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FCC Denies Expert Linears' Request for Waiver of 15 dB Rule:

from The ARRL Letter on January 5, 2017
View comments about this article!

FCC Denies Expert Linears' Request for Waiver of 15 dB Rule, Petition Pending:

The FCC has denied a request by Expert Linears America LLC to waive 97.317(a)(2) of the Amateur Service rules limiting amplifier gain. Expert, of Magnolia, Texas, distributes linears manufactured by SPE in Italy. Its waiver request, filed in June, would have allowed Expert to import an amplifier capable of exceeding the current 15 dB gain limitation as it awaits FCC action on its April petition (RM-11767 to revise the same Amateur Service rules. That petition remains pending. Expert has asserted that there should be no gain limitation on amplifiers sold or used in the Amateur Service. Most commenters supported Expert's waiver request, but a couple of commenters -- including FlexRadio, which supports a rule change -- expressed concerns about granting a waiver to Expert alone.

"In light of the conflicting comments regarding the desirability of eliminating the 15 dB limitation, we conclude that waiving the limitation at this stage of the rulemaking proceeding would prejudice the rulemaking proceeding and prematurely dispose of commenters' concerns," the FCC said in denying the waiver. "Moreover, we agree with FlexRadio that granting Expert's waiver request while the rulemaking petition remains pending would provide an unfair market advantage for one equipment model over other manufacturers' RF power amplifiers that would still be limited by [the existing rules]."

The FCC said it would rather give full consideration to "the pending issues" and apply the result of the rulemaking proceeding to all Amateur Radio Service equipment. The Commission said rule waivers "generally" are not warranted "merely to accommodate technical parameters that are based solely on harmonization with the manufacturer's products available abroad."

In its April rulemaking petition, Expert maintained 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.

Although the FCC had proposed in 2004 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 limit in the subsequent Report and Order in that proceeding. Read more


The ARRL Letter

Member Comments:
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FCC Denies Expert Linears' Request for Waiver of 15 dB Rule:  
by ZENKI on January 5, 2017 Mail this to a friend!
The FCC has the ability to make a law to restrict the gain of an amplifier but seem unable to make a law that prohibits the sale of amplifiers like the SPE that has terribly poor IMD that causes interference.

Gain is not the issue today on the bandw but poor IMD is the issue of much greater importance. The FCC should introduced mandated IMD laws as required by ITU regulations which applies to all commercial HF equipment.

If there was a a mandated FCC IMD standard the SPE Amplifier would have failed on the gain rules as well as the IMD rules.

I dont really agree with the FCC's rejection of the SPE request for a waiver. Eliminating this rule would have produced cheaper and cleaner transmitters and amplifiers.

Why not have a ultra clean 1 watt transmitter that can drive a HF PA that can deliver anything from 100 watts to 1500 watts of clean output.

It could have meant a new generation of transceivers that were clean, did not need a filthy 12 volt poor IMD PA and would have eliminated a heavy 12 volt power supply. It would also have mode possible smaller mobile radios with an associated high gain amplifier.

This platform could have been achieved with a autotune tetrode amplifiers or even a LDMOS Amplifiers which has proper IMD specifications and technologies like pre-distortion.

The Gain rule can easily be fixed by SPE but what cant be fixed by SPE is their horrendous IMD from their amplifiers which are not much better than illegal class C CB amplifiers.

SPE should improve the IMD performance of their amplifiers. I have spoken to the owner of SPE about their IMD problem, they are not interested in producing amps with better IMD performance that was made very clear to me. Their head is buried in the sand in regard to the issue of poor IMD of their products. They dont have the engineering skills or money to design a clean amplifier. So while there poor products sell like hotcakes they dont care about selling filthy amplifiers to the ham radio market.

When a company cant be professional about the engineering standards of its products is willing to sell product that cause more harm than good to engineering standard they dont deserve a free reign in the market that disadvantages other competitors.
RE: FCC Denies Expert Linears' Request for Waiver of 15 dB R  
by STRAIGHTKEY on January 5, 2017 Mail this to a friend!
You have some actual measurements or are you just talking out your butt? Probably the latter since you didn't post any specifics.
RE: FCC Denies Expert Linears' Request for Waiver of 15 dB R  
by ZENKI on January 6, 2017 Mail this to a friend!
Specifics and IMD figures of the SPE are well documented.

Why dont you demonstrate your expertise and post your data that proves that the SPE is such wonderfully clean amplifier as you would like it to be in your imaginary world.

The measured data that demonstrates that the IMD is poor is out there. You provide the data that says otherwise?

You can tell lies if you want, I suppose the manufacturers data for the IMD figures can cut through any lies that you want to tell to defend your newly purchased toy.

The measured numbers dont tell lies, unlike non technical people who have no understanding of what the data means. Only a cb'er or an ignorant person would want to misrepresent what the measured data is telling us. The IMD suppression is terrible those are the facts.
RE: FCC Denies Expert Linears' Request for Waiver of 15 dB R  
by STRAIGHTKEY on January 6, 2017 Mail this to a friend!
You made the claims, not me. The burden is on you to provide evidence to back up your claim, not me to disprove it.
RE: FCC Denies Expert Linears' Request for Waiver of 15 dB R  
by KD6VXI on January 7, 2017 Mail this to a friend!
Actually, he made a claim that is well known. It is documented, by the ARRL and others. It's also well documented by the myriad of amateurs that live near one of the SPE IMD flamethrowers.

No, it's not up to anyone to provide documentation. Eham is not a peer reviewed journal, not a trade magazine and never purported as such.

You are arguing with him. As such, it's up to YOU to disprove him. Not be a pedantic ass and start telling someone else they need to back their claims up because you call foul.

Wanna call foul, prove him wrong.

Even SPE documentation of the 1.3 shows sub minus 30 db imd.

This. Means the guy running a kilowatt of spe power without predisposition now is running 5 watts of splatter.

Ask any dedicated qrp guy what 5 watts will do!

SPEs own testing shows their amps are crap.
RE: FCC Denies Expert Linears' Request for Waiver of 15 dB R  
by KD6VXI on January 7, 2017 Mail this to a friend!
Sorry for the couple typos. Android keyboards on the smartphone trying to outsmar me!
RE: FCC Denies Expert Linears' Request for Waiver of 15 dB R  
by STRAIGHTKEY on January 7, 2017 Mail this to a friend!
All Icom radios are crap. Well known fact. Prove me wrong.
FCC Denies Expert Linears' Request for Waiver of 15 dB Rule:  
by W8ASA on January 11, 2017 Mail this to a friend!
Now, now, kiddies. Please be nice to each other. How about if the original OP gives us some direct links to what he's claiming? Let those links speak for themselves so we can avoid the bashing.

Direct links to SPE testing results would also help. Let us read the information and test results, not just the claims.


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