FCC Technological Advisory Council Investigating Technical Regulations

Discussion in 'Amplitude Modulation' started by K4KYV, Sep 4, 2017.

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  1. K4KYV

    K4KYV Premium Subscriber Volunteer Moderator QRZ Page

    The FCC Technological Advisory Council is looking into FCC technical regulations to determine if reforms or changes might be in order. The FCC has asked its Technological Advisory Council to help identify FCC technical rules that are obsolete or may be ripe for change in light of current communications technologies. http://www.arrl.org/news/fcc-technological-advisory-council-investigating-technical-regulations

    Revisiting the AM power issue comes to mind.

    Recommendations for Removing Obsolete or Unnecessary Technical Rules:
    The rapid pace of technology evolution often makes rules that were adopted years ago unnecessary or irrelevant. This work group is tasked to review the FCC technical rules to identify and prioritize those that should be eliminated. In making recommendations the work group is to consider the benefits and costs of doing so, particularly relative to any potential risks of detrimental impact or unintended consequences to existing stakeholders and how those risks can be mitigated. The work group is also tasked with identifying alternative processes for streamlining the introduction of new technologies as an alternative to the Commission’s traditional approach of considering technical matters through rule making. The Commission has largely left it to industry to develop standards for new technologies. Would it be feasible to use standards bodies for development of standards for such things as transmitter power limits and out of band emissions? Are there processes that exist or can be developed that bring stakeholders together to develop consensus recommendations on technical matters, including whether it is necessary to embody specific elements in regulations?

    Interested parties may file comments in ET Docket 17-215 until October 30, using the FCC Electronic Comment Filing System (ECFS).

  2. K4KYV

    K4KYV Premium Subscriber Volunteer Moderator QRZ Page

    It could be a double-edged sword, making it all the more imperative to watch this closely. For example, certain interest groups might take this as an opportunity to re-launch the ill-fated regulation-by-bandwidth proposal, or to otherwise impose specific bandwidth limits or other onerous regulations adverse to AM. Less likely, but not beyond the realm of possibility, we could see renewed attempts to outlaw AM altogether.
  3. WA3QGD

    WA3QGD Ham Member QRZ Page

    no worries don only fly in the oinment is coming up with an AKA[ handle] Call signs are pretty much meaninless,75 has been comprimised,and the only place one can be boss seems to have the fellows I used to remember having fond memories of as gentlemen of the aether.My I humbly suggest {Frozen Faucet} or {tunbuckle twister} 73'es
  4. K5UJ

    K5UJ Ham Member QRZ Page

    I have not actually read the FCC notice--have to make that clear up front. My perception which might very well be flawed, is that this is a form of deregulation. I'm seeing phrases like removing out of date rules etc., words like "obsolete" and "unnecessary." So I am not too worried about bans on this or that or bandwidth limits etc. because those involve more rules not less. the power limit thing is an interesting issue to contemplate. Here's a question: what power criteria for measurement would be fair for everyone and easy to execute? It certainly isn't p.e.p. Few, outside of CW, FM and data operators, can actually measure it (many think they can).

    It's certainly an interesting rag chew QSO topic or one for an AM get-together.
  5. K4KYV

    K4KYV Premium Subscriber Volunteer Moderator QRZ Page

    One model might be something along the line of the Canadian regulations. In the FCC proceeding, the Commission claimed they wouldn't be able create a one-size-fits-all rule for defining and measuring output power that would include SSB power, without reducing AM power, and still keep the wording simple. Canadians must be smarter than United States-ese, since they figured out how to do it:

    Standards for the Operation of Radio Stations in the Amateur Radio Service RIC-2

    10.2 Amateur Radio Operator Certificate with Basic and Advanced Qualifications

    The holder of an Amateur Radio Operator Certificate with Basic and Advanced Qualifications 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

    The drawback with the Canadian regs is their 6 kc bandwidth limit. But most Canadians I have ever QSOed with on AM were using standard AM equipment without any special low-pass filters. I have never heard of a Canadian AMer being cited for exceeding 6 kc bandwidth, just as I have never heard of a US AMer being cited for exceeding 1500w p.e.p.
  6. WB1E

    WB1E Ham Member QRZ Page

    The biggest fault currently are the ESSB'ers who don't know how exactly they how poorly their signal affects others (or care). Sometimes 30Kc wide and talk like CB'ers to boot. They snuggle up right next to 3890 (3894) and do their deal wiping out most of everything down to 3880 at least. No filtering will un-mix their splatter. And no one seems to care about enforcing any rules down here in Texas.

  7. K7JEM

    K7JEM Ham Member QRZ Page

    One thing that I see is that the Canadian regulation seems to limit CW output to 750 watts, if I read that right.
    AG6QR likes this.
  8. K4KYV

    K4KYV Premium Subscriber Volunteer Moderator QRZ Page

    Yep, just exactly as the US regulation did before they changed over to that PEP bull-Shi'ite. The historical power limit was 1 kw DC input. Nominally, 750 watts carrier output on AM, CW and FM. For SSB, the FCC went by a standard using a plate current meter with 0.25 seconds ballistic time constant to peak at no more than 1000 watts DC input on voice syllables. That was guestimated to be around 2000 watts p.e.p. input, which roughly transmits nominally to 1500 watts p.e.p. output. It wasn't unusual to see ads for SSB leen-yars in 1960s ham magzines touting "2000 watts pep input".

    Then they changed over to the present rule. The FCC claimed it would have been too complicated to write a rule that would have preserved all the existing mode power limits, so they adopted a one-size-fits-all approach, a p.e.p. standard based on SSB and a fictitious final amplifier efficiency of precisely 75% . IOW, the FCC cut AM power because they didn't think the rules adequately accommodated slopbucket power. The CW, RTTY and FM power limits were doubled. Slopbucket remained nominally the same, although they were actually given a slight boost, since few if any SSB amplifiers actually run at an efficiency as high as 75%. AM was cut in half (at least that's the party line).

    In the power limit NPRM, the FCC explicitly stated that it was their intent to "improve" how transmitter power was measured, not to change the actual power levels that amateurs used, but then went on to claim they couldn't figure out how to do it without making the rules unduly complicated. The Canadians, evidently smarter than United States-ese, were able to figure that out with a couple of paragraphs.

    This might be used as an argument in this latest Docket to revisit the AM power limit.
  9. K7JEM

    K7JEM Ham Member QRZ Page

    I don't think you will make points with the CW crowd by suggesting a cut in their power so that a few AM ops can run a little more.
  10. K4KYV

    K4KYV Premium Subscriber Volunteer Moderator QRZ Page

    No-one has said anything about reducing CW power or adopting the Canadian regulations verbatim. The issue at hand is correcting the previous error and returning historic power privileges back to AM operators.

    Nevertheless, of all the modes available to amateurs, CW probably had the least justification for a power increase, since CW was already the most power-efficient mode included in amateur privileges at that time. CW can get through noise and interference when AM and SSB fail, and that's long been one of the advantages touted by CW enthusiasts. But once the power increase was granted, taking it away would raise opposition from a very vocal CW community. Given that CW/FM/RTTY power was given a hefty power increase, returning it back to its previous level would now amount to taking away existing privileges.

    When the FCC adopted the current rules, they apparently assumed that amateur interest in AM was declining, that AM activity would eventually dwindle to insignificance and that hams would discard and replace their older equipment, but that didn't happen. Since then, over the past 30 years, interest in AM has increased and the mode has increasingly returned to mainstream. Add to that the continued interest in restoring and operating vintage equipment capable of running the historic AM power level.

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