AG19
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ARRL Bulletin 19  ARLB019
>From ARRL Headquarters  
Newington CT  May 26, 2016
To all radio amateurs 

SB QST ARL ARLB019
ARLB019 ARRL 'Strongly Supports' Petition to Drop 15 dB Restriction
for Amateur Amplifiers

In comments filed on May 26, the ARRL said it 'strongly supports' a
petition to the FCC seeking to eliminate an Amateur Service rule,
spelled out in Part 97.317(a)(2), that amateur amplifiers not be
able to boost the RF input signal by more than 15 dB. The Petition
for Rule Making (RM-11767), was submitted in April on behalf of an
amateur amplifier distributor, Expert Linears America LLC of
Magnolia, Texas.

ARRL's comments can be found on the web at,
www.arrl.org/news/arrl-strongly-supports-petition-to-drop-15-db-restriction-for-amateur-amplifiers
.  RM-11767 can be found on the web at,
apps.fcc.gov/ecfs/comment/view?id=60001536394 .

'The Petition proposes relief that is in the nature of eliminating
unnecessary regulatory underbrush, and it continues an effort
started by the Commission on its own motion in 2004...to do
precisely that,' the ARRL said in its comments. 'The rule proposed
to be eliminated is outdated; it constituted overregulation when it
was adopted long ago, and it now substantially limits the
flexibility of Amateur Radio operators to experiment with the
current generation of software-defined Amateur Radio equipment.'

The 15 dB provision came into the rules during an era when the FCC
initiated various actions to rein in a major interference problem
resulting from the use of illegal 11 meter amplifiers during the
Citizens Band radio boom of the 1970s. 'In its effort to address
that problem, the Commission enacted a series of largely redundant
and overlapping regulations that, in their overall effect,
unnecessarily (and inappropriately) penalized the wholly innocent
Amateur Radio operators,' the League asserted. 'There was created a
plethora of restrictions on manufacturers of external RF power
amplifiers.'

The ARRL noted that while the FCC eliminated some of the unnecessary
regulations in 2004, others remain, including the 15 dB gain
restriction. The rules adopted in 1978 also called for type
acceptance (certification) of manufactured RF power amplifiers
operating below 144 MHz, including a 50 W minimum drive power
requirement and a ban on amplifiers capable of operation between 24
and 35 MHz.

'Indeed, precisely the same rationale for elimination of the 50 W
minimum drive power rule in 2006 applies to the elimination of the
15 dB gain rule for amateur amplifiers,' the ARRL said in its
comments. 'There is no continued justification for retaining the 15
dB gain limitation.'

The League agreed with the petitioner that a current generation of
low-power Amateur Radio transceivers, including software-defined
designs, cannot drive an amplifier to full legal power given the 15
dB limitation. 'It should not be necessary to configure an Amateur
Radio station to include an additional amplifier stage in order to
make use of current SDR technology in the Amateur Service,' the ARRL
said.