> "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]."
First, there are two proceedings relating to the elimination of the 15 dB
amplification gain restriction: (1) the Petition for Rulemaking filed in
April; and (2) Expert's Waiver Request filed in June. The PRM that
permanently amends the 15 dB gain restriction is still pending with the
Commission. Flex's rationale for the objection to Expert's Waiver Request
is probably reasonable -- although Flex doesn't even have an amplifier
that's ready for certification and thus Flex would not be financially
disadvantaged if the waiver request was granted. So, Flex has no current
standing on the issue but that doesn't diminish the Commission's concerns
while it assesses comments.
A grant of Expert's waiver also creates a potential conundrum: what if the
FCC denies the petition after granting the waiver request to Expert? If the
grant of the petition was merely a short-term formality, then I see no
problem with a waiver grant. In essence, Expert prematurely requested its
waiver. Why would the FCC want to see a quick proliferation of high-gain
amps into the U.S. market, only to later deny the formal petition on the
same issue after full consideration?
Paul, W9AC
ps
_______________________________________________
Amps mailing list
Amps@contesting.com
http://lists.contesting.com/mailman/listinfo/amps
|