Believe me, Don, your bona fides did not need to be established from my perspective. This wasn't about expertise, however, but about what the FTC should do, if anything, to aid uneducated consumers in making choices in the market. The rule they landed on isn't that relevant to consumer applications, and that's the root of the problem from my perspective. That is one reason why it's so hard to measure as they have described it--a rule closely traced to consumer applications would be far easier to test. Use cases are easier to draw requirements from when they are realistic, and properly formulating requirements demands testability. Did that sound like lecturing? If so, I apologize--I teach systems engineering processes and can't help it.I have said that high-power RF amps often include intermittent power ratings with on and off (cool-down) duty cycle periods specified. Very common, and would work with the intent (I think) of the FTC rule: continuous power rating, then add a peak power rating that is adequately defined (e.g. the IHF 20 ms burst test) for headroom. You are reading too much into my post without reviewing prior context. Which is the same problem I have and why I should really just stay out of this mess; I am too lazy to post a book with all relevant experience, and then end up being lectured because my responses are either not clear or insufficiently detailed, about a topic I appreciate but realistically is just a bunch of keyboard warriors (myself included) whining about.
I have not renewed my Ham license in many years, another expensive hobby I have not gone back to, but have plenty of experience with Ham radios, commercial radio/TV systems, medical transmitters (e.g. 60 MHz ultrasound scanners), and government (military and otherwise) systems. I like seeing a continuous power rating as it has implications for other things like thermal management, then a headroom spec based on (defined) short-term output, would cover amplifiers for music and other (e.g. radar, communication, telemetry) applications. A radar transmitter is a good example of a design having very high peak power with much lower continuous power ratings. That is why the audio comparison. And you have already provided example where continuous power matters.
My argument with the FTC spec is lack of a clear definition both in scope and compliance testing. I think I have been consistent but this has gone on for so long I am sure someone could find something somewhere. If the FTC opens up a new comment period, I will contribute as I did last time. In this case, I think part of the problem is that people with knowledge of test standards assumed a base experience level not reflected in the final rule.
And I have never been opposed to continuous power testing, if the signal being tested is relevant to the use case. The FTC condition isn't that, and it has never seemed to me that the power ratings that comply with it will reliably tell uneducated consumers which amp will make their music louder, especially within a factor of 2 or so.
Rick "just a guy" Denney