SB QST @ ARL $ARLB019
ARLB019 ARRL "Strongly Supports" Petition to Drop 15 dB Restriction for
Amateur Amplifiers

ZCZC AG19
QST de W1AW
ARRL Bulletin 19  ARLB019
> From ARRL Headquarters
Newington CT  May 26, 2016
To all radio amateurs

SB QST ARL ARLB019
ARLB019 ARRL "Strongly Supports" Petition to Drop 15 dB Restriction for
Amateur Amplifiers

In comments filed on May 26, the ARRL said it "strongly supports" a petition
to the FCC seeking to eliminate an Amateur Service rule, spelled out in Part
97.317(a)(2), that amateur amplifiers not be able to boost the RF input signal
by more than 15 dB. The Petition for Rule Making (RM-11767), was submitted in
April on behalf of an amateur amplifier distributor, Expert Linears America
LLC of Magnolia, Texas.

ARRL's comments can be found on the web at, http://www.arrl.org/
ews/arrl-strongly-supports-petition-to-drop-15-db-restriction-fo
-amateur-amplifiers .  RM-11767 can be found on the web at, http
//apps.fcc.gov/ecfs/comment/view?id=60001536394 .

"The Petition proposes relief that is in the nature of eliminating unnecessary
regulatory underbrush, and it continues an effort started by the Commission on
its own motion in 2004...to do precisely that," the ARRL said in its comments.
"The rule proposed to be eliminated is outdated; it constituted overregulation
when it was adopted long ago, and it now substantially limits the flexibility
of Amateur Radio operators to experiment with the current generation of
software-defined Amateur Radio equipment."

The 15 dB provision came into the rules during an era when the FCC initiated
various actions to rein in a major interference problem resulting from the use
of illegal 11 meter amplifiers during the Citizens Band radio boom of the
1970s. "In its effort to address that problem, the Commission enacted a series
of largely redundant and overlapping regulations that, in their overall
effect, unnecessarily (and inappropriately) penalized the wholly innocent
Amateur Radio operators," the League asserted. "There was created a plethora
of restrictions on manufacturers of external RF power
amplifiers."

The ARRL noted that while the FCC eliminated some of the unnecessary
regulations in 2004, others remain, including the 15 dB gain restriction. The
rules adopted in 1978 also called for type acceptance (certification) of
manufactured RF power amplifiers operating below 144 MHz, including a 50 W
minimum drive power requirement and a ban on amplifiers capable of operation
between 24 and 35 MHz.

"Indeed, precisely the same rationale for elimination of the 50 W minimum
drive power rule in 2006 applies to the elimination of the 15 dB gain rule for
amateur amplifiers," the ARRL said in its comments. "There is no continued
justification for retaining the 15 dB gain limitation."

The League agreed with the petitioner that a current generation of low-power
Amateur Radio transceivers, including software-defined designs, cannot drive
an amplifier to full legal power given the 15 dB limitation. "It should not be
necessary to configure an Amateur Radio station to include an additional
amplifier stage in order to make use of current SDR technology in the Amateur
Service," the ARRL said.

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/EX

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