AM Power Issue Revisited (lengthy read)

Discussion in 'Amplitude Modulation' started by K4KYV, Sep 17, 2017.

Thread Status:
Not open for further replies.
ad: L-HROutlet
ad: l-rl
ad: MessiPaoloni-1
ad: Left-2
ad: L-Geochron
ad: Left-3
ad: abrind-2
ad: L-MFJ
ad: HRDLLC-2
  1. K4KYV

    K4KYV Premium Subscriber Volunteer Moderator QRZ Page

    How FCC fraudulently screwed AM operators when they revised the amateur radio power limit

    Note: The following is an in-depth, read-only narrative with attached documentation, closed to further comments. Readers are invited to post comments and responses here, or if you prefer, please feel welcome to start a new thread on the topic.

    Table of Contents (by posting #)
    View attachments to each posting for the full story.

    1. Introduction. FCC Notice of Proposed Rulemaking, full text.
    2. The FCC's decision: R&O 22 July 1983
    3. Petitions for Reconsideration
    4. K1MAN Lawsuit
    5. Petitions to FCC to Outlaw AM
    6. 1990 Petitions to FCC to Retain Historic AM Power
    7. 1300 Modes
    8. 1990 Petitions Denied
    9. Conclusion
    10-11. Commentary
    12. Links to FCC on-line archives


    From the beginning of licensed amateur radio until 1983, the maximum legal power limit in the U.S. was defined in terms of input power to the RF-generating stage of the transmitter. As various operating modes and technologies evolved beyond spark transmission, a specific power standard of one kilowatt DC input to the anode of the final amplifying stage of the transmitter became the rule, which stood for many decades. Although the efficiency of various classes of service of vacuum tube and transistor finals varies to a degree, this power standard resulted in roughly equivalent maximum legally achievable, effective output power levels for all classes of final amplifiers and authorised modes of emission.

    In 1982 the FCC publicly declared that the historic DC input standard was "obsolete" (in the words of one official, "not so much a problem, but an embarrassment" to the FCC). Following this pronouncement, the FCC initiated a revision of the rules, basing the legal limit on peak envelope output power.

    The purpose of the power limit is to limit interference. The effective loudness of a signal, thus its interference potential, is a function of average, or mean power, not the maximum amplitude of random modulation peaks that may occur infrequently. The FCC's argument was that the old DC input measurement was a safety hazard to field engineers conducting station inspections as they connected measuring instruments to high voltage circuitry in unfamiliar transmitters. In the initial Notice of Proposed Rulemaking, the FCC clearly stated that the intent of this change was to improve the method of measuring power, not to change power levels amateurs actually used, and that the Commission was committed to fairness to all amateur operators.

    Peak power varies widely for a given average power level, depending on the mode of emission transmitted. It is average (mean) power, not peak power, that determines how much the output from a transmitter heats up a dummy load, how brightly it lights an incandescent lamp, how far it deflects a thermocouple rf ammeter inserted in the transmission line, and the apparent loudness of a transmitted signal, thus its potential for causing interference.

    The FCC's argument was that the Commission saw a problem evaluating the output power of stations operating one specific mode, SSB suppressed carrier, since there is no resting carrier and the output level fluctuates widely in step with the voice modulation, making it difficult to define and measure average output power from a SSB transmitter. One obvious solution to this dilemma could have been to simply define output power in terms of average power, with the exception of suppressed carrier signals, which would be defined in terms of peak power. A better alternative might have been to categorise amateur emissions into distinct classes, as exemplified by (1) steady carrier modes like CW, RTTY and FM, (2) full carrier amplitude modulated modes like conventional AM and (3) suppressed carrier modes like SSB, and define an appropriate maximum output power for each class.

    Instead, they decided on a one-size-fits-all peak power standard that would apply to all emission types. Consequently, SSB turned out to be the only one of the popular modes used by amateurs, that did not have its effective power level significantly changed. Steady carrier modes like CW, FM and RTTY enjoyed a two-fold increase in their legal output power, while amplitude-modulated carrier modes like conventional AM would be reduced to half their historic legal power levels, according to FCC logic. Their argument was that it would have been too complicated to write clear, easily understandable rules to account for all the various modes while keeping all power levels unchanged, and that (get this): it would be too costly to train FCC field personnel to observe different power standards for different modes of emissions. o_O

    This assertion notwithstanding, the FCC apparently had no problem coming up with a simple revision to the CB rules when they changed the CB power standard from the old 5 watts DC input-to-the-final rule, to output power from the transmitter:

    47CFR § 95.410 (CB Rule 10) How much power may I use?
    (A) Your CB station transmitter power output must not exceed the following values under any conditions:
    AM [Amplitude Modulation] - 4 watts carrier power [CP]
    SSB [Single Side-Band] - 12 watts peak envelope power [PEP]

    Bottom line: the FCC deliberately reduced the maximum legal transmitting power for AM, allegedly due to a perceived difficulty with the measurement of SSB transmitter power.

    As public comments to this rulemaking proposal poured in, by far the greatest concern came from the AM community that the legal AM power level would be reduced, but the FCC disregarded those comments and attempted to placate AM operators by grandfathering the old DC input power limit for a period of seven years, set to expire in 1990. They promised to reconsider the AM power reduction "if there is any justification to do so". The assumption was that interest in AM was steadily dwindling and that by 1990 few, if any amateurs would still be using the mode. On the contrary, as 1990 approached interest in AM had been steadily increasing, and most commercially-built transceivers were including AM capability. Several Petitions for Reconsideration, including one from ARRL were filed, but these were summarily dismissed by the FCC. For the entire duration of this proceeding the Commission's arguments were tainted with deceptive and misleading statements, half-truths, and steadfast refusal to address issues brought up in petitions and comments from the AM community. This will be thoroughly exhibited below in pages to follow.

    During the "grandfather" period, one individual ham, Glenn Baxter K1MAN (now SK) filed an appeal in federal court. ARRL responded that court action was "premature" since administrative remedies had not been fully exhausted (the expiration of the grandfather clause). Baxter went ahead with his appeal, which was denied by the court. He then petitioned an appeal to the US Supreme Court, which the Court declined to hear. Baxter had been a pain in the FCC's side for some time by then, with this lawsuit along with a series of other ongoing disputes with the Commission. His appeal appears to have hardened the FCC's determination to not change the AM power reduction past the 1990 deadline, come hell or high water.

    As the 1990 deadline approached, the FCC showed no sign of following through with its previously stated commitment to revisit the AM power issue, so three Petitions for Rulemaking were submitted, including one from ARRL, to eliminate the "sunset clause" and extend the historic AM power level indefinitely. Using the same deceptive arguments and twisting of facts, the FCC denied all three petitions and requests for reconsideration that followed.

    Ironically, the comments received by the FCC in response to these petitions, overwhelmingly opposing any reduction of AM legal power, rivalled the number of comments from the greater amateur community over what was supposed to have been the hot-button amateur radio issue of the day, the proposed No-Code Technician licence.

    In the pages that follow, a running narrative in chronological order outlines the 1982-1991 AM power proceeding, documented in depth by attached FCC releases, petitions, and selected comments from the amateur community.

    Original FCC Output Power Proposal, 01 November, 1982: Docket 82-624

    Click on the attached file below to view the original Notice of Proposed Rulemaking. See also

    Paragraphs 27-28 under Procedural Matters are deleted, since they contain no information relevant to the topic:

    Attached Files:

    Last edited: May 25, 2020
    AF4K and NISHAYENG like this.
  2. K4KYV

    K4KYV Premium Subscriber Volunteer Moderator QRZ Page

    The FCC's decision: R&O 22 July 1983

    Attached Files:

    AF4K and N6YW like this.
  3. K4KYV

    K4KYV Premium Subscriber Volunteer Moderator QRZ Page

    Petitions for Reconsideration

    Following the R&O of 22 July 1983, three Petitions for Reconsideration were filed, by Floyd Dunlap WA5TWF (SK) for S.P.A.M. (Society for Promotion of Amplitude Modulation), Donald Chester K4KYV, and Kevin Aflred Strom WB4AIO.

    In addition, ARRL filed a Memorandum Opinion and Order, expressing concern over the FCC's statement that should the Commission decide on other standards of power measurement in the future, they would release them in public notices. The League was concerned that changing substantive standards without issuing a NPRM open to public comment would be contrary to the Federal Administrative Procedures Act.

    Attached are the Petitions by Dunlap and Chester; Strom's Petition has not been located in archives. Also attached is the League's Motion.

    The FCC denied the Petitions and terminated the proceeding; see attached FCC Memorandum Report and Order.

    A new, totally bogus argument was interjected by the Commission, claiming that to retain the pre-existing AM power level by re-expressing the rule in terms of the new peak envelope power standard, (paragraph 10) …we cannot reconcile this argument with the requirements of Section 342 of the Communications Act of 1934… which prescribes that one should use the minimum amount of power necessary to carry out the communication desired. This reasoning is completely erroneous, irrelevant and a mis-application of Section 324, which is a general requirement that all stations in all radio services use the un-enumerated minimum power necessary to maintain the desired communication, while the amateur power limit rule prescribes the enumerated maximum legal power that a station may use under any circumstances. No attempt was made to explain or justify why an AM transmitter, operating at the former historical legal limit, could not have been using the minimum power necessary to maintain the desired communication under a variety of propagation and interference conditions.

    Attached Files:

    AF4K, AC0OB, W3DBB and 1 other person like this.
  4. K4KYV

    K4KYV Premium Subscriber Volunteer Moderator QRZ Page

    K1MAN Lawsuit

    Circa 1984, following the FCC's dismissal of the Petitions for Reconsideration, Glenn Baxter, K1MAN (SK) filed a civil lawsuit against the FCC in the U.S. Court of Appeals. See attached documents for details.

    Baxter had done his homework and presented numerous well-stated valid points in his brief to the FCC, as seen in documents listed below. In a letter in response to members of the AM community, David Sumner K1ZZ, then Executive Vice President of ARRL which had proposed the permanent "grandfathering" of AM equipment when the power measurement rules were changed, maintained that "Since the rules changes actually take effect in 1990, an administrative remedy still exists and a court challenge is inappropriate."

    Despite persuasive arguments in his well-written court briefs, several AM operators who had attended the proceedings in person reported that Baxter made a very poor presentation in court, veering off topic, boasting claims of heroism in the aftermath of the Mexico City earthquake in his efforts to provide emergency communication via AARN, his "American Amateur Radio Network". According to one witness, "he totally blew it" before the judge. The judge didn't seem particularly sympathetic to the FCC, but summarily dismissed the lawsuit, stating that the court was obliged to "defer to the expertise of the Commission" in this highly technical matter.

    Baxter then filed an appeal to the U.S. Supreme Court, but the Court declined to hear the case.

    Following the court decisions, Sumner stated in another communication, that Baxter's ill-fated attempt in court had "hardened the FCC's resolve", and that it would now be much more difficult to persuade them to reconsider the original decision in 1990 as they had initially promised to do. Some time later at a Dayton Hamvention FCC Forum, John Johnston, then chief of the Bureau in charge of amateur radio rulemaking, was asked if the Commission intended to follow through on its previously stated commitment to reconsider the AM power issue in 1990 when the seven-year "grandfather" provision in the R&O was set to expire. Johnston replied with a smirk, "you took us to court, remember?"

    This was around the beginning of Baxter's long-running feud with the FCC regarding his "bulletin broadcasts" that the FCC claimed violated numerous provisions of Part 97, and his refusal to cooperate undoubtedly prejudiced the FCC against the AM community on the power issue.

    The attachments below consist of the following:
    1. Press release that Baxter submitted to several amateur radio publications and to the Private Radio Bureau of the FCC.
    2. Notifications Baxter sent to the court, informing them of his imminent court action.
    3. Statement to the FCC by Donald Chester K4KYV, summarising and supporting claims made by Baxter in his suit against the FCC.
    4. Documentation of the FCC's summons to court.
    5. Baxter's initial Brief to the court. Well written and persuasive; he should have submitted this directly to the FCC during the initial comment period.
    6. Baxter's reply to the FCC's response.

    Attached Files:

    AF4K, AC0OB, N2EY and 2 others like this.
  5. K4KYV

    K4KYV Premium Subscriber Volunteer Moderator QRZ Page

    Petitions to FCC to Outlaw AM

    Some years after the FCC's dismissal of the Petitions for Reconsideration for the AM power change and the federal court's decision to dismiss K1MAN's lawsuit, an individual named W.B. Prechtl, W3KO, filed a petition with the FCC to "Phase out Double Side Band Full Carrier Amplitude Modulation (A3E)". The FCC sat on this undated rulemaking petition for a number of years, taking no action, assigning no RM- number, nor even releasing a Public Notice that such a petition had been filed.

    As the 7-year Grandfather period for the KW-input power standard for AM was approaching its end, the FCC suddenly took an interest in this old Petition and assigned it a rulemaking number, RM-7401. A 30-day public comment period followed. At the FCC Forum at Dayton in April 1990, John Johnston announced the filing of this Petition, and referred to its author, Mr Prechtl, by his first name, "Bill", leaving the impression that they knew each other personally; this suspicion is further corroborated by Precht's W3 callsign even though at the time he was residing in Texas.

    Stories circulated alleging that Prechtl's petition was instigated by an AM vs SSB squabble on 40m. AMers in the region of Texas and nearby states had gathered for years in early morning hours on 7160 kHz, and friction had recently developed with the arrival of a nearby SSB group of which Prechtl was a member.

    Suspicion of the Prectl-Johnston connection made sense: Prechtl, a former resident of the state of Maryland may have known Johnston personally. After his move to Texas he became entangled in the 7160 kHz squabble and decided to call on his old friend at the FCC to get rid of the AMers, and was advised to submit a petition. Speculation at best with no additional corroborating evidence, but nevertheless, the petition was filed and would play an important role in the FCC's bag of tricks when the AM power issue was raised again in 199o. See the attached letter.

    Attached below is a copy of Prechtl's petition, and the comment I submitted to the FCC in response. My comment cites an earlier petition to outlaw AM dating back to 1980, RM-3665, which was dismissed by the FCC in 1981. A copy of the FCC's Order dismissing RM-3665 was attached as an integral part my original comment and is also included below. I believe other comments to Prechtl's petition were filed, but as of this date I have not located anything additional in my archives.

    Attached Files:

    AF4K and AC0OB like this.
  6. K4KYV

    K4KYV Premium Subscriber Volunteer Moderator QRZ Page

    1990 Petitions to FCC to Retain Historic AM Power

    In the FCC's Report and Order dated 22 July 1983, the P.E.P. output power proposal was enacted into the rules (see post # 3 above). From page 3, paragraph 6,

    "By far, the most significant concern expressed in the comments was the effect that the proposal would have on AM DSB operations. Typically, these operations would be limited to half of the maximum operating power that is currently used. Most of the comments insisted that the proposed five-year grandfather period was inadequate. Typical of these were the comments of the ARRL which stated: "This effort by the Commission to lessen the negative impact that the proposal would have on these amateurs (using AM DSB) is appreciated by the League. Nevertheless, the Commission should go one step further and make this grandfathering provision permanent." The Commission remains sympathetic ot the effect the proposed rule change will have on these operations. However, we still cannot justify a permanent and continuous expense in terms of equipment and training that would be necessary for us to be prepared to make a special power measurement for this class of operations. This is particularly true in light of the fact that, in the worst case, the actual power reduction (a reduction of 3 dB) would generally be insignificant in terms of actual communications effecviness and, furthermore, given the that only approximately one percent of the licensed amateur operators use this mode. We, therefore, have decided to limit the grandfather provisions to a period ending June 1, 1990. If it appears there is any justification to do so, we will reconsider the matter at that time."
    (emphasis mine)

    As the June, 1990 deadline approached, no action by the FCC to reconsider was apparent, so three Petitions for Rulemaking were submitted, by Dale Gagnon KW1I, the ARRL and Norman Scott WB6TRQ President of S.P.A.M.

    Attached below are copies of the three petitions and a copy of my comments to the FCC in response.

    Attached Files:

    AF4K and AC0OB like this.
  7. K4KYV

    K4KYV Premium Subscriber Volunteer Moderator QRZ Page

    1300 Modes

    Prior to 1979, the FCC rules listed a table of 13 modes of emission in the amateur rules.

    From the 1974 edition of The Radio Amateur's License Manual :

    Types of emission referred to in the amateur rules
    Type A0 — Steady, unmodulated pure carrier.
    Type A1 — Telegraphy on pure continuous wave.
    Type A2 — Amplitude tone-modulated telegraphy.
    Type A3 — Amplitude-modulated telephony including single and double sideband, with full, reduced or suppressed carrier.
    Type A4 — Facsimile.
    Type A5 — Television.
    Type F0 — Steady, unmodulated pure carrier.
    Type F1 — Carrier-shift telegraphy (FSK, Frequency Shift Keying).
    Type F2 — Audio frequency-shift telegraphy.
    Type F3 — Frequency- or phase-modulated telephony.
    Type F4 — F.M. facsimile.
    Type F5 — F.M. television
    Type P — Pulse emissions.

    WARC-79, the World Administrative Radio Conference that revised many of the world's radio regulations, adopted a new, but very complex system of emission classification. The traditional A (Amplitude), F (Frequency), and P (Pulse) was intuitive, but limited and clumsy when dealing with new modes such as digital data and image. The world's radio bodies, including the FCC, adopted a new system to replace the old one. This new system is based on a combination of necessary bandwidth and a precise description of emission classification.

    Under the new system, each possible combination of emission classifications is defined as a separate distinct mode. For example, under the old designators, type A3 emission included conventional double-sideband AM, SSB suppressed carrier, SSB reduced carrier, and SSB with full carrier. Under the new designators, each one of these is classified as a separate distinct type of emission.

    As a result of this new system, the number of emission designators used in the amateur service increased from 13 to 1296. This does not mean that amateurs were suddenly authorised to use nearly 100 times the number of modes as before; the number of modes in use by amateurs was tallied up to 1296 under the new system with no change in the number of modes actually authorised. The number of specific modes was rounded up to 1300 for the sake of simplification in discussions that followed, and as Part 97 rules were later revised.

    Part 97 (the amateur rules) uses a simplified system as described in §97.3(c), to consolidate the complex terminology of emission, modulation and transmitting characteristics into nine terms that are more familiar to amateurs:

    (c) The following terms are used in this part to indicate emission types. Refer to §2.201 of the FCC Rules, Emission, modulation and transmission characteristics, for information on emission type designators.

    (1) CW. International Morse code telegraphy emissions having designators with A, C, H, J or R as the first symbol; 1 as the second symbol; A or B as the third symbol; and emissions J2A and J2B.

    (2) Data. Telemetry, telecommand and computer communications emissions having (i) designators with A, C, D, F, G, H, J or R as the first symbol, 1 as the second symbol, and D as the third symbol; (ii) emission J2D; and (iii) emissions A1C, F1C, F2C, J2C, and J3C having an occupied bandwidth of 500 Hz or less when transmitted on an amateur service frequency below 30 MHz. Only a digital code of a type specifically authorized in this part may be transmitted.

    (3) Image. Facsimile and television emissions having designators with A, C, D, F, G, H, J or R as the first symbol; 1, 2 or 3 as the second symbol; C or F as the third symbol; and emissions having B as the first symbol; 7, 8 or 9 as the second symbol; W as the third symbol.

    (4) MCW. Tone-modulated international Morse code telegraphy emissions having designators with A, C, D, F, G, H or R as the first symbol; 2 as the second symbol; A or B as the third symbol.

    (5) Phone. Speech and other sound emissions having designators with A, C, D, F, G, H, J or R as the first symbol; 1, 2, 3 or X as the second symbol; E as the third symbol. Also speech emissions having B or F as the first symbol; 7, 8 or 9 as the second symbol; E as the third symbol. MCW for the purpose of performing the station identification procedure, or for providing telegraphy practice interspersed with speech. Incidental tones for the purpose of selective calling or alerting or to control the level of a demodulated signal may also be considered phone.

    (6) Pulse. Emissions having designators with K, L, M, P, Q, V or W as the first symbol; 0, 1, 2, 3, 7, 8, 9 or X as the second symbol; A, B, C, D, E, F, N, W or X as the third symbol.

    (7) RTTY. Narrow-band direct-printing telegraphy emissions having designators with A, C, D, F, G, H, J or R as the first symbol; 1 as the second symbol; B as the third symbol; and emission J2B. Only a digital code of a type specifically authorized in this part may be transmitted.

    (8) SS. Spread spectrum emissions using bandwidth-expansion modulation emissions having designators with A, C, D, F, G, H, J or R as the first symbol; X as the second symbol; X as the third symbol.

    (9) Test. Emissions containing no information having the designators with N as the third symbol. Test does not include pulse emissions with no information or modulation unless pulse emissions are also authorized in the frequency band.

    [54 FR 25857, June 20, 1989]

    The FCC added this item to its bag of deceptive tricks in responding to the AM power issue, in an attempt to downplay the significance of AM by referring to it as "only one of the 1300 emission types amateurs use". Any poll of the amateur community would show universal puzzlement if hams were asked if they knew they were allowed 1300 emission types. This distortion of facts was designed to make Commissioners and non-technical lawyer types at the FCC, as well as elected officials who might have been contacted by constituents, feel as though this was an insignificant matter.

    For further discussion of mode types and emission designators see the attached files and visit the links listed below.

    Attached Files:

    AF4K likes this.
  8. K4KYV

    K4KYV Premium Subscriber Volunteer Moderator QRZ Page

    1990 Petitions Denied

    As predicted, the FCC combined the Prechtl Petition to outlaw AM, and the three Petitions to continue historic AM power levels, into one proceeding, while continuing to downplay the significance of AM, insisting that it is merely one of 1300 emission types used by amateurs.

    There was some concern within the AM community regarding the petition by Norman Scott WB6TRQ that it might be counterproductive, since he was requesting that the AM power limit be increased to 1500 watts carrier power, approximately twice the historical limit. Although this would have been consistent with the change to double the power limits of CW, FM and frequency-shift keyed RTTY, the FCC had already hinted at a bogus claim that the AM community was asking to increase the power level of AM to twice that of "the rest of the 1300 modes" used by amateurs (by retaining the historic power level), and this petition might have added fuel to the fire. Attached is a copy of a belated letter dated April, 1991 (unless the date was mis-typed), that Bill Kleronomos KD0HG (SK) wrote to Norm, asking that he withdraw his Petition.

    At the Dayton Hamvention FCC forum that year, the speaker was John Johnston, chief of the amateur rulemaking division of the FCC's Private Radio Bureau. His topic was that with the recent availability of low-cost word processors, the amateur community was wasting the FCC's time with an avalanche of frivolous rulemaking petitions. "You (the amateur community) have been working your word processors overtime", he said. Then he continued his discourse with a carefully worded example: "On the one hand we have a Petition from the ARRL to change the rules to allow AM operators to run twice as much power as everybody else. And then we have this other Petition (from Mr Prechtl) who wants to eliminate AM altogether."

    The obvious implication was that the FCC would be "even-handed" and deny all the petitions, letting the AM power reduction stand.

    On 31 October, 1990 the FCC released its Order denying all four petitions. (Attached)

    A Petition for Reconsideration was submitted by Dale Gagnon, KW1I regarding RM-7402 and RM-7404 (Attached). Absent from Dale's was any reference to RM-7403, Norman Scott's petition.

    Norm Scott submitted his own Petition for Reconsideration (attached). Also attached is a News Release from S.P.A.M., but the second page is missing.

    The FCC either denied both Petitions, or simply sat on them and failed to act; I could find no Order formally denying the Petitions.

    To view these documents, click on the attachments below:

    Attached Files:

    AF4K and AC0OB like this.
  9. K4KYV

    K4KYV Premium Subscriber Volunteer Moderator QRZ Page


    An insight into the FCC's stonewalling and steadfast refusal to take the AM community's letters, comments and pleadings into consideration may be gained from a communication I received from Norm Scott in May, 1990 (see attached). He claims that Bill Cross at the FCC, second in command under John Johnston, had called him on the telephone and that they talked at length about Norm's petition.

    According to the letter, Bill Cross, who Norm reports was in charge of the AM power petitions, implied in their conversation that the 1990 Petitions were filed too late. He stated that the power rule was "tested all the way to the Supreme Court", referring to K1MAN's lawsuit, and that the Commission was not going to change the rule without having an overwhelming reason, since they had "used a lot of resources" to defend the Commission's action. When Norm asked if that was why they would not change the rule, Cross became very upset and emphatically denied it. Then Cross went on to imply that there wasn't much interest in the issue since the FCC had "only four petitions dealing with AM".

    An interesting side note to history: Norman Scott WB6TRQ had taken over S.P.A.M. (Society for Promotion of Amplitude Modulation) after the unexpected death of the previous president, Floyd Dunlap WA5TWF. He initially hit the ground running with articles, letters and petitions, very actively promoting the AM cause, as witnessed by Norm's letters and petitions in this proceeding. Then Norm abruptly seemed to have dropped off the face of the earth; nothing more was heard from him, and all attempts to contact him went unanswered. He retained the S.P.A.M. membership roster, all the organisation's documents and a small amount of cash from membership contributions, and no-one ever found out what happened to any of that. His most recent renewal is listed on the FCC's ULS web page as effective 05 December 2013, with expiration date 08 February 2024, and his call sign is still actively listed on, but after more than a quarter century, no further contact has been made. After his disappearance, his ad continued to appear for a couple of years in the classified section of Electric Radio, inviting readers to join S.P.A.M.

    Dale, KW1I started up an AM advocacy group to replace S.P.A.M., which he named AMI (AM International). AMI flourished for a few years until interest eventually waned as more and more hams gained access to the internet, and numerous amateur radio and AM-related on-line discussion forums made it less relevant.

    Thus ends the AM Power narrative, but additional documents will be uploaded if they become available, since my archives are not 100% complete. If anyone has documents on file that are missing from this series but you feel are relevant to the AM power issue, please forward me a copy and they will be posted. I will try to scan and upload some of the more interesting comments to the FCC I have on file, but it would be impractical to include them all, since the file is several inches thick, mostly re-statements of what is already posted here. My contact information is here on, including my e-mail address.

    Most of the commentary and documentation posted here were formally submitted as comments to the FCC's Technological Advisory Enquiry, and appear on the ECFS website. Links appear in message #12 on the next page

    Don k4kyv

    Click on the attachment below to view Norm Scott's summary of a telephone conversation he had with the FCC official in charge of the AM power proceeding.

    Attached Files:

    AF4K, N6YW, AC0OB and 1 other person like this.
  10. N6YW

    N6YW Ham Member Volunteer Moderator QRZ Page

    Thank you for the in depth article Don. It is very much appreciated.
    Since you taught me about true AM power measurement relating to carrier power,
    and the logic behind it making perfect sense, I maintain that rule in my operations.
    For example, when another Amateur attempts to chastise me for running more than
    375 watts of carrier and that my "PEP" surpasses the Amateur legal limit of 1500 watts
    PEP, I simply state that AM is not measured in PEP. Carrier power is the true measurement
    for AM. For a moment I hear crickets which usually is the conundrum building in their
    heads before the next comment surfaces, which usually is another version of what they said the first time.
    I simply state that I am not going to argue with them about this because they don't have sufficient
    means to state their case against my Bauer 707 output, which on low power is 675 watts
    and that's what I normally run.
    I actually enjoy discussing the power rule and I don't do it to sound pithy or arrogant, just
    discussing fact over their perception of rule. When I bring up the well used jargon that BC stations
    use when describing their power level, it's always regarding carrier power as PEP is never even
    mentioned. That's what bothers them the most. I find it funny.
    Thanks again.
Thread Status:
Not open for further replies.

Share This Page