Thanks for the informative discourse on the FCC. My intent in my
original posting was to merely test the waters - see if the idea had
any interest or merit. I am building one of the CCI kits
(EB-27A). So this is not a new design approach. I wondered if there
might be interest being able to purchase them assembled. One writer
suggested just offering to assemble them. Probably the easiest
approach. I will not make any decision until I build "my" amp. If
it tests good then I may entertain commercial ideas.
I am not a multi-millionaire industrialist, just a retired
engineer/technician/ham with the interest and ability to build
things. I am QRV 500-KHz to 10-GHz. EME on 144, 432, and 1296. I
keep an eye toward ham business opportunities and this looked promising.
In Free America, it is too bad that a government entity punishes one
segment of society for the gov'ts inability to regulate another
segment. But I can continue to live on SSA and Medicare living below
the poverty level and lobby my congress-person for more handouts
instead of doing free-enterprise. My little rant. Of course that is
not my attitude, and I will not let this stop me.
This probably exhausts this topic so no further replies are required.
Loving my new K3! I will post my progress with the CCI kit on:
signature at bottom of page
Date: Mon, 19 Apr 2010 10:50:36 -0400
From: "Paul Christensen" <[hidden email]>
Subject: Re: [Elecraft] News from Visalia!
To: "Elecraft Reflector" <[hidden email]>
Content-Type: text/plain; format=flowed; charset="iso-8859-1";
The 15 dB gain limitation made more sense when Part 97.317 included a
companion restriction of requiring not less than 50-watts drive power to
attain the amp's rated output power. If a Part 95 user had the wherewithal
to somehow modify a recently manufactured QRP-input type amp, 15 dB still
places a 4W Part 95 transceiver at roughly 140-watts AM, 400W SSB (Part
95.410). Part 97.317(a)(3) already states: "no amplification (0 dB gain)
between 26 MHz and 28 MHz."
I believe the gain restriction could be dispensed with, and the remaining
sections of 97.317 kept intact -- and little detriment would occur.
As to HF amp kits requiring certification, I see no dispositive section in
the CFR that affirmatively compels certification of a kit for use in Part 97
service. Section 97.315 clearly discusses "manufactured and imported"
amplifiers -- kits are not specifically included in the rule. However,
there may be relevant case law on the matter that backs up the CFR -- and
the FCC may have invoked internal policy decisions in the past, but someone
could create an argument that if the FCC had wanted to compel certification
of HF amp kits, they could have easily done so and that requirement should
have been implemented as a matter of procedure under the APA.
The argument can be further bolstered under Part 97.315(a)(1) which states
amplifier certification is not required if: "...the amplifier is
constructed or modified by an amateur radio operator for use at an amateur
station." Does the term "construction" mean home-brew only with parts
secured on-hand and through multiple vendors? Or, does construction also
mean "in kit form," where the parts are consolidated for sale? The question
is then: how does one interpret the exact rule of law?
The "in kit form" term could have been easily defined and included in
Sections 97.315 and 2.815, but it isn't. If the government intends to
prohibit something that's simple to read and interpret, they need to codify
it in a rule and not leave it to guess work. Other means to get the FCC's
position on the matter can take the form of form of a Declaratory Ruling or
73, Ed - KL7UW, WD2XSH/45
BP40IQ 500 KHz - 10-GHz www.kl7uw.com
EME: 144-600w, 432-100w, 1296-60w, 3400-fall 2010
DUBUS Magazine USA Rep [hidden email]
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