01 MAR 21
Is a class licence appropriate for amateur radio in Australia? The common issues/opinions/misconceptions are discussed below.
For details on the ACMA proposed changes see:
https://vkradioamateurs.org/rasa-interim-position-on-acma-proposed-changes/
FAQ on the WIA position paper released 24 February 2020:
The proposal states that under the Class licence, the amateur service would now operate under a ‘no interference, no protection’ basis. This is contrary to the status of the amateur service in the Australian Radio Frequency Plan which grants multiple spectrum blocks either ‘EXCLUSIVE’ or ‘PRIMARY’ status.
The spectrum plan (primary/secondary service, etc) and licence type are two separate issues.
Maritime and aeronautical, which operate under class licences, are also assigned Primary status in many sections of the spectrum plan…
Primary status in the spectrum plan has nothing to do with preventing interference to another licenced radiocommunications service if your transmitter is generating spurious emissions, for example.
However, if you are operating in accordance with the technical requirements of the LCD (power, spectral purity, etc.), you are within your rights to continue transmission.
The proposed new LCD clarifies this at 10 (1) on p 7:
A person must not operate an amateur station if its operation causes harmful interference to radiocommunications.
Note that Radiocommunications does not include Broadcasting (TV, radio).
Notwithstanding the above, RASA does not accept our interference protections being withdrawn under a class licence.
The proposed Class Licence wording that amateur stations must not “exceed the general public exposure limits specified in the ARPANSA Standard” requires them to show compliance directly with that Standard, removing the additional conditions afforded Apparatus Licensees. This will substantially increase compliance costs and enforcement risk for the amateur service.
How can this conclusion be drawn? There is no evidence to support this.
Why would ACMA, who intend to reduce regulatory burden on amateurs, require amateurs to produce complex calculations showing compliance with the standard?
Amateurs are required to comply with the ARPANSA standards using the methodology described at http://vkregs.info/electromagnetic-radiation/
There is no evidence to suggest that this arrangement will change under a class licence.
Removal of an individual licence document that identifies the individual operator (and includes the reference to the CEPT T/R61-01 licence), will prevent Australian Amateur Radio operators from using the CEPT international Amateur Radio arrangements when travelling overseas.
AMC would be tasked to produce said document if required under delegation from ACMA, or else ACMA would produce it as required.
Various concerns around transmitter spurious emissions standards, translations of technical requirements (particularly impacting the MF and LF bands) and the handling of secondary spectrum, that further restrict the amateur services.
This is a very sweeping statement…. An A-B comparison of the proposed new LCD and the current one demonstrates that technical conditions themselves have not changed at all.
The arrangement of technical conditions has been changed – for the better. They are much clearer in the proposed new LCD.
The requirements concerning radiated power at LF and MF are exactly the same – they are simply inserted directly into the permitted frequencies, power limits and limitations table (p 10), rather than being detailed in a separate section, as in the current LCD….
General FAQs
Why can’t we keep the present system?
It is clear from the tone of the ACMA document that they wish to move to a class licence. The consultation document is drafted in standard Public Service (not just ACMA) style: point out the disadvantages of the current system, propose an unworkable middle ground option and discuss the advantages of the favoured option.
Moreover, in line with standard Government policy, this is not an issue we get to “vote” on – the consultation is simply a process to enable Option C to go forward. This implies no criticism of ACMA – it is just the way that the Government goes about its business.
The ACMA proposal would have been cleared with the Department of Communications and the Minister prior to publication.
As we said in the interim submission – the pragmatic response is to negotiate with ACMA on a mutually acceptable outcome.
Class licencing will “diminish” AR and turn us into CB
Amateurs require technical qualifications. The CB service does not.
We remain a technical hobby, with access to vast amounts of frequencies (in relative terms) from LF to EHF, regardless of whether we operate under a class or apparatus licence.
Our UK and NZ colleagues effectively operate under a class licence; AR hasn’t been “diminished” in those countries…
Class licensing will lead to type approved equipment and therefore the end of home brewing
For there to be a requirement for type approved equipment, there first needs to be an Australian Standard for ACMA to reference, as per the CB and marine class licences.
Amateur Radio has not and does not use type approved equipment, therefore there are no standards available for ACMA to reference.
A standard would need to be written. By whom? Certainly not by any of the Standards Australia committees….they require resources (i.e. $) to do this. None of the overseas standards bodies would do it for free, either.
Who would provide the funds? It is very unlikely that ACMA would fund a standard, given their stated aim of simplification and less regulation of the amateur sector.
Without a standard, there can be no type approved equipment, and therefore the current home brew arrangements will continue.
Moreover, what would ACMA have to gain from banning home brew…and…how would they enforce it?
Will we lose protection from interference under a Class Licence (Option C)?
Yes. This is why RASA is arguing for the retention of these protection rights should ACMA chose to implement Class Licencing (Option C). Refer our Interim Position paper here https://vkradioamateurs.org/rasa-interim-position-on-acma-proposed-changes/
Under a Class Licence will our bands become mayhem? Pirates and bad behaviour will become commonplace and no-one will police.
We note that ACMA intends to maintain their regulatory role under Option C, quote (p14):
If someone operates an amateur station without holding a recognised qualification or operates the amateur station in a way that is not consistent with the class licence conditions applicable to people holding that level of qualification, they will not be operating in accordance with the class licence and the ACMA may investigate and take appropriate compliance and enforcement action under the Act.
This is effectively a continuation of the current arrangements.
Will ACMA be able to take away our bands under a Class Licence?
ACMA can’t “take away” our primary* allocations. To be realistic, secondary* allocations above 70cm are threatened regardless of our licence type; we are a mainly a secondary service in that part of the spectrum.
ACMA are NOT going to “give our secondary HF allocations away” to Defence, Google or Bill Gates…
Why would they? The amateur HF secondary allocations have been established for many years…and are well utilised.
HF allocations are coordinated internationally via the ITU.
Given the complex process at the ITU, any international moves to threaten our secondary HF allocations would take years, which means that we will have plenty of time to oppose them – as per the recent French proposal for the bottom end of 2m.
In summary: operating under a class licence does not make our allocations any more vulnerable than the current arrangements.
* see https://vkradioamateurs.org/amateur-radio-spectrum-management/
Didn’t we lose 60m due to poor representation? Will it become worse under a Class Licence..
We never had 60m, and we were never going to get it, frankly; the Australian position taken the the World Radio Conference was to oppose the 60m amateur band, principally because of objections from Defence. You can’t lose something you never had.
Will our privileges and examinations change? I want 20m!
The ACMA propose changes to the LCD and licencing arrangements only – there are no changes proposed by ACMA for licence grades, examination arrangements or privileges per grade.
ACMA can arbitrarily impose conditions on us
A class licence does not confer upon ACMA the power to make arbitrary changes without consultation – class licences work exactly the same as apparatus licences in that regard.
Maritime and aeronautical (boat and aeroplane) class licences (class licences using qualified operators) have not had conditions arbitrarily imposed upon them. Any changes are only implemented after sector consultation and discussion. There is no reason to believe that an amateur radio class licence would work any differently.
Under a class licence ACMA can shut you down if you cause TVI!
No, they can’t. If you are operating in accordance with the technical requirements of the LCD (power, spectral purity, etc.), you are within your rights to continue transmission. The proposed new LCD defines this at 10 (1) on p 7:
A person must not operate an amateur station if its operation causes harmful interference to radiocommunications.
Radiocommunications does not include Broadcasting (TV, radio).
If ACMA don’t issue licences, there will be no amateur details in the ACMA database
We would expect that ACMA would require AMC to provide frequent database updates of callsigns issued.
If I have no licence, I can’t apply for things like electronic on line logbooks, E-QSL and DMR ID numbers
As is standard Government practice, we would expect the callsign document to include words to the effect of “issued under the authority of the ACMA”
Why are the WIA and RASA not co-operating on important matters?
RASA has attempted to communicate with the WIA on numerous occasions but has received no response. We are always willing to cooperate with the WIA for the good of VK AR. Why is this not reciprocated? Ask the WIA….
Are the WIA and RASA are being paid to keep quiet so ACMA can take away our bands and privileges?
This is a ridiculous assertion! RASA has not been silenced or paid by anyone. We issue regular bulletins, and you can read our interim response to the ACMA proposals by visiting our web-site.
Is our radio spectrum at risk from US business purchasers?
No, not at all!
I heard that a Class licence will allow AMC to increase their exam fees.
The Deed (contract) between AMC and ACMA has nothing to do with the proposed Class licence…
Why has RASA included “power limits” in its outline statement?
ACMA undertook to include the question of power limits in this LCD review after the May 2019 RASA submission.
Advanced licencees have effectively received no extra privileges since the introduction of the “WARC bands” 30-odd years ago…
Anecdotal evidence is not the same as factual evidence (regarding QRO)
This is true but it is well recognised that some amateurs do break current regulations in many areas but that this has not been recognised by the ACMA as being factual. It is therefore valid for such a statement to be made in a submission so that the basis on which it is made is understood and not overstated in any way.
What about the Intruder Watch system?
It doesn’t work now….it appears that ACMA do not conduct any monitoring of IW complaints….
See https://vkradioamateurs.org/has-the-intruder-watch-system-reached-its-use-by-date/
Changes in call sign structure will cause major difficulties for contesting administrators
Yes, it is true that alternative methods will be required by Australian contest organisers where in the past components of call signs have been used as part of the scoring process. It needs to be noted that other countries have not had an area or region based call sign system for some time and that international contest rules have been adjusted so that, if required, distances or location can be managed in a different manner. Changes will be required but are easily achievable.
Is the Australian Maritime College a profit driven organisation?
The AMC is part of a public University and administers callsign allocation and Amateur Radio exams on a cost recovery basis under a deed with the ACMA.