RSGB Guidance for Responding
The feedback that we are getting is that some people have found the consultation document difficult to read and interpret, yet the questions seem simple. Since there are various important points that may not be entirely obvious on first reading of the document we have decided to provide some more specific guidance on how to interpret the document and importantly help you to form your response. The main concerns that RSGB consider need addressing are Questions 1, 6, 7 and 8, where we hope the following discussion will help you to formulate your own views for your response. You will of course need to consider the other questions, which we understand people are finding more straightforward.
Question 1: Do you agree with the proposal to include, as a matter of course, the 470 kHz and 5 MHz bands into the Licence for all Amateur Radio (Full) licensees?
The main thrust of this proposal is that the Licence be varied for all Full licensees (including Club and Reciprocal licensees), authorising the use of the 470 kHz and 5 MHz bands as a matter of course. However it proposes to achieve this by a ‘copy+paste’ of existing NoV clauses, which are not necessarily appropriate in the main licence/schedule and in places could present serious difficulties for radio amateurs.
Paragraph 2.26.3 proposes a potentially far-reaching precedent in relation to interference namely:
“The station must not cause interference to, and may not claim protection from other wireless telegraphy or electronic equipment.”
The key words are ‘electronic equipment’ which implies that we must not cause interference to non-radio equipment. This has never been included in the licence schedule and is at variance with Ofcom’s normal practice in not investigating interference to non-radio related equipment.
Paragraph 2.26.6 also proposes that:
“The licensee must take suitable precautions, particularly in locations to which people have access, to minimise the risks associated with exposure to Radio Frequency (“RF”) radiation”
This seems to have been carried over from an earlier application form for Special Research Permits and should be omitted as in the 470 kHz band near field measurements are very difficult to make. Clause (e) in the Notes to Schedule1, found at the end of Section 2 of the existing licence, is sufficient in this regard.
As these two issues stand they may not immediately cause problems, but their inclusion into a licence document covering an ITU agreed amateur band, as in the case of the 472kHz band, could set a precedent for the terms to be applied to other amateur bands in a future review of the amateur licences.
Q1 suggested response:
‘No – Not as proposed. I agree that the bands should be made available to all Full Licencees but in exactly the same way as other bands to which amateurs have access on a Secondary basis. The standard wording applicable to other amateur bands should suffice i.e:
“Secondary. Available on the basis of non-interference to other services inside and outside the UK”
Furthermore some of the proposed clauses set concerning precedents that if subsequently applied to other bands would radically change specific aspects of amateur radio in the UK. Of particular concern is Paragraph 2.26.6, which should be omitted entirely, as well as the phrase ‘electronic equipment’ in 2.26.3
With respect to Paragraph 2.26.6, near-field measurements at these frequencies are very difficult to determine with any accuracy and in any case are irrelevant at the power levels in use. Clause (e) in Notes to Schedule1 of the existing licence is sufficient and does not need to be reinforced in relation to the 472kHz entry.’
Question 6: Do you agree that Clause 13 of the Licence should be amended to allow for a simpler, more flexible approach for identifying Amateur Radio stations?
The proposal suggests a less prescriptive approach than the long-established requirement for transmission of callsigns at the beginning of a contact and at 15-minute intervals etc.
The requirement would now be that a station must be ‘clearly identifiable at all times’, that a valid call sign for the station be transmitted ‘as frequently as is practicable during transmissions’ to ensure that the station is clearly identified; and that the station’s identity be given in ‘voice, Morse Code or a format consistent with whatever form of modulation is in use’.
Our observations are:-
- ‘as frequently as practicable’ is open to too great a range of interpretation (and in some cases might be more burdensome than the well known 15 minute rule).
- Licence terms that refer to specific modes such as CW or voice are unwelcome
- Ofcom notes in Para 2.62 that these relaxations would in any case not apply to the 5MHz band
On air identification by and of amateurs is a key concern and a cornerstone of good operating practice. Our view is that :-
- a station must be clearly identifiable at all times
- the station’s identity be given in a format consistent with the modulation in use
- clear definitions for callsign use (and a maximum interval) are essential
Q6 suggested response:
‘No – Not as proposed. A clear definition of callsign usage and the current maximum interval of 15-minutes should be retained. However the requirements that a station must be clearly identifiable at all times and that the identity be given in a format consistent with the modulation in use are supported (but that specific terms such as voice or Morse Code should not be used).’
Question 7: Given the current uncertainty amongst Radio Amateur licensees in relation to Clause 2(2), do you believe that it would be a practical solution for Ofcom to remove this clause and to insert additional wording into Clause 13, as proposed above?
Note—Q7 and Q8 (for Intermediate Licensees) need to be read together as both affect the use of RSLs.
The key words are found in paragraph 2.64 (from Licence condition 2(2))
“The Licensee shall use the following appropriate Regional Secondary Locator after the United Kingdom Callsign prefix “G”, “M” or “2” as specified in Section 1, when identifying the Radio Equipment in accordance with Clause 13(1):”
and Ofcom’s comments that “we understand that there is confusion as to exactly what Clause 2(2) means”
It has been a licensing requirement in the UK for many decades to use the relevant RSL to indicate the location of the transmitter. As well as a requirement it has become custom and practice amongst UK amateur licence holders and the RSLs are deeply embedded into amateur psyche. This arrangement has also been acknowledged and understood by amateurs outside the UK. The implications of making the RSL optional could be huge including causing confusion in DXCC, contests and within the VHF/UHF community in easily determining beam headings, etc.
The consultation refers to confusion within the Amateur Radio community. However the root cause of the problem appears to be within Ofcom who at times have issued a mixture of licences with the RSL embedded or not embedded in the core main station address callsign. The proposed change will certainly cause confusion resulting from the optional inclusion of the RSL for Foundation and Full Licence holders and the related, but very different, Question 8 mandatory changes for Intermediate Licence holders.
It is clear that the changes outlined in both Question 7 and Question 8 below constitute a major impact. The RSGB’s view is that the arrangements for the call sign prefix in our current licence meets the requirements laid down in the ITU Radio Regulations. We thus have the opinion that no change is necessary. We consider Ofcom should listen to and respect the Stakeholder position for “no change” and “if it is not broken don’t fix it”. A better approach would be for Ofcom to fix the root cause of the problem mentioned in the paragraph above.
Q7 suggested response:
‘No – there is no need to change current mandated and widely accepted practice. Any change of current practice will lead to both confusion and disruption both nationally and internationally. To do otherwise would do away with more than 50 years of practice, widely understood throughout the world and would create far more confusion than is currently alleged to exist‘
Question 8: Do you agree with Ofcom’s proposal to amend Clause 2(3) of the Licence to require Intermediate licensees to transmit a call sign that reflects the location of their main station?
Compared to the proposal in Question-7, this introduces a totally different (and potentially discriminatory) requirement for Intermediate Licensees. Furthermore by locking the callsign to the main station address rather than the actual location of the transmission, serious confusion arises (with for example a 2W0xxx station operating as that in Scotland for example). This would be in conflict with the Q6 requirement for clear identification and be inconsistent with Foundation and Full licensees.
If you agree there is no confusion in respect of current practice in terms of the callsign prefix for other licence classes then a response as suggested below follows logically. This also introduces the concept of equal treatment for all, something which Ofcom themselves have highlighted in their recent equality statement.
Q8 suggested response:
‘No I disagree – All call sign classes should be treated in the same way by retaining the current clause in respect of the callsign prefix’
- Ofcom require feedback from individuals on their Consultation Response Form. These forms will provide evidence that Ofcom will use when judging the level of support or otherwise for their proposals. Please consider the guidance carefully, form your own view that could, of course, be at variance with the above guidance, and make your response using the online Ofcom Response Form here: https://stakeholders.ofcom.org.uk/consultations/amateur-radio-licence/howtorespond/form
- Please try to tailor your individual response – Ofcom need your individual views, not just multiple copies of our guidance!
- If you wish to update a previous reply to Ofcom, you can submit again but you must make it clear that the response supersedes your previous one
- RSGB shortcut for information: http://rsgb.org/licencereview.
- RSGB guidance for responding to the Ofcom consultation on updating the amateur licence (4-page/27.7KB PDF)