And a more detailed response from Steve Hicks, N5AC (CTO): I'd like to rewind a bit here and make sure everyone understands what happened: 1. First, Expert Linears filed a Petition for Rulemaking on April 7, 2016 which was assigned RM-11767 <https://www.fcc.gov/ecfs/filing/60001536394/document/60001569485> by the FCC. This petition sought to remove the 15dB gain limit on HF amplifiers. 2. FlexRadio filed support <https://www.fcc.gov/ecfs/filing/60001982321/document/60002090299> for this petition on June 1, 2016. All good so far! 3. While I can't specifically comment on why, Expert apparently did not want to wait for the NPRM and filed a request for waiver <http://transition.fcc.gov/Daily_Releases/Daily_Business/2016/db1227/DA-16-1450A1.pdf> of the rules and was assigned WT Docket number 16-243. The process and explanations for why you would file a waiver can be found here <https://www.law.cornell.edu/cfr/text/47/1.925>. Note that in order to request a waiver, you must meet this legal hurdle (verbatim from 47 CFR § 1.925 (b)(3)): *The Commission may grant a request for waiver if it is shown that:* *(i) The underlying purpose of the rule(s) would not be served or would be frustrated by application to the instant case, and that a grant of the requested waiver would be in the public interest; or * *(ii) In view of unique or unusual factual circumstances of the instant case, application of the rule(s) would be inequitable, unduly burdensome or contrary to the public interest, or the applicant has no reasonable alternative.* Because Expert Linears are already selling their amplifiers, modified, in the USA, along with every other manufacturer, there is nothing inequitable, burdensome, etc. about the rules. ALL amplifier manufacturers are following the rules in unison today. The applicant not only had a reasonable alternative to requesting a waiver, they were currently exercising it (limiting the gain). Just like everyone else. 4. The FCC requested <https://www.fcc.gov/ecfs/filing/072910655488/document/07291065548894cb> public comments to this waiver on July 29, 2016 with a cut-off date of September 13, 2016 5. FlexRadio does not support one manufacturer (Expert) having an advantage over all other manufacturers including Icom, Yaesu, OM Power, Elecraft, FlexRadio Systems, etc. We filed comments in opposition <https://ecfsapi.fcc.gov/file/10801058839144/Comments%20to%20FCC%20on%20WT%20docket%20No%2016-243%20Stephen%20Hicks.pdf> to the waiver on August 1st. I was frankly a little miffed to have to spend time writing comments in opposition to something that I think a manufacturer shouldn't file in the first place -- a request for an personal waiver to the rules that everyone else is following, but would like removed, after already requesting this in a Request for Rulemaking. I do, however, commend Expert Linears for taking the time, energy and funding to request the Rulemaking in the first place. 6. After FlexRadio filed comments, Expert doubled-down in new comments <https://www.fcc.gov/ecfs/filing/109131505615016/document/1091315056150165763> on August 26, 2016, stating again that an immediate waiver of the rules should be granted to Expert 7. The FCC reached an independent decision <https://ecfsapi.fcc.gov/file/12270924300990/DA-16-1450A1.pdf#viewer.action=download> on December 23, 2016, relying in part on comments from all concerned, and the decision aligned with FlexRadio's position. In short, the waiver was denied. RM-11767 is still before the FCC and will be ruled on in due time. Again, *FlexRadio System's official position is that we support removal of the 15dB limit*. But it should be removed for all manufacturers in due course of the FCC's normal business (as was stated in our comments to the waiver). I encourage all of you that would like to understand how the FCC does business to read the well-considered decision from the FCC as well as all of the petitions and comments referenced in this note chronicling the process. On Sat, 27 Jun 2020 at 11:46, rjairam@gmail.com <rjairam@gmail.com> wrote:
See additional information from Gerald Youngblood, K5SDR, CEO of FlexRadio.
https://community.flexradio.com/flexradio/topics/fcc-denies-expert-linears-r...
"
*We DO NOT want them to maintain the 15 dB rule*, which is completely antiquated and unnecessary. Our new PowerGenius XL amplifier design already supports the ability to amplify milliwatts to kilowatts internally so it is not a technology issue for us. We have to attenuate the signal on the input of the amplifier in order to reduce 50W down to milliwatts to stay within the current rules just the same as the petitioner does.
FlexRadio 100% supports the original FCC request for comment to change the rules permanently for *ALL *manufactures of amplifiers - not just one. That would provide a level playing field for everyone making an amplifier in today's market.
The following is from the FCC Order with my emphasis added:
"The other, *FlexRadio Systems (FlexRadio), supports the proposed rule change* but argues that granting Expert’s waiver request while the rulemaking remains pending would unfairly advantage one manufacturer over others and be contrary to the public interest."
We would like the 15 dB rule lifted for our products and our competitors products at the same time. Otherwise every manufacturer has to individually go through the waiver process.
Isn't that fair and reasonable?
On Sat, 27 Jun 2020 at 11:44, rjairam@gmail.com <rjairam@gmail.com> wrote:
" I can understand why manufacturers who have invested in a certification effort for their amplifiers would oppose dropping this rule. It opens them to more competition and lower profit margins. "
FlexRadio's specific opposition to this was for the waiver that would be granted only to Expert Linears America (ELA) allowing them to sell the non-US versions of the LDMOS SPE 1.3K-FA (and its successors). In my conversations with Flex and 4O3A engineering teams, they want the low drive capability but want it to apply across the board to all amplifiers on the market, rather than allowing ELA to have an unfair advantage.
I own of the first PGXL amplifiers delivered in the US (Serial #7) and had a hand in its product development in 2017 when it was first announced. Changing the drive level is a matter of a software switch controlled by the amplifier firmware. My initial beta test amp had its drive levels adjusted many times by software as the amp was refined, often for safety reasons (a smoke filled shack is not fun, ask me how I know!) So when this rule is dropped, a firmware update will enable low drive operation. For existing owners this would likely fall under a modification which we can do under part 97 rules so it wouldn't require recertification (Dave Siddall can correct me if I'm wrong.)
Furthermore, the low drive version of the 1.3K-FA was never FCC certified. They would have the same certification requirement as all other manufacturers if the rule was lifted.
I am not intimately familiar with what other manufacturers have said. Most commenters opposing the rule change seem to be concerned that this will encourage more hams to operate high power. This is not relevant to this petition anyway as most tube amplifiers are cheaper than LDMOS and this rule change by itself wouldn't open the flood gates to high power operation.
Ria N2RJ
On Sat, 27 Jun 2020 at 11:11, Mickey Baker <fishflorida@gmail.com> wrote:
I'm not an expert on the legal requirements for recusal, but I've had an opinion on this for quite some time. I appreciate Director Hopengarten bringing this to the group.
This rule has done little to actually reduce the availability of low drive, high gain amplifiers available to the Citizens Band service, for example: https://www.ebay.com/itm/Linear-Amplifier-HF-3000-Watt-PEP/222986717807?hash... and http://www.rfamplifiers.com/bbs/download2.php?bo_table=31&wr_subject=HD31619... . Citizen Band operators run as much power as they wish and, as we know, there is little to no enforcement.
The availability of amplifier pallet configurations has changed the landscape, but the amateur community does not benefit from this change because of this rule. Law abiding amateurs who understand issues like purity of emission are hesitant to experiment with these devices because they are not apparently in use in the marketplace in the US in commercial amplifiers. Current semiconductor packages provide high gain and exceptional purity and this rule is constraining innovation for the amateur service in the US.
In fact, some amplifiers available in the rest of the world are simply modified for the US market to require more input power by the use of a "pad" in the input circuit to require higher drive. The requirement to obtain this certification on a completed amplifier results in grey market imports, increase costs and the mechanism of creating "kits" for amateur completion of amplifiers.
Most of the new transceivers coming on the marketplace from offshore, like the Xiegu family, only have 20 watts or less output.
I can understand why manufacturers who have invested in a certification effort for their amplifiers would oppose dropping this rule. It opens them to more competition and lower profit margins. I can understand why they would want the drive requirements kept high when their flagship products will easily drive amplifiers which require 40-50 watts drive. But if you examine the circuits of most of the current certified solid state amps, a simple modification would enable driving them at much lower powers.
*All that said, I believe that it is ARRL's duty to remove constraints that no longer make sense technologically when doing so would lead to a lower financial barrier of entry to the radio amateur, and, perhaps more importantly, encourage innovation. *
*I support dropping this requirement and I encourage my fellow directors to consider doing so as well, particularly in light of the recommendation of W1ZR. This would be a welcome action for the newer amateur who is building a station.*
73, off to Field Day,
Mickey Baker, N4MB Palm Beach Gardens, FL *“The servant-leader is servant first… It begins with the natural feeling that one wants to serve, to serve first. Then conscious choice brings one to aspire to lead." Robert K. Greenleaf*
On Fri, Jun 26, 2020 at 11:23 PM Dale Williams <dale.wms1@frontier.com> wrote:
Fred,
I introduced this to the Board a couple of years ago. It was decided that because ARRL had no skin in the game we would not request action by the FCC directly, but instead support an amplifier manufacturer who would make such a request of the Commission. That took place and ARRL offered supporting comments.
The FCC has not acted to date.
73
Dale Williams WA8EFK
On 6/26/2020 8:11 PM, Hopengarten Fred wrote:
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 <k1vr@arrl.org>*
New England Director
[image: cid:a4a12f0b-0468-4a39-b953-31b2a3da8564]
Serving ME, NH, VT, MA, RI and CT
*From:* Hallas, Joel W1ZR [mailto:jhallas@arrl.org <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
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