Fred et al,
Joel may not be aware that in 2016 Expert Linears petitioned the FCC to delete the rule. (Through counsel N3JT.) ARRL has supported the request for deletion at every opportunity,
from then to now, including as recently as in late March when we briefed the relevant staff on pending amateur proceedings and issues.
Expert also asked for a waiver. FlexRadio (and Nick Leggett) opposed the waiver. The Commission cited those oppositions in denying the waiver, saying that given the opposing
comments, the issue is more appropriately considered in a future rulemaking proceeding.
Since that time (late 2016), the ARRL repeatedly has expressed support for deletion of this rule. See our latest FCC staff briefing in late March, extract attached. I expect
(hope) that this petition will be included in a rulemaking soon. But since Scot Stone left last December there have been discussions, some internal meetings (I am told) and some drafting, but nothing has actually moved forward into the decisional pipeline.
I do talk with Scot’s replacement regularly about status to try to move things. But Scot’s absence and COVID-19 have not helped, that’s for sure. And increasingly, FCC staff is turning to housekeeping matters as their entire offices are moving across town
as soon as the pandemic permits.
FCC headquarters staffers still have not returned. They continue to work from home. (The D.C. area is still pretty high in numbers, although very slowly decreasing.)
Enjoy Field Day everyone.
73, Dave
David R. Siddall
Managing Partner
DS Law, PLLC
1629 K St. NW, Ste 300
Washington, DC 20006
direct: +1 202 559 4690
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From: arrl-odv <arrl-odv-bounces@reflector.arrl.org> on behalf of Fred Hopengarten <hopengarten@post.harvard.edu>
Reply-To: Fred Hopengarten <hopengarten@post.harvard.edu>
Date: Friday, June 26, 2020 at 8:11 PM
To: 'ODV' <arrl-odv@reflector.arrl.org>
Subject: [arrl-odv:30471] FW: Suggested ARRL Position on FCC Amplifier Power Limit
To the Board:
W1ZR, see below, thinks we should chime in on the amplifier gain rule. I believe he’s talking about the petition filed by N3JT on behalf of (perhaps it was) an
Italian amplifier manufacturer.
Full disclosure, N3JT has been co-counsel with me in a couple of cases when I was ill a few years back and is a close friend. He has also been VERY helpful w/r/t
the drafting of our AREPA bill.
As I recall, the original rule was designed to dampen the market for 5 watt to 500 watt-1KW CB amplifiers.
Should I recuse myself? Should ARRL adopt the Joel Hallas, W1ZR, position? Is this a Board matter? Or does it go to PSC?
Fred Hopengarten, Esq. K1VR
Six Willarch Road
Lincoln, MA 01773
781.259.0088, k1vr@arrl.org
New England Director
Serving ME, NH, VT, MA, RI and CT
From: Hallas, Joel W1ZR [mailto:jhallas@arrl.org]
Sent: Thursday, June 18, 2020 1:30 PM
To: Hopengarten, Fred, K1VR, (Dir, NE)
Subject: Suggested ARRL Position on FCC Amplifier Power Limit
Fred,
I think it is time to push the FCC to drop its rule about amplifier gain.
I believe that the current limitation of a max gain of 13 dB no longer serves a purpose and results in lower performance of amplifiers, and thus excessive size, weight
and cost of amateur equipment.
Any thoughts?
Thanks.
GL & 73, Joel
Joel R. Hallas, W1ZR
Contributing Editor,
QST
ARRL, The National Association for Amateur Radio
