Can we justify more bands?

The WIA recently published their response to the ACMA five Year Spectrum Outlook (FYSO).

RASA’s view is that, in the current environment, any expansion to existing amateur allocations in Australia is highly unlikely.  Indeed, we would suggest that there is no justifiable demand for additional allocations (other than 5MHz).

On this basis, RASA offers the following comments on the WIA submission (WIA sections in red).

2.1.1 HF Spectrum Demand

Global demand for HF amateur spectrum has grown, particularly since the start of the COVID pandemic.

Congestion (particularly on the 7MHz band) from both legitimate and unauthorised illegal transmissions is often severe during times of increased ionospheric propagation.

Additionally, heightened tensions across the globe have increased the use of high-power HF radar systems which frequently disrupt HF amateur communications across large segments of spectrum, particularly on the lower frequency bands. Increasing spectrum access within the 3-10MHz range is seen as vital to enable sufficient frequency agility for the amateur service, so that communications can be maintained when large amounts of spectrum are suffering interference from international radar based intruders.

The WIA intends to seek expansions to amateur bands in the 3-12MHz segment over the next 5 years for Australian amateurs, at least in alignment with international allocations, although the WIA acknowledges that this is a lower priority than other items proposed.

Comments

Large sections of the 7 MHz band are quiet, especially during the day, even on weekends.  There is ample space available at peak usage times around late afternoon/early evening. 

7200-7300 kHz is little used…. 

It is rare to hear more than one SSB conversation on the 10 MHz band during the day.  Of course, the digital segment around 10136 kHz is very busy with FT8 stations…but that is only 3 kHz wide.

In general, the 40 and 30m bands are not particularly busy.  Whilst there is some interference from Over The Horizon Radar, it certainly can not be classed as “harmful”* in the ITU sense.

Can we expand our allocations between 3 and 12 MHz?

80m – 3500-3700 and 3776-3800 kHz

As we have discussed previously, there are thousands of Australian commercial assignments from 3700-4000 kHz.  As already confirmed by ACMA, there is no possibility of an expansion of 80m in the foreseeable future.

40m – 7000-7300

Australian amateurs already have access to the entire Region 3* allocation of 7000-7300 kHz.  We don’t fully use what we have.

30m – 10100-10150 kHz

Again, we have access to the entire Region 3* allocation, and we are able to use voice modes….a privilege denied to our overseas colleagues.

We could increase our allocations through either the granting of an extension to the 40 and/or 30m bands and/or the establishment of new bands.   However, this can only be accomplished at an ITU World Radio Conference….and this is a long, drawn out process* that will take at least a decade, if not longer.

So, as it stands, even if ACMA wanted to give us more bands, they can’t.

2.1.2 UHF/SHF Spectrum Demand

The Wireless Institute seeks to draw attention to the ongoing disruption caused to the amateur service by spectrum reallocation activities.  The amateur service has faced a significant reduction in access to UHF spectrum over the past 10 years.

In total, 318MHz of spectrum has been withdrawn in the 420, 576, 2300 and 3400MHz bands across much of Australia.  This represents a loss of over 42% of available spectrum to the amateur service.  If the impact of LIPD transmissions on spectrum usability is also considered, a further 250MHz of spectrum has been degraded in many areas, particularly on the 433 MHz, 2400 MHz and 5700 MHz bands.

The overall impact has been a net 76% reduction in usable spectrum in many locations across Australia for many types of amateur service communications.

The most affected activities to date have been wideband Amateur Television services.  Many television repeater stations have faced multiple spectrum withdrawals, resulting in repeated replanning, service reconstruction, or in some cases the cessation of ATV activity in an area.

The WIA requests that future spectrum reallocation discussions give due consideration to maintenance of sufficient amateur spectrum, so activities such as amateur television can continue to operate with a level of certainty.

Comments

As we know, spectrum above 70cm is fantastically valuable.  The ACMA recently auctioned spectrum for 5G mobile services in the 26 GHz band.  The auctions generated $647M in revenue.

The amateur service has Secondary status in all of the UHF and SHF bands identified by the WIA. 

Our Secondary status, combined with our very low levels of utilisation means that we can no longer justify large UHF/SHF frequency allocations in bands where we are a Secondary service (i.e. most bands above 2m…).

We acknowledge that this is unwelcome news, but it is the reality, unfortunately.

Alas, there is no room for sentimentality in UHF and SHF spectrum planning.  There is simply too much money at stake.

Extension of operating privileges for AOCP(S) class licensees to include access to the 50-52 MHz band.

RASA has actively lobbied ACMA for access to 50-52 MHz by standard class amateurs since 2019.  This is reflected in our submission to the recent ACMA consultation on licencing.

We are pleased the see that the WIA supports our position.

Primary status 7100-7200 kHz

The WIA requests the ACMA conduct a further review of the defined usage of 7100-7200 kHz in the Australian Radio Spectrum Plan.

Noting the proposed changes already being made to withdraw Broadcasting as a defined use of the 7100-7200kHz band in the draft 2021 spectrum plan, the WIA seeks to open discussions with ACMA on how the fixed and land mobile use could also be withdrawn from the band, elevating the amateur service to PRIMARY status in Australia. (The WIA notes that there is currently only one scientific licence assigned in this segment).

RASA raised this anomaly with the ACMA some time ago.  We support this change, although we understand that the ACMA no longer allocate fixed and mobile services in this band. 

Conclusion

As we have said in numerous articles, amateurs need to apply a pragmatic approach to our spectrum and the relationship with ACMA.  We can’t just put a submission to ACMA asking for more bands with no reasoned justification.

ACMA use professional automated radio monitoring systems to inform their decisions on spectrum management.  They understand the utilisation of various bands very well.

Bland, unjustified statements to the regulator that “use has increased” are simply not sustainable in a modern spectrum management environment.

Such claims serve only to diminish AR’s reputation with the regulator.

What amateurs need are facts, not spin and false hope.

RASA will continue to lobby the WIA for a more collaborative approach to sector communication with the ACMA.  Indeed, at least two WIA Directors have indicated a willingness to open a line of communication.

As always, we welcome feedback and questions.

*For more information on ITU issues, see

https://vkradioamateurs.org/amateur-radio-spectrum-management/ and

https://vkradioamateurs.org/inside-the-itu/

The Radio Amateur Society of Australia

07 May 2021

PS Get on the air….!