AG15
QST de W1AW  
ARRL Bulletin 15  ARLB015
>From ARRL Headquarters  
Newington CT  April 28, 2016
To all radio amateurs 

SB QST ARL ARLB015
ARLB015 FCC Invites Comments on Petition to Eliminate 15 dB Gain
Limit on Amateur Amplifiers

The FCC has put on public notice and invited comments on a Petition
for Rule Making (RM-11767), filed on behalf of an amateur amplifier
distributor, which seeks to revise the Amateur Service rules
regarding maximum permissible amplifier gain. Expert Linears America
LLC of Magnolia, Texas, which distributes linears manufactured by
SPE in Italy, wants the FCC to eliminate the 15 dB gain limitation
on amateur amplifiers, spelled out in Part 97.317(a)(2). Expert
asserts that there should be no gain limitation at all on amplifiers
sold or used in the Amateur Service.

RM-11767 can be found on the web at,
apps.fcc.gov/ecfs/comment/view?id=60001536394 .

'There is no technical or regulatory reason [that] an amplifier
capable of being driven to full legal output by even a fraction of a
watt should not be available to Amateur Radio operators in the
United States,' Expert said in its Petition.

Expert maintains that the 15 dB gain limitation is an unneeded
holdover from the days when amplifiers were less efficient and the
FCC was attempting to rein in the use of Amateur Service amplifiers
by Citizens Band operators. While the FCC proposed in its 2004
Notice of Proposed Rulemaking and Order in WT Docket 04-140 to
delete the requirement that amplifiers be designed to use a minimum
of 50 W of drive power and subsequently did so, it did not further
discuss the 15 dB amplification limit in the subsequent Report and
Order in the docket.

The R&O is in PDF format at,
https://apps.fcc.gov/edocs_public/attachmatch/FCC-06-149A1.pdf
.

'Although no party advocated retention of the 15 dB limit, it
remains in place today,' Expert pointed out in its filing. 'In the
intervening years, advancements in Amateur Radio transmitter
technology have led to the availability of highly compact,
sophisticated low-power transmitters that require more than 15 dB of
amplification to achieve maximum legal power output. Therefore,
Expert seeks to remove the 15 dB limit from Part 97.317 so that
Amateur Radio manufacturers and distributors will not be forced to
needlessly cripple their amplifiers for sale in the United States.'

Expert pointed to its Model 1.3K FA amplifier as an example of a
linear 'inherently capable of considerably more than 15 dB of
amplification,' which would make it a suitable match for low-power
transceivers now on the market having output power on the order of
10 W.