SB QST @ ARL $ARLB015
ARLB015 FCC Invites Comments on Petition to Eliminate 15 dB Gain Limit on
Amateur Amplifiers

ZCZC AG15
QST de W1AW
ARRL Bulletin 15  ARLB015
> From ARRL Headquarters
Newington CT  April 28, 2016
To all radio amateurs

SB QST ARL ARLB015
ARLB015 FCC Invites Comments on Petition to Eliminate 15 dB Gain Limit on
Amateur Amplifiers

The FCC has put on public notice and invited comments on a Petition for Rule
Making (RM-11767), 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 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 Part 97.317(a)(2). Expert asserts that there should be no gain
limitation at all on amplifiers sold or used in the Amateur Service.

RM-11767 can be found on the web at, http://apps.fcc.gov/ecfs/co
ment/view?id=60001536394 .

"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 in
the docket.

The R&O is in PDF format at, https://apps.fcc.gov/edocs_public/a
tachmatch/FCC-06-149A1.pdf .

"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 Part 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.

NNNN
/EX

)\/(ark

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