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Subject: FCC Invites Comments on Petition to Eliminate 15 dB Gain Limit on Amateur Amplifiers Date: Wed Apr 27 2016 21:04:12
From: ARRL de WD1CKS To: QST

 04/27/2016 

The FCC has put on public notice and invited comments on a Petition for Rule
Making (RM-11767[1]), filed on behalf of an amateur amplifier distributor,
which seeks to revise the Amateur Service rules regarding maximum permissible
amplifier gain. Expert Linears America LLC[2] of Magnolia, Texas, which
distributes linears manufactured by SPE in Italy, wants the FCC to eliminate
the 15 dB gain limitation on amateur amplifiers, spelled out in ?97.317(a)(2).
Expert asserts that there should be no gain limitation at all on amplifiers
sold or used in the Amateur Service.

"There is no technical or regulatory reason [that] an amplifier capable of
being driven to full legal output by even a fraction of a watt should not be
available to Amateur Radio operators in the United States," Expert said in its
Petition.

Expert maintains that the 15 dB gain limitation is an unneeded holdover from
the days when amplifiers were less efficient and the FCC was attempting to rein
in the use of Amateur Service amplifiers by Citizens Band operators. While the
FCC proposed in its 2004 Notice of Proposed Rulemaking and Order in WT Docket
04-140 to delete the requirement that amplifiers be designed to use a minimum
of 50 W of drive power and subsequently did so, it did not further discuss the
15 dB amplification limit in the subsequent Report and Order[3] in the docket.

"Although no party advocated retention of the 15 dB limit, it remains in place
today," Expert pointed out in its filing. "In the intervening years,
advancements in Amateur Radio transmitter technology have led to the
availability of highly compact, sophisticated low-power transmitters that
require more than 15 dB of amplification to achieve maximum legal power output.
Therefore, Expert seeks to remove the 15 dB limit from ?97.317 so that Amateur
Radio manufacturers and distributors will not be forced to needlessly cripple
their amplifiers for sale in the United States."

Expert pointed to its Model 1.3K FA amplifier as an example of a linear
"inherently capable of considerably more than 15 dB of amplification," which
would make it a suitable match for low-power transceivers now on the market
having output power on the order of 10 W. 


[1] http://apps.fcc.gov/ecfs/comment/view?id=60001536394
[2] http://www.expertlinears.com/
[3] https://apps.fcc.gov/edocs_public/attachmatch/FCC-06-149A1.pdf

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