Regional Secondary Locator
Paul Jarvis of Ofcom, speaking at the National Hamfest and at the RSGB Convention, raised a policy issue on the use of Secondary Identifiers. The presentation slides are available for download.
Clause 2(2) of our Licence Schedule states that we “shall modify our call sign prefix with an alternative or secondary prefix letter…”. This identifies the UK Nation in which the station is located. The exceptions are licence variations that allow the use of special short-term prefix letters that are not geographically related, e.g. the recent GV prefix. Ofcom has recently interpreted clause 2(2) as applicable only to the fixed or home station operation. However, Ofcom is aware that standard practice has, for many years, been to change this prefix when applied to alternative, temporary and mobile operations.
An example of this would be where say G4*** operates as a portable station from Wales he or she uses the call sign GW4***/P. For a holder of an Intermediate Licence the practice is for 2E0*** to operate as 2W0***/P. Similarly practice is followed by Foundation Licence holders. Ofcom consider that its intent in the wording of the current licence is that the call sign in these circumstances should be G4***/P , 2E0***/P, etc, as the fixed or home station address is unchanged. If Ofcom needs to contact the station concerned it would write to the licensee at that address. Likewise Ofcom considers that it would expect to see GM4*** operate mobile from the Isle of Man as GM4***/M; a similar suffix addition would apply for Intermediate and Foundation Licence holders.
We understand that in raising this interpretation Ofcom is not suggesting that the current practice should change now, but that it is considering including this subject within the Licence Review consultation. It wants to see if there is a way forward that is both legally sound, in terms of the licence, and also satisfies the needs of the amateur community.
This unexpected interpretation raises some concerning implications, and the Society is keen to provide Ofcom with some initial views before it frames its consultation question on the subject.
This Litmus Test consultation has now finished, with the following outcome:
The Society understands that the Secondary Regional Identifier (RSL) is not an ITU-R Radio Regulations requirement, but can be requested at the discretion of the national administration (in our case Ofcom). The RSGB also recognizes that Ofcom are best positioned to determine the legality of the current or possible changes to the wording of clause 2(2) of the Licence Schedule, so this response does not consider the legal aspects; but equal attention must be given to functional issues and to the impact of any change. The function of an amateur call sign is to identify each individual station concisely and unambiguously to any listener around the world (including the monitoring services of other administrations). The established UK system of RSL achieves that in a way that is widely known and understood. Any unilateral change by OFCOM would thus have a negative impact on stakeholders, not only in the UK but around the world. That impact would need to be formally assessed and could only be justified in terms of some overriding need. RSGB sees no such need or justification for changing the existing system.
The purpose of this document is to give RSGB views on the potential impact of changes to usage of the RSL.
The overriding view from those participating in our consultation, which was paralleled at the Ofcom session at the recent RSGB Convention, is that the current practice of using the appropriate RSL at the point of where the transmitter is located should stand. Ofcom may wish to consider if the wording in the Licence Schedule needs to be improved to make this clear.
The RSGB is keen to point out the following potential impacts:
a) Current practice is to change the RSL as the station operates in different UK Nations. Amateurs outside the UK may be confused where the appropriate RSL for the actual location of the station is not used, or its application is made optional.
b) Short-term operation from those UK Nations where amateur operations are less common will significantly reduce if the use the appropriate Regional Secondary Locator is not allowed.
c) Various International Amateur Awards and Contest adjudication may be made more complicated if changes are made to the usage of RSLs. Some contests too rely on the RSL attract activity.
d) There may be an impact in terms of usage by amateurs visiting from overseas and operating under the CEPT TR61-01 arrangements.
The RSGB proposes that the current interpretation of Clause 2(2) in the licence schedule be strengthened by clarifying that the appropriate RSL must be used for alternative, temporary or mobile operations. Further, that call signs with non-RSLs, such as special prefixes, may be used through variation of the licence at the request of the licensee.
Within our consultation on the RSL there were several comments about the shortcoming of lack of regional location with the use of the GB prefix for Special Event Stations. The RSGB is willing to work with Ofcom to reach an outcome that will better meet UK amateur’s needs.
Comment was made in our consultation that inclusion of the RSL issue, with its implications about regional identity, would be inappropriate to include in the Licence Review if this was to take place during the course of the Scottish Referendum Campaign.