Thanks, Chris! Hopefully the FCC will move faster than “the speed of government” on this one. ’73 de JIM N2ZZ Director – Roanoke Division Serving ARRL members in the Virginia, West Virginia, South Carolina and North Carolina sections ARRL – The National Association for Amateur Radio™ From: arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Christopher Imlay Sent: Thursday, May 26, 2016 10:11 AM To: arrl-odv Cc: Kutzko, Sean, KX9X; WW1ME Rick Lindquist; Henderson, Dan N1ND Subject: [arrl-odv:25348] RM-11767, Expert Linears America LLC Petition for Rulemaking to Remove the 15 dB limit for external power amplifiers Greetings. I have just now filed the attached comments in support of RM-11767 at the instruction of and with the approval of the Executive Committee. The Petition proposes that the Commission amend Section 97.317(a)(2) of the Amateur Service rules in order to eliminate the requirement that, for a manufacturer of external RF power amplifiers to receive a grant of certification therefor, the the amplifier must not be capable of amplifying the input RF power (driving signal) by more than 15 dB of gain. This petition continues the effort that Bill Cross initiated for us in 2006 in Docket 04-140 which eliminated the 50-watt minimum drive power requirement for amplifiers and modified the ban on amplifiers that exhibited amplification between 24 and 35 MHz. the rule now requires zero amplification between 26 and 28 MHz. But in 2006 FCC left in the 15 dB limit on amplification. Now, that rule makes it impossible for, for example, SDR low power output transmitters to be amplified to full legal power without an intermediate amplification stage added. I am personally very glad to see this proposal; the first Amateur matter I worked on for Bob Booth, W3PS in 1979 was the court appeal of the linear amplifier ban. The FCC overregulated terribly in 1978 and only now is the last major vestige of that being addressed. The Expert Linear petition was prepared by my good friend Jim Talens, N3JT, a PVRC guy, excellent CW man and former FCC staffer. Thanks for timely review and very helpful edits by the entire Executive Committee, and most especially for the good edits from Rick Roderick and Greg Widin. 73, Chris W3KD -- Christopher D. Imlay Booth, Freret & Imlay, LLC 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG