Thank you to all our members and non-members who commented on our interim position paper on the ACMA consultation. We have consolidated your comments into a final response which has been submitted to ACMA today.
We aren’t going to ask you to send a form letter of support to ACMA. Such letters are routinely ignored by Government.
If you like our submission, by all means communicate this to ACMA. It is up to you.
We are pleased to see that the WIA support our ideas on interference resolution, repeater assignment and a cross-sector committee.
Finally, the amateur radio sector is (almost) united….
Mr. Nicholas Brody
Spectrum Licensing Policy Section
Australian Communications and Media Authority
Dear Mr. Brody,
RESPONSE TO ACMA CONSULTATION PAPER ON AMATEUR LICENCING ARRANGEMENTS
This submission is the result of an extensive consultative process within the Amateur Radio sector. An interim submission and a Frequently Asked Questions document were prepared and circulated widely via email bulletins, social media, the RASA website and the RASA magazine QTC.
We received numerous comments and suggestions from the sector, which were integrated into this final document. This submission thus represents the position of RASA and a large number of licensed amateur radio operators throughout Australia.
ACMA’s preferred option
We recognise that ACMA’s preferred option is C, and that this is driven by Australian Government policy on outsourcing and reduction of regulation.
Protection from interference
The principal issue of contention with Option C is the proposal that, under a class licence, amateurs would operate on a “no interference, no protection” basis.
It is our view that ACMA, as managers of the RF spectrum, have a responsibility to ensure that spectrum users can properly coexist, regardless of what licence fees they do or do not pay or what class of licence they operate under.
We acknowledge that ACMA field staff resources have been severely rationalised and therefore that it will not be possible for an ACMA Radio Inspector to physically attend amateur radio related interference complaints.
It is reasonable to require amateur radio operators, as technical practitioners, to investigate and, as far as possible, resolve interference problems themselves.
However, ACMA must retain final responsibility for oversight of amateur radio interference issues.
We propose that, as with the current system, amateurs deal with interference issues themselves, by following a logical, documented process, such as that detailed at https://qrm.guru/category/an-overview-of-the-qrm-guru-process/
If the amateur has taken all reasonable steps to resolve the interference to/from their station, and the problem persists, ACMA should be called upon to provide an impartial resolution of the issue by email.
Deliberate amateur-amateur interference and illegal operation is another area where ACMA must retain a regulatory role. Most interference of this type will cease with the application of common sense (i.e. don’t feed the troll…), but there are some rare examples where the interference is harmful and ongoing, and the only path to resolution involves regulatory action.
We note that ACMA intends to maintain this 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.
The Class Licence
The proposed new class licence is relatively simple and much less restrictive than the current LCD.
We suggest that, with the aim of simplification, Schedule 3 – Emission modes could be deleted, or else reference made to Vol 2 Appendix 1 of the Radio Regulations, which defines emission modes in detail. Similarly, Section 2 on exclusion areas could be referenced to another document; it impacts relatively few amateurs and takes up a large amount of space in the document.
Schedule 1, tables A, B and C (p 10) use the term “maximum power spectral density” in relation to bandwidth. The term is not referenced in the Definitions (p 2) and the method of measurement is not specified. This anomaly needs to be rectified.
Ongoing sector liaison with ACMA
There needs to be a mechanism for sector representatives to meet with ACMA on a scheduled basis (perhaps biennially) to discuss sector issues – experience has proven that the current ad-hoc system is not effective.
To this end, it is proposed that a sector representative committee be constituted, and that it includes AMC, as the ACMA’s outsourced provider. AMC could possibly provide the chair.
Amateur operating procedures document
We note that ACMA are proposing moving non-mandatory conditions to an operating procedures document. It is further proposed that this be managed by the amateur community in the future. The logical way to update such a document would be to use the sector representative committee discussed previously.
Publicly available callsign database
If Option C is implemented, we assume that ACMA will maintain the current on-line public callsign database or some similar arrangement.
Licencing document for amateurs travelling overseas
We also assume that ACMA (or AMC under delegation) will produce some form of amateur licence document for amateurs travelling overseas – stating equivalence with CEPT T/R 61-01/2.
Output power for advanced licensees
One issue that is not discussed in Option C is an increase in transmitter power for Advanced licensees. RASA presented a paper from our Vice President, Dr. Andrew Smith (an Oral and Maxillofacial Surgeon) to ACMA on this issue in May 2019. ACMA indicated to RASA that this issue would be included within the 2021 LCD review – hence its inclusion here.
The paper is summarised as follows:
Health risks with increased power
- A review of world literature has identified that radio amateurs have no higher incidence of medical conditions or causes of death from RFE than the general public. (Radio-Frequency and ELF Electromagnetic Energies A Handbook for Health Professionals, Hitchcock RT and Robertson RM. Revised 1994, John Wiley and Sons.)
- A review of the literature failed to ascertain any reports of damage to humans and/or animals from any amateur transmissions at power levels up to 2kW PEP. Data is scarce on issues related to microwave frequencies but yet again there are no reports of illnesses or diseases. (ibid.)
- There is no empirical evidence that supports the ACMA position that an increase of PEP from 400W to 1kW would have any deleterious effect on radio amateurs, members of the public or animals, as long as the emissions comply with ARPNSA standards. There is no validity in terms of health, well-being and OHS that supports the ACMA argument for a 400W PEP limit in the Amateur HF and VHF/UHF bands.
Interference risks with increased power
- It is a sine qua non that with increased power, the higher and closer the source then the risk of Radio Frequency Interference (RFI) may increase.
- There are multiple sources of RFI apart from Amateur Radio Transmissions.
- The change from analogue to Digital TV transmissions has reduced the risk of amateurs interfering with TV broadcasting and a literature review suggests that the number of complaints over this have dropped worldwide although other factors including a lack of follow up on reports of interference through personnel shortages may have had an effect.
- There is no evidence that there has been any increase in RFI complaints in countries (NZ and Canada) (Sources FCC, NZART and Radio Commission of Canada) that have increased their permitted PEP over the last decade or so.
There is no health or occupational health reason preventing power limits for Advanced class Radio Amateurs in the HF/VHF/UHF bands to be increased. There is little or no evidence that suggests that an increase in power will increase complaints of RFI.
Anecdotal evidence from the amateur radio sector is that many stations currently operate well in excess of 400W PEP output power on HF – there have not been any reports of RFI/EMR/EMC issues with these stations.
ACMA should therefore increase the maximum PEP for Advanced licencees from 400W to 1kW.
Access to 50-52 MHz for Standard Class amateurs
Standard class amateurs are allocated only the top 2 MHz (52-54 MHz) of the 6 metre band. This anomaly serves no real purpose. Granting standard class amateurs all of 6m (50-54 MHz) would not impact the incentive to upgrade, as the privilege gap to advanced is still considerable.
In December 2019, we conducted a survey on this issue – 71% of respondents were in favour. We discussed this with ACMA who noted that the issue would be considered as part of the LCD Review. We therefore request that Standard Class licencees be granted access to the full 50-54 MHz band.
We understand that the WIA also support this proposal, as detailed in previous submissions to LCD reviews.
Amateur repeater/beacon assignment and licencing
As noted by RASA in numerous submissions to ACMA, assignment of repeater and beacon frequencies is not working well at all and needs to be streamlined.
We have had frequent complaints from clubs and individuals regarding excessive delays in receiving frequency allocations – despite the use of professional frequency assigners.
From what we are told by assigners, assignments have to be checked by the WIA. As far as we understand, this is to ensure compliance with the bandplan for the band in question.
Some time ago, ACMA staff made the suggestion that bandplans for the amateur bands supporting repeaters could be translated to Radiocommunication Assignment and Licencing Instructions (RALI) – as used by commercial land mobile services.
We support this proposal.
A RALI for each of the 29, 52, 146, 438 and 1296 MHz bands would list the repeater channels available in each band. An assigner would use the amateur RALI data, along with the assignments listed in the Register of Radiocommunication Licences to make their assignment.
The RALI would be updated as/if bandplans change.
This arrangement would significantly streamline the assignment process.
“Amateur band only” assigners
We note that ACMA has floated the idea of Approved Persons who would only make frequency assignments in amateur bands. There are suitably qualified amateurs (i.e. holding Tertiary qualifications in comms engineering) who could undertake this function.
However, ACMA staff have indicated informally that said specialist assigners would still be required to hold Professional Indemnity (PI) insurance – this is expensive – in the order of thousands of dollars a year.
The PI requirement is the main reason that qualified amateurs have not sought accreditation as assigners up until now. However, given the potential risks for interference to safety services inherent in frequency assignment, it is difficult to see how the PI requirement could be waived.
If the RALI arrangement as discussed earlier was implemented, there would be no need for amateur-band-only assigners.
27 March 2021