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[Amps] FCC Denies Expert Linears' Request for Waiver of

To: <amps@contesting.com>
Subject: [Amps] FCC Denies Expert Linears' Request for Waiver of
From: "Jim Thomson" <jim.thom@telus.net>
Date: Wed, 28 Dec 2016 18:41:35 -0800
List-post: <amps@contesting.com">mailto:amps@contesting.com>
Date: Wed, 28 Dec 2016 16:55:39 -0800
From: Jim Brown <jim@audiosystemsgroup.com>
To: amps@contesting.com
Subject: Re: [Amps] FCC Denies Expert Linears' Request for Waiver of
15 dBRule

On Wed,12/28/2016 4:26 PM, qrv@kd4e.com wrote:
> just the freedom to buy what you want to use? 

It has NOTHING to do with freedom. One of the FCC's functions is to 
establish the rules of the road for radio and other communications 
mediums, and their function is much like establishing rules of the road 
for our highways. Speed limits and no passing zones are not restrictions 
on our freedoms, they are practical rules that make it safer for citizens.

The 15 dB rule was established at the height of the CB radio boom, and 
was part of an attempt to deal with illegal operation using ham gear. It 
may have outlived its usefulness, and it the petition to change it is 
timely. But ALL amplifier manufacturers have been subject to it and 
designed their products to conform. SPE chose to ignore it, and those 
who have sold these amps in the US are in violation of Federal law.

My personal opinion is that the ham community would be better served by 
allowing commercially made amplifiers to have more gain _IF_ FCC Rules 
were also amended to tighten IMD and keying bandwidth limits on 
transmitted signals and enforced on manufacturers who sell rigs that 
don't meet those Rules. 20 dB would allow a 10W radio like a KX3 or ANAN 
10e to drive a 1kW amp to full power. 21 dB gets it to 1.25 kW, less 
than 1 dB below legal limit.

73, Jim K9YC

##  Whoa.  I thought the 15 db rule was only for  the 12 + 10m bands ??? 
IE:   >  24 mhz.    Below 24 mhz, I was sure that was no gain limit.   

##  spe  et all, would just have to  switch in a pad on the 12+ 10m bands  to 
meet
fcc compliance.... or increase NFB.  

##  as for the TX  IMD situation, its a mess.   The Z match that the amp makers 
has chosen, is done
so  the eff is max, like typ 50%.... but only when the devices are run flat 
out.... whereby the amp then
becomes an IMD  garbage truck.   If you back off on the PO of the amp, its imd 
improves, BUT the eff
goes to hell, like down to 30-35%  when run at half rated power.   The fix for 
the eff...is to use less vdc, when
using lower power levels, but then the IMD goes to hell.  Lower vdc typ makes 
the imd worse. 

##  to really do it right would mean to use devices rated for 3-4-5 kw, then 
operate them at 1.5 kw pep out, then
design the Z match based on 1.5 kw out.     Then use a power supply, that will 
handle the 1.5 kw output.   Ditto
with 1.5 kw LP filters.   No rocket science here folks,  for low imd, and 1.5 
kw pep out on ssb,  you either  require
bigger devices, or more devices ....or both.   Typ you will also get a 1 db 
redux in IMD  for every 1 db in NFB. 
Problem is, with more NFB, drive requirements increase.   3db  of NFB on a  
Drake L4B means you now require 200
watts to drive the amp.   6db means u  require 400w of drive.  So the NFB 
works... provided the device has loads of gain
to begin with.   IMD can also be reduced a bit by tweaking the bias.... like 
increasing idle current.  But you can only go so far
with that method. 

## Dishtronics  2.5 kw output amp, when run at 1.5 kw pep out, still has a 
lousy  -30 db pep IMD.   If you look at the spec sheets
for these various  devices, esp the  IMD  vs PO graphs, you will soon see that 
they have to be severely re-rated to achieve  what I would
call reasonable IMD....   -40db pep.... or –34 db below one tone of a 2 tone 
signal. 

##  problem is, no countries regs that I can see, regulate IMD for amateur use, 
its a non regulated free for all.    Even if it was regulated, 
which committee  will pick the numbers ?  All the existing gear would be 
grandfathered.   Its the higher order IMD that causes the real issues,
like  IMD- 9-11-13-15-17-19  etc.   

##  You would require 2 x sets of regs,  one for the xcvrs..and another for the 
amps.  Dirty xcvr driving a clean amp = bad imd.    Clean xcvr
driving a dirt amp = bad imd.   They both have to be clean. 

##  Too bad the ARRL  etc, cant call a spade a spade, when  doing equipment 
reviews... esp regarding spectral purity.   yes, nice piece of
gear for a ham amp  / xcvr... BUT  we cant recommend it due to its lack of 
spectral purity.....then  dont accept their magazine advertising either,
until said gear meets ARRL etc, min specs for IMD etc. 

## Ok say no regs.    How about voluntary guidelines.      How about some 
leadership for a change.   If  ICOM / Kenwood / Yaesu  can build
FCC  compliant marine gear, that meets ITU / FCC specs... they could easily do 
the same  for amateur gear. 

Jim   VE7RF

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