[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 cid:a4a12f0b-0468-4a39-b953-31b2a3da8564 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 -- This email has been checked for viruses by Avast antivirus software. https://www.avast.com/antivirus
No comment on recusal. I will say that I agree fully with Joel. There are several reasons: - CB amplifiers can be easily obtained already. In any case they have no issue whatever with our rules. - Allowing low power drive by removing the 15dB limit has several technical advantages. The first of which is energy and weight savings. An exciter doesn't have to be a big mass of metal anymore and a big power supply doesn't need to be included with the exciter. It can be just that, an exciter, a low level signal into the final, high-gain external PA. I am talking even lower than 5W. Something like +7dBm. This can also have implications for DXpeditions, lessening their load considerably. - One can already obtain a low drive amp, either by importation or modification, both of which are already legal under the rules. I had in my possession at one time such an amplifier. The cost was about the same as ordering from a US dealer. - Other more effective methods to block CB usage already exist, such as firmware locks with encryption keys to block out 26-29MHz with software. This means nobody but a factory authorized servicer can open the amplifier for CB usage. However, I was unaware that this was even under debate still. I thought that it was already commented on and debated? Ria N2RJ On Fri, 26 Jun 2020 at 20:11, Hopengarten Fred <hopengarten@post.harvard.edu> 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] *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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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 Unauthorized Disclosure Prohibited. This e-mail is intended solely for the intended recipient(s) and may contain information that is proprietary, confidential or privileged. If you are not the intended recipient, it is prohibited to disclose, copy, distribute, or use the contents of this email and its attachments. If you received this e-mail in error, please notify the sender by reply e-mail and destroy all electronic and physical copies of the e-mail message and its attachments. Unintended transmission shall not constitute waiver of attorney-client or any other privilege. Thank you. 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 [cid:image002.png@01D64C0B.0534B5A0] 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 [Image removed by sender.]<https://www.avast.com/sig-email?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=emailclient&utm_term=icon> Virus-free. www.avast.com<https://www.avast.com/sig-email?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=emailclient&utm_term=link>
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
cid:a4a12f0b-0468-4a39-b953-31b2a3da8564
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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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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" 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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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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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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I have to chime in on this issue as I spent much of my career at Rockwell Collins designing high power HF amplifiers for commercial & military applications besides being an active ham for 60 years (as of this month). If we go back to my early days of ham radio (shortly after the earth cooled and guys like Faraday, Hertz, and Marconi gave us radio) the region of 27 MHz was the 11-meter ham band. The FCC removed it from the amateur service and put it in a new class of Citizen Band. It was 5 Watts of AM as I recall. It wasn't long before the numbers of CB operators literally exploded and along with it all kinds of illegal operations including high power, dxing, no licenses, "free-banding", etc. Things got completely out of control as the FCC did not have the resources for effective enforcement. So a quick "fix" was to change the AMATEUR SERVICE RULES to limit amplifiers covering 26 to 28 MHz to 0 dB gain (effectively removing the 10 meter band from ham amplifiers) and 15 dB gain for amplifiers operating 144 MHz and below. So in effect, the mostly law abiding amateurs suffered in the FCC's quest to mitigate the CB problems they started. I, too, think it's long over-due to correct this 1978 "error" and permanently get rid of BOTH the amplifier gain restriction AND the 26-28 MHz "block". Today there are several techniques for greatly improving the linearity of the transmitted signal. These techniques are much easier (and economical) to implement in modern transmitter designs if these restrictions are removed. And we can all benefit from cleaner signals on today's ham bands. My opinion..... 73's, Rod, K0DAS On Sat, Jun 27, 2020 at 10:11 AM 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
<https://www.avast.com/sig-email?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=emailclient&utm_term=icon> Virus-free. www.avast.com <https://www.avast.com/sig-email?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=emailclient&utm_term=link> <#m_-1011884709090526186_m_-3012033314401180050_DAB4FAD8-2DD7-40BB-A1B8-4E2AA1F9FDF2>
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participants (6)
-
Dale Williams -
david davidsiddall-law.com -
Hopengarten Fred -
Mickey Baker -
rjairam＠gmail.com -
Rod Blocksome