SB QST @ ARL $ARLB045
ARLB045 FCC Denies Expert Linears' Request for Waiver of 15 dB Rule, Petition
Pending

ZCZC AG45
QST de W1AW
ARRL Bulletin 45  ARLB045
> From ARRL Headquarters
Newington CT  December 28, 2016
To all radio amateurs

SB QST ARL ARLB045
ARLB045 FCC Denies Expert Linears' Request for Waiver of 15 dB Rule, Petition
Pending

The FCC has denied a request by Expert Linears America LLC to waive Part
97.317(a)(2) of the Amateur Service rules limiting amplifier gain. Expert, of
Magnolia, Texas, distributes linears manufactured by SPE in Italy. Its waiver
request, filed in June, would have allowed Expert to import an amplifier
capable of exceeding the current 15 dB gain limitation as it awaits FCC action
on its April petition (RM-11767) to revise the same Amateur Service rules.
That petition remains pending. Expert has asserted that there should be no
gain limitation on amplifiers sold or used in the Amateur Service. Most
commenters supported Expert's waiver request, but a couple of commenters -
including FlexRadio - demurred.

"In light of the conflicting comments regarding the desirability of
eliminating the 15 dB limitation, we conclude that waiving the limitation at
this stage of the rulemaking proceeding would prejudice the rulemaking
proceeding and prematurely dispose of commenters' concerns," the FCC said in
denying the waiver. "Moreover, we agree with FlexRadio that granting Expert's
waiver request while the rulemaking petition remains pending would provide an
unfair market advantage for one equipment model over other manufacturers' RF
power amplifiers that would still be limited by [the existing rules]."

The FCC said it would rather give full consideration to "the pending issues"
and apply the result of the rulemaking proceeding to all Amateur Radio Service
equipment. The Commission said rule waivers "generally" are not warranted
"merely to accommodate technical parameters that are based solely on
harmonization with the manufacturer's products available abroad."

The FCC said a minority of those commenting on the waiver request expressed
concern that eliminating the 15 dB limitation would lead to an overall
increase in power levels, "including transmissions that intentionally or
unintentionally exceed the maximum power limit."

In its April rulemaking petition, Expert maintained 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.

Although the FCC had proposed in 2004 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 limit in the
subsequent Report and Order in that proceeding.

Expert has 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.

The full Report and Order can be found on the web in PDF format at,
https://apps.fcc.gov/edocs_public/attachmatch/FCC-06-149A1.pdf .

NNNN
/EX

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