The Manager
Strategy and Transition Section
Spectrum Review Implementation Branch
Australian Communications and Media Authority
By email spectrumworkprogram@acma.gov.au
Dear sir/madam,
COMMENTS ON DRAFT FIVE YEAR SPECTRUM OUTLOOK 2019-23
I write with reference to the draft Five Year Spectrum Outlook (FYSO) 2019-23 published on the ACMA website.
The Radio Amateur Society of Australia (RASA) offers the following comments.
1. 5 MHz amateur band 5351.5-5366.5 kHz
RASA has discussed the 5 MHz band with ACMA over the past 18 months. These discussions are summarised as follows.
There is a very large Queensland-wide allocation at the top of the band on 5365 kHz. The number of stations and their wide geographic dispersal would preclude any sharing with amateur services on the eastern seaboard.
For this reason, it is proposed that the upper end of the band be restricted to 5365 kHz.
Data from the ACMA RADCOM database indicates that the remainder of the band is shared with commercial services in remote and very remote locations, viz:
Woomera SA
Karratha WA
Meekatharra WA
Milparinka NSW
Menindee NSW
Narrandera NSW
Dubbo NSW
ACMA Frequency assignment practice guideline number 8 defines an indicative communication distance of approximately 400 km at 5 MHz during daylight hours for the purposes of channel sharing, based on a typical transmitter power of 100 Watts.
From professional experience, 400 km is at the upper end of the achievable range on 5 MHz during daylight hours for a typical land mobile installation.
All the locations detailed previously, apart from Dubbo, are very remote – the amateur population within 400 km is negligible. When considered with the low EIRP limit granted to amateurs at the World Radio Conference (15W), there is minimal potential for interference.
The Dubbo channel has been shared with WICEN for more than ten years, with no reports of interference. Moreover, WICEN operate under a land mobile licence, which allows 100W transmit power.
Although the public RADCOM database does not list all Defence allocations, Defence does not normally directly share segments with commercial land mobile services.
Proposed way ahead
We understand why there would be reticence to giving amateurs immediate unrestricted access to what is a commercial land mobile segment.
Other administrations have taken a graduated approach to the introduction of the 5 MHz amateur band, and we suggest that this would be appropriate for Australia.
To this end, we suggest a trial sharing arrangement be undertaken for a defined period, say six months.
Amateur operation to be restricted to spot frequencies on the existing commercial allocations of 5351, 5355 and 5360 kHz, using USB mode only with a maximum 2.8 kHz bandwidth.
Additionally, we propose a trial digital mode allocation on the vacant 5363-5365 kHz segment.
We also suggest that it would be logical to embargo any new commercial allocations in the segment 5350-5365 kHz. There are ample frequencies available either side of this segment for land mobile services. Defence has large allocations outside the segment.
The channelised arrangement has been used in many other countries to introduce the 5 MHz amateur band – notably, Europe, the USA and New Zealand.
These countries all have high commercial utilisation of 5 MHz and much shorter distances between amateurs and commercial users than Australia.
We understand that the trials have been successful.
2. Revisions to the amateur Licence Conditions Determination (LCD)
RASA supports revision of the current LCD, as it is too prescriptive and not reflective of current and future technologies. We would be pleased to participate in the consultation and redrafting process.
3. Reforming arrangements for amateur certificates of Proficiency
RASA does not support the articulation of amateur qualifications into the Australian Qualifications Framework (AQF), as this framework is designed for workplace and trade use. Amateur Radio is a hobby and an amateur radio licence is not intended to provide certification for work purposes.
In addition, it was clear from the responses to the ACMA options paper for amateur qualifications prior to the recent tender for assessment services that the sector was not in favour of any attempt to align Amateur Radio with the VET and TAFE system.
The contract for assessment services has recently been awarded to the University of Tasmania’s Australian Maritime College. The College is successfully undertaking the assessment tasks and is now providing the academic rigour and maintenance of standards that had failed in the past.
It is the view of RASA that now is not the time to change the structure of amateur radio training and assessment. However, we would encourage the ACMA, along with the AMC and representatives of the amateur radio community, to review the syllabi for study and to use these new syllabi as a basis for a fresh LCD that puts into plain language the rules under which amateur radio operates and more accurately reflects developments in technology that have made the current document obsolete.
Yours sincerely
G.C. Dunstan
President
14 May 2019