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

To: Leigh Turner <invertech@frontierisp.net.au>, "'Charles H'" <k4vud@hotmail.com>
Subject: Re: [Amps] FCC Denies Expert Linears' Request for Waiver of 15 dB Rule
From: DavidC KD4E <qrv@kd4e.com>
Date: Wed, 28 Dec 2016 16:34:11 -0500
List-post: <amps@contesting.com">mailto:amps@contesting.com>
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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