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=item33eb0b4a6f:g:wjQAAOSwNNdZ1ToL and http://www.rfamplifiers.com/bbs/download2.php?bo_table=31&wr_subject=HD31619&no=0 . 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

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

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