in 1978, methods of preventing RF
equipment from transmitting on frequencies
other than those intended have been developed an
d they are, generally speaking, sufficient to
address the illegal CB use issue. The Commission noted, however, that as of 2006 it still
received complaints of interference to television service that are attributable to overpowered
operation by CB radio operators. In order to prevent the use of amateur radio amplifiers by CB
operators, it found specifically that it is necessary
to continue to require that manufacturers of
amateur radio amplifiers design their products
to avoid operation on the CB frequencies. It
therefore decided to retain the requirement th
at amplifiers exhibit no amplification capability
between 26 MHz and 28 MHz and require manufact
urers to certify that amplifiers are not
capable of amplification between 26 MHz and 28 MHz
and are not easily modifiable to operate
between 26 MHz and 28 MHz prior to the grant of
an equipment certification. Not one word was
mentioned, however, justifying the continued necessity of the 15 dB gain requirement for linear
amplifiers.
8
III. There is No Justification for Continuing the 15 dB Gain Limit for Amateur Amplifiers.
8. Indeed, precisely the same rationale for
elimination of the 50-watt minimum drive
power rule in 2006 applies to the elimination
of the 15 dB gain rule for Amateur amplifiers.
There are current rules that, separately and in the aggregate, are sufficient to keep illegal
amplifiers out of the hands of 27 megahertz CB operators who might misuse them without
unnecessarily restricting the continually rule-abiding radio Amateurs. The current Section 97.317
of the Commission’s Rules reads as follows:
§ 97.317 Standards for certification of external RF power amplifiers.
(a) To receive a grant of certification, the amplifier must:
(1) Satisfy the spurious emission standards of § 97.307 (d) or (e) of
this part, as applicable, when the amplifier is operated at the lesser
of 1.5 kW PEP or its full output power and when the amplifier is placed
in the standby or off positions while connected to the transmitter.
(2) Not be capable of amplifying the input RF power (driving signal) by
more than 15 dB gain. Gain is defined as the ratio of the input RF
power to the output RF power of the amplifier where both power
measurements are expressed in peak envelope power or mean power.
(3) Exhibit no amplification (0 dB gain) between 26 MHz and 28 MHz.
(b) Certification shall be denied when:
(1) The Commission determines the amplifier can be used in services
other than the Amateur Radio Service, or
(2) The amplifier can be easily modified to operate on frequencies
between 26 MHz and 28 MHz.
There is no continued justification for retaining
the 15 dB gain limitation. Instead, the Commission
can rely on the more objective, existing standa
rd calling for no amplification between 26 and 28
megahertz; the certification requirement that prohibits the utility of an amplifier for use in radio
services other than the Amateur Service; and the deter
mination of the ability of the amplifier to be
9
easily modified to operate on frequencies between 26 and 28 megahertz. On the CB rules side,
Section 95.411 o
f the Commission’s rules (CB Rule 11)
20
provides additional objective rules
sufficient to preclude the use of RF power amplifiers with a CB transceiver:
§ 95.411 (CB Rule 11) May I use power amplifiers?
(a) You may not attach the following items (power amplifiers) to your
certificated CB transmitter in any way:
(1) External radio frequency (RF)
power amplifiers (sometimes called
linears or linear amplifiers); or
(2) Any other devices which, when used with a radio transmitter as a
signal source, are capable of amplifying the signal.
(b) There are no exceptions to this rule and use of a power amplifier
voids your authority to operate the station.
(c) The FCC will presume you have used a linear or other external RF
power amplifier if
(1) It is in your possession or on your premises; and
(2) There is other evidence that you have operated your CB station with
more power than allowed by CB Rule 10, § 95.410.
(d) Paragraph (c) of this section does not apply if you hold a license
in another radio service which allows you to operate an external RF
power amplifier.
9. Finally, the equipment authorization rules
21
that implement the service rule standards
relative to grants of certification for external RF power amplifiers and which are applicable to
manufacturers are sufficient to preclude a gran
t of certification to an Amateur Radio Service
amplifier that is capable of operation with a CB transceiver or on a frequency between 26 and 28
megahertz. Neither of those equipment authorizations
rules makes reference to the 15 dB gain limit
of Section 97.317. Section 2.815
of the Commission’s Rules reads as follows:
20
47 C.F.R. §95.411
21
47 C.F.R. §2.815(b) and 47 C.F.R. §1060(c).
10
§ 2.815 External radio frequency power amplifiers.
(a) As used in this part, an external radio frequency power amplifier
is any device which, (1) when used in conjunction with a radio
transmitter as a signal source is capable of amplification of that
signal, and (2) is not an integral part of a radio transmitter as
manufactured.
(b) No person shall manufacture, sell or lease, offer for sale or lease
(including advertising for sale or lease) or import, ship or distribute
for the purpose of selling or leasing or offering for sale or lease,
any external radio frequency power
amplifier capable of operation on
any frequency or frequencies below 144 MHz unless the amplifier has
received a grant of certification in accordance with subpart J of this
part and other relevant parts of this chapter. These amplifiers shall
comply with the following:
(1) The external radio frequency power amplifier shall not be capable
of amplification in the frequency band 26-28 MHz.
(2) The amplifier shall not be capable of easy modification to permit
its use as an amplifier in the frequency band 26-28 MHz.
(3) No more than 10 external radio frequency power amplifiers may be
constructed for evaluation purposes in preparation for the submission
of an application for a grant of certification.
(4) If the external radio freque
ncy power amplifier is intended for
operation in the Amateur Radio Service under part 97 of this chapter,
the requirements of § § 97.315 and 97.317 of this chapter shall be met.
Section 2.1060(c)
of the Commission’s Rules reads as follows:
§ 2.1060 Equipment for use in the amateur radio service.
*****
(c) Certification of external ra
dio frequency power amplifiers may be
denied when denial would prevent the use of these amplifiers in
services other than the Amateur Radio Service.
10. The 15 dB gain rule should therefore be el
iminated as unnecessary for the same reasons
stated by the Commission in Docket 04-140 in the 2006
Report and Order
for the elimination of the
50-watt minimum drive power requirement. As the
Petitioner notes accurately, there is a current
11
generation of low powered Amateur Radio transceivers, including software-defined Amateur
equipment which cannot be operated at full legal power with a single amplifier due to the 15 dB
limitation on amplification. It shou
ld not be necessary to configur
e an Amateur Radio station to
include an additional amplifier stage in order to ma
ke use of current SDR technology in the Amateur
Service.
Therefore, given the foregoing, ARRL, the national association for Amateur Radio joins with
the Petitioner in this proceeding and respectfully requests that the Commission timely issue a
Notice
of Proposed Rule Making
proposing to modify Section 97.317 of the Commission’s Rules so as to
delete Subsection (a)(2) therefrom.
Respectfully submitted,
ARRL, THE NATIONAL ASSOCIATION FOR
AMATEUR RADIO
225 Main Street
Newington, CT 06111-1494
By:____
Christopher D. Imlay
________________
Christopher D. Imlay
Its General Counsel
BOOTH, FRERET& IMLAY, LLC
14356 Cape May Road
Silver Spring, MD 20904-6011
(301) 384-5525
May 26, 2016

 

Canadian HAM's are NOT allowed 2KW.
Read my previous post about our power limits.

 

Mmmmm. I read your previous post, Matt.

These are the applicable regulations (see below), as copied from Canada's RBR-4 — "Standards for the Operation of Radio Stations in the Amateur Radio Service". Sections 10.1(a) and 10.2(a) seem pretty redundant, BTW, unless the equipment builder/operator is presumed to have no accurate RF power meter. OK... point taken.

If I'm reading this correctly, Canadian operators with AQ status can transmit quite a bit more power than their U.S. counterparts. Looks like +3db on AM and +4db on SSB. That's pretty significant. I could see people getting jealous over that - it doesn't take much to do it.

And of course, outboard power amplifier gain is arbitrary, with 15db being a legislated limit that has no connection to technical capability. That's pretty obvious, right? After all, gain from the mic to the output of a 100W rig is about 50db. No technical challenge at all, really.

As for "How much power is enough?". Well... that's a transcendental question with no meaning in the physical universe, like "How big should a star be?" From the human perspective (the one that seems to count, logic notwithstanding), there are rabid proponents of 1mw to infinity. Though some prefer to specify output power in "Pills"

Regarding your comments on Expert Amps: "I see this as an attempted money grab by Expert Amps. They want the rules changed, so they can produce amps that require low drive and give legal limit out." Well, imagine that. A company that wants to improve their sales - by making their product more universally applicable. Pretty responsible thing to do from a shareholders viewpoint, right? Do you invest in stocks? If so, you probably prefer companies that are profitable - tough to achieve in the miniscule Ham market. So... good for them.

But benefits to many users are there, too. Think of all those hungry Elecraft KX-2 and KX-3 owners who could then get to 1.5KW PEP in one amplifier step. They'd be happy. And it might even start a trend where the standard output of most rigs becomes just 10W, with all the heat generating hardware safely away in another box. That might even broaden the QRP community, with QRP right "out of the box" so to speak.

Of course, it would only apply to Expert Amps if they stopped their significant price gouging the U.S. and Australia. Particularly in view of the painfully weak Euro. ('Fess Up, guys, your "profit grin" is becoming just a tad too wide!) Most likely, other manufacturers would benefit more. Like...Elecraft, for example. And probably others. So... that's progress.

The only real objection there ever was is the ease with which illegal users could gain access to lots of power on unauthorized bands. Given the number of RF cr@p generating "Dave Made" 6-pill CB amps out there right now, this might even be an improvement - at least the amp would meet FCC requirements for signal purity. (Sigh!) But probably not.

In any case, YOU have 2.2KW PEP authorized and we only have 1.5 KW PEP. (Boo, Hoo!) Both are fine with me, big northern brother. I don't need to remotely power my outdoor party lights or broil my cat with broadcast power. (Hmmm - she just hissed at me sooo...) But others.... they have different aspirations (like 500Amp/3-phase entry panels in 600 sq. ft. shacks). I've met them. I don't understand them. But I've met them. And put them in the same class as crop circles - something I'll NEVER understand.

Best Regards and Happy Holidays!

Brian - K6BRN

_____________________________________________________

10. Restrictions on Capacity and Power Output
The transmitting power of an amplifier installed at an amateur station shall not be capable of exceeding by more than 3 dB the transmitting power limits described in this section.

10.1 Amateur Radio Operator Certificate with Basic Qualification
The holder of an Amateur Radio Operator Certificate with Basic Qualification is limited to a maximum transmitting power of

• (a) where expressed as direct-current input power, 250 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,
  • (i) 560 W peak envelope power for transmitters that produce any type of single sideband emission, or
  • (ii) 190 W carrier power for transmitters that produce any other type of emission.

10.2 Amateur Radio Operator Certificate with Advanced Qualification
The holder of an Amateur Radio Operator Certificate with Advanced Qualification 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,
  • (i) 2,250 W peak envelope power for transmitters that produce any type of single sideband emission, or
  • (ii) 750 W carrier power for transmitters that produce any other type of emission.

 

Hello Brian. Happy Holidays to you and yours as well!
I found your response both eloquent and intelligent, hence my "liking" it.

Dang! Somebody called me out on it! ... oh well.

I won't expend a lot of time/energy defending myself except to say that 2250 watts PEP
is roughly 1500 watts RMS ( 2250 x .707 = 1590.75)

My feeling is that a lot of Canadian HAM's these days seem to hold their Basic license.
Looking through the call sign database, I'm starting to feel my age.
To be honest, I'm as happy as a three-headed cat in a dairy farm that our hobby
will continue to thrive because of the new generation coming into our ranks.

What bothers me is that the newer operators prefer to buy something off the shelf,
rather than explore proven technology that comes from our history.
Don't even get me started on "appliance" operators!

To this day, I still have an amplifier that uses a 4CX250 that will take 4 watts of
drive and make several hundred watts of output. Gang several of these, and you can have legal limit.
They are also inexpensive compared to 3CX1500's, 4CX800's etc.
This is something that could be easily employed by the Elecraft users or other QRP radios,
should they decide to build rather than buy.

Really?! Perhaps I'm in need a some education.
I admit I have not looked up your power limitations recently, but I was under the
impression that the American limit was 1.5 KW RMS rather than PEP.

Anyways, I digress.
The primary question of this post is whether to change of the 15 db rule should happen.

I'm not trying to stand in the way of progress, with regard to newer devices with higher
gain factors. I think the change would be okay, as long as "safety" devices are built in
to protect from their use on non-HAM bands. I just want fellow HAM's to remember that
we already have the means to accomplish the desire to create legal limit output with
minimal drive input.

Enough said ... and I approve this message! LOL

73 de Matt
VE3OY
from the Great White North

 

I have no gun at this shooting range. I'm just watching since we've moved away from the 15db rule and gone on to us vs canada power.

But US limit is PEP, not RMS

My reason for wanting to see the ruling fall is to open the door for more affordable solid state power. Simple as that. Some of these devices are capable of producing more power from lower drive than currently manufactured.

I like making stuff myself. I've made plenty of kits, from radios to tuners and now I'm homebrewing a switch for a M/S contest station. But I can't homebrew an amplifier.

And even if I could, I don't have the time. I work a full time job and run help run a fire department. I see nothing wrong with getting some on the shelf solutions for people to purchase.