* The proposed power thresholds for transistors and MMICs in ECCN 3A611 bear no direct correlation to military-specific applications in accordance with the stated intention. By taking the existing frequency and power thresholds under ECCNs 3A001 and 3A982 and converting the power unit of measure to a tighter metric, this rule would have the opposite effect.
* The addition of a power-added efficiency metric to the transistor and
* Telecom infrastructure providers use wide band gap products, such as with a frequency range of DC-18 GHz for backhaul services (telecom providers can take the traffic at a local cell phone tower back to the switchboard by aggregating the calls).
* The proposed power added efficiency thresholds, as a function of bandwidth, bear no logical correlation to the way that discrete microwave transistors and
* The proposed power-added efficiency values start at 30% for the lowest frequency tier, go up to 40%, then go back down to 35% before hitting 30% again. The commenter believes that these thresholds are arbitrary and impractical, and proposes alternatives of 60%, 53%, 45%, 30%, 15%, & 10% for HEMTs and 65%, 57%, 50%, 30%, & 15% for MMICs.
* Saturated peak output power is the most appropriate measure. A peak output power metric would most accurately address potential concern relating to military importance for parts. This unit also would eliminate many of the close-to-the-threshold concerns by providing a more precise measure of power. BIS should adopt peak output power for all ECCNs that apply to discrete microwave transistors and MMICs. In particular, the average power metric should be eliminated from proposed 3A611, 3A001 and 3A982, or at least that term should be clearly defined in a way that corresponds to peak power.
* The commenter expects a surge in demand for discrete microwave transistors with a rated peak power of 120 W in the 3.55-3.65 GHz band (currently used by naval radar systems) because of an
* The commenter recommended that 3A611 exclude discrete microwave transistors and MMICs that are specifically designed for communications in a frequency band allocated by the
* Proposed 3A611 would expand controls on several commercial parts that are, and should continue to be, 3A001 or EAR99. Similar parts are available without license restrictions from UMS (
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