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Re: [Amps] FCC Denies Expert Linears' Request for Waiver of 15 dB Rule

To: "'DavidC KD4E'" <qrv@kd4e.com>
Subject: Re: [Amps] FCC Denies Expert Linears' Request for Waiver of 15 dB Rule
From: "Leigh Turner" <invertech@frontierisp.net.au>
Date: Thu, 29 Dec 2016 08:23:07 +1030
List-post: <amps@contesting.com">mailto:amps@contesting.com>
Hi David,

Well at least the surplus military gear commonly adapted and used by hams
was build to decent performance specs.

Re your "The FCC needs to catch up with noise floor challenges & modern
technology."

Be careful what you wish for here because if the FCC were to address these
challenges and mandate rules for minimum Tx performance specs then most
solid-state rigs and amplifiers would be proscribed due to their lousy /
mediocre IMD performance :-(

It's probably best to leave the sacrosanct ham bands as a free-for-all
anything goes as long as you keep your spectral muck confined within the
designated ham bands... :-)

73

Leigh
VK5KLT

-----Original Message-----
From: DavidC KD4E [mailto:qrv@kd4e.com] 
Sent: Thursday, 29 December 2016 8:04 AM
To: Leigh Turner; 'Charles H'
Cc: 'AMPS'
Subject: Re: [Amps] FCC Denies Expert Linears' Request for Waiver of 15 dB
Rule

I don't get where the notion comes from that commercialization vs home 
brewing is something new to Ham radio.
For at least 75 years commercial & military surplus gear have been a common 
part of our hobby.
Many Hams have interests other than building - they are not lesser Hams.
The FCC needs to catch up with noise floor challenges & modern technology.
IMHO, YMMV ...


On December 28, 2016 5:35:38 AM "Leigh Turner" 
<invertech@frontierisp.net.au> wrote:
>
> I heartily agree Charly.
>
> Sadly there has been an insidious creep in the commercialization of ham
> radio markets for profit and financial gain that coincides with the rise 
> of technically unskilled appliance operators incapable of building their 
> own amplifiers....a tragic situation in what's ostensibly a technical 
> based hobby!
>
> Thankfully savvy and adept homebrewers are free to build and operate
> whatever they please...
>
> Since the IMD specs of these QRO solid-state amps leaves much to be 
> desired it is probably wise of the FCC to limit their proliferation!!
>
> 73
>
> Leigh
> VK5KLT
>
> -----Original Message-----
> From: Amps [mailto:amps-bounces@contesting.com] On Behalf Of Charles H
> Sent: Wednesday, 28 December 2016 8:07 PM
> To: Morel Grunberg; amps@contesting.com
> Subject: Re: [Amps] FCC Denies Expert Linears Request for Waiver of 15 dB
> Rule
>
> Flex co. just lost my support.  I do not like the commercialization of ham
> radio and stories of competing companies, not just Flex, knifing each 
> other.
>
>
> Charly
>
>
> ________________________________
> From: Amps <amps-bounces@contesting.com> on behalf of Morel Grunberg
> <gmorel@netvision.net.il>
> Sent: Wednesday, December 28, 2016 9:05 AM
> To: amps@contesting.com
> Subject: [Amps] FCC Denies Expert Linears Request for Waiver of 15 dB Rule
>
> From ARRL Bulletin:
>
> FCC Denies Expert Linears Request for Waiver of 15 dB Rule, Petition
> Pending
>
> 12/27/2016
>
> The FCC has denied a request by  <http://www.expertlinears.com/> Expert
> Expert Linears America, LLC<http://www.expertlinears.com/>
> www.expertlinears.com
> Expert Linears America, LLC (ELA) is an authorized distributor and repair
> facility of SPE Linear Amps. Bob Hardie W5UQ is SPE factory trained on all
> Expert Linear ...
>
> Linears America LLC to waive §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 (
> <http://apps.fcc.gov/ecfs/comment/view?id=60001536394> RM-11767) to revise
> FCCs Electronic Comment Filing System -
> apps.fcc.gov<http://apps.fcc.gov/ecfs/comment/view?id=60001536394>
> apps.fcc.gov
> Welcome to the FCCs new Electronic Comment Filing System, ECFS 3.0,
> launched June 20, 2016. This system contains the entire history of
docketed proceedings from ...
>
> 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 Experts 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
> Experts 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 manufacturers 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
<https://apps.fcc.gov/edocs_public/attachmatch/FCC-06-149A1.pdf>
> Before the Federal Communications Commission Washington, D
> ...<https://apps.fcc.gov/edocs_public/attachmatch/FCC-06-149A1.pdf>
> apps.fcc.gov
> Federal Communications Commission FCC 06-149 Before the Federal
> Communications Commission Washington, D.C. 20554 In the Matter of
Amendment of Part 97 of the ...
>
> 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.
>
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