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   
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    * Origin:  (1:3634/12.73)