How the FCC intentionally screwed the AM operator when they revised the amateur radio power limit Note: This is a read-only narrative closed to further comments, which would accumulate and eventually push posted information off the bottom of the page. Readers are invited to post comments and responses here, or if you prefer, please feel welcome to start a new thread on the topic. Introduction From the earliest days of licensed amateur radio until relatively recently, the maximum legal power limit in the U.S. was defined in terms of input power to 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 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). The proposed new standard was to be be based 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 amplitude of random modulation peaks that may occur only 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 the FCC. Their argument was that it would have been too complicated to write easily understandable rules to account for all the various modes while keeping all power levels unchanged, and that it would be too costly to train FCC field personnel to observe different power standards for different modes of emissions. This assertion notwithstanding, the FCC apparently had no problem making a simple revision to the CB rules when they changed the CB power standard from input to output power: 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 reduced the maximum legal power for amateur stations transmitting AM, because they had a perceived problem with the measurement of SSB 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 declined by the FCC. The Commission's arguments were filled with deceptive statements, half-truths, and steadfast refusals to address issues brought up in petitions from the AM community. This will be exhibited below in pages to follow. During the "grandfather" period, one individual ham, Glenn Baxter K1MAN (SK) filed an appeal in federal court. ARRL claimed 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 for 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 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 opposed to any reduction of AM legal power, rivalled the number of comments received from the greater amateur community over what was supposed to be 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 details the entire 1982-1991 AM power proceeding, documented 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 http://forums.qrz.com/index.php?thr...ng-technical-regulations.580233/#post-4385889. Paragraphs 27-28 under Procedural Matters are deleted, since they contain no information relevant to the topic.