Assessment of WIA submission to the ACMA

Dear fellow amateurs,

Why do people join the WIA?  What is the core function of our institute?

Of course, it is to represent our interests to the regulator, the ACMA.

The WIA board recently made a submission to the ACMA on revised licence conditions for the Australian amateur service.

It may be found here:

http://www.wia.org.au/newsevents/news/2016/20160430-1/index.php

We have analysed this submission.  Our analysis may be found below.

We would welcome your feedback using the contact form on our website.

Unlike the current board, we believe strongly in consultation, particularly on such a fundamental issue as licence conditions.

To this end, we will be publishing another electronic survey in a few days to elicit your views on the structure of our hobby.

We will advise when this is ready.

73

WIA RG

 

 

An assessment of the April 2016 WIA board submission to the ACMA

The purpose of this short paper is to evaluate the effectiveness of the April 2016 submission from the WIA board to the ACMA proposing changes to amateur licence conditions.

Readers should note the WIA Reform Group does not, under any circumstances, wish to impede access to new bands, power and modes for the amateur service.

However, we will only achieve extra privileges or new licence conditions if our reasons are sound and logically presented.

Any new conditions must also be supported by a majority of amateurs. This Board appears to have conducted little or no consultation with the membership with regard to the recent submission.

Summary

As our representative body, we reasonably expect the WIA to prepare proactive and professionally researched submissions to the Government Regulator, ACMA.  We expect updates on previous submissions and consultation with the membership.

The following key points are provided as a summary of our analysis of the recent WIA Submission to the ACMA.

  1. No timeframe or target dates are offered in the submission.
  2. Access to four new band allocations is proposed. Whilst we support this in principle, no justification or reasoning is offered.
  3. Immediate access to 60m (5 MHz) is proposed. This appears poorly researched as the band is already allocated to Government services and immediate access is almost certainly an unreasonable gambit.
  4. Data modes for Foundation Licensees. This is long overdue and we strongly support it.
  5. Extra Bands for Foundation Licence and Standard Licence. The WIA Reform Group is concerned that the WIA Board has not sought a mandate or any feedback from the membership for these proposed changes.  The proposal is a significant dilution of existing licence structures and undermines the original intent of the FL; that being an entry point to the hobby with a clear advancement path.
  6. 200W for standard. The justification offered for this increase in privileges is poorly structured at best.  No sound basis is offered and this proposal does little more than undermine the existing licence structures.
  7. Three letter callsign suffixes for FL. This is a long overdue proposal and our detailed response offers some further consideration.  The Board’s submission proposes little in terms of specific recommendations; a lost opportunity that illustrates a lack of leadership on the issue.
  8. An item not covered in the submission is transmit frequency coverage of HF transceivers used by amateurs. This is a contentious issue that needs resolution.

Overall, it is positive that the WIA Board has made a submission and have included some key elements that are well overdue.

However, the paper is unnecessarily verbose and is by no means a clearly understood document with well justified recommendations (many would regard the writing style as unnecessarily bureaucratic).

A lack of conversation and consultation with the membership reflects very poorly on the Board.

 

Detailed comments on the submission

Timeframe

The submission is an initial input to the ACMA.  A further meeting is proposed in August-September to progress the submission further.  However, a timeframe for implementation is unclear.

Access to new bands at 1.9, 3.5, 70 and 960 MHz

The introductory item for the review document mentions that

“WIA outlined its proposals to the ACMA for extending frequency access in existing bands at 1.8 and 3.5 MHz, seeking additional bands at 70 MHz and 920 MHz, acquiring primary status for 50-52 MHz and securing better access to UHF and microwave bands in the face of threats from spectrum demands of the mobile broadband telecommunications industry and the NBN”

There is a passing reference to this at section 4.1.  No specific proposals or justification is provided.

Immediate access to 60m

The submission proposes that amateurs be given immediate access to the 15 kHz wide 60m band (5351.5-5366.5 kHz), granted at the recent World Radio Conference.

Article 4.4 of the Radio Regulations is quoted in the submission – this Article allows access provided that harmful interference is not caused to existing users (our italics).

The submission then goes on to note that the band in question is “generally committed” with allocations throughout Australia.

Further, the submission states that:

In the first instance, the WIA seeks the retention of the current channels assigned for specific amateur use, for the time being, and to work with the ACMA and other stakeholders to achieve institution of the ITU allocation at the earliest opportunity, with conditions appropriate to the prevailing circumstances, and in keeping with the power limit conditions set out in the WRC-15 decision.

This paragraph is somewhat obtuse.  To clarify – it needs to be considered as two separate requests – “current channels assigned for specific amateur use” and general access to the 15 kHz band.

“current channels assigned for specific amateur use”

We assume that this refers to the two 5 MHz WICEN channels.

In 2006, at the request of then WIA Director Glenn Dunstan, VK4DU, WICEN was allocated two by 5 MHz land mobile voice channels.

However, the channels are shared with commercial fixed and mobile users and are subject to the condition that they are for “use in emergency situations by WICEN to provide emergency and safety communications” [1]

[1] ACMA assignment details for licences 141519/1 and 1141520/1

 

The channels are not assigned for “specific amateur use” as claimed in the WIA board submission.

Moreover, only one of these channels falls within the new 15 kHz band – 5355 kHz.  The other, 5102 kHz, is outside of the band.

General amateur access to the 60m band

Perusal of the ACMA database reveals that there are 65 Australian commercial assignments in the proposed 60m amateur band.  Most of these are Government and safety of life related – Federal police, Ambulance service, Fire and Rescue, Flying Doctor and State Emergency Service.

These assignments take up the entire 15 kHz – there is no space available.

As per the decision of the World Radio Conference, the band is not available for amateurs until 2017.  Even when it becomes available, amateurs are classified as a “Secondary service” to the Primary users – commercial Fixed and Mobile stations.

In accordance with the International Radio Regulations and the Australian Spectrum Plan, Secondary services are not allowed to cause harmful interference to Primary services.

Given the lack of any spare frequencies in the 15 kHz wide 60m band, and the type of Primary user (Government safety of life services), it is doubtful that Australian amateurs will have access to 60m for the foreseeable future – let alone early access as proposed in the WIA submission….

Alas, this is symptomatic of the WIA’s entirely unprofessional approach to the 5 MHz band.

Is it any wonder amateurs have such a poor reputation with industry, when the WIA advocates at the ITU for a band that is used heavily in Australia by Government safety of life services and also for major Australian Government-funded health radio networks in PNG and the Solomon Islands?

The PNG and Solomon Islands networks cost around 25M to install, and have 2000 stations.

Surely, the sensible thing to do was to engage with industry, to see if there was a segment that could be used, rather than just hoping for the best at the ITU….

Consultation obviously does not figure highly on this board’s agenda….

Data modes and increased power for the Foundation Licence (FL)

Data modes for the FL are long overdue.

The FL syllabus needs to include the practicalities of digital mode operation – interconnection of radios/modems and the vital importance of proper modulation level control.

In keeping with the ethos of the FL, only commercially manufactured digital mode interfaces should be used.

Extra bands for Foundation and Standard class

The submission notes that some overseas administrations have granted their entry and middle level licences more bands than our Foundation and Standard class.

There is no specific request or recommendation as to which extra bands should be granted.

This “they have it, so we should” argument is flimsy at best.  Government regulators require proper, evidence based reasoning before they would consider any change to licence conditions.

From a practical perspective, there is nothing new to be achieved by looking at overseas equivalencies, as this has all been done before.

For example, the UK FL provides access to all HF bands, 6m, 4m, 2m, 70cm and 3cm.  It was introduced three years before its Australian counterpart.

The UK FL model was considered in detail by the then WIA Federal Council when the Australian FL was being developed.

The view was that the FL is intended to be an entry level qualification, and the selection of bands for the Australian FL gives a good sample of what AR has to offer.

There is a well-defined path for those who wish to aspire to more privileges.

We have seen no compelling evidence to change this view.

What the WIA board are proposing, in effect, is to undermine the current tiered licencing structure by seriously diluting the incentive to upgrade from the FL and Standard classes….

This is a major policy shift for the amateur service in Australia. 

The WIA RG notes that there has been no consultation with WIA members, or indeed the general Australian amateur population, on these changes.  They were simply presented to the ACMA by the WIA board as a fait accompli.

Does the WIA board have a mandate to go to ACMA proposing a major restructure of the amateur radio service without any consultation?

We would argue that they unequivocally do not.

200 watts for Standard class

The submission argues for a doubling in power output for Standard licences to 200 watts.  There is no reasoned justification to support this claim.

The reasons are, frankly, baseless.  Again, the “others have it, so why can’t we” argument is rolled out…..

As for as the argument that “there are 200W commercial transceivers available” – this is entirely unjustifiable from a regulatory perspective.

There are 3 kW amplifiers commercially available in Australia – using the WIA board’s logic, Advanced Class amateurs should be permitted 3 kW…..

Three letter suffixes for FL callsigns

FLs clearly need three letter suffix callsigns, for the reasons quoted in the submission.

Surely it would be logical to suggest some ideas for a callsign restructure, rather than just demand it be done…..?

The entire Australian Amateur Radio callsign structure should be reviewed.

Why, for argument’s sake, are AX and VI reserved for specific occasions? Two whole blocks sitting idle for 99% of the year…

The old argument that certain blocks were set aside for commercial services is becoming less valid these days.  Most commercial services do not use formal ACMA-issued callsigns over the air now, and the ones that do (maritime and aviation, in the main) use a different structure to amateurs.

Why not translate the current VKxFxxx template to a VI prefix with a three letter suffix?

VK2FABC could become VI2ABC.

This issue is further addressed at section 5.4 of the submission, but, again, no examples are provided to stimulate discussion.

Transmit frequency coverage of HF transceivers – not addressed in the submission

There are unresolved issues around permitted transmit frequency coverage of amateur HF transceivers – there appears to be no official, published interpretation by ACMA.  This needs to be addressed by the WIA.

Most modern HF amateur transceivers are capable of transmitting outside of our HF allocations – 1.8-2 MHz, 3.7-4 MHz, for example.

Therefore, surely it is the responsibility of amateurs, as technically qualified practitioners, to ensure that they transmit in their licenced bands, regardless of the transmitter’s frequency coverage?

This always has been an issue of operate, rather than possess.

Permitted bandwidths and higher power for Advanced licences

Whilst we certainly support relaxation of permitted bandwidths for Advanced licences, this may be difficult to achieve below 28 MHz, as it would seriously impact on existing band usage.

High power for Advanced licences is supported, provided a meaningful EMR/C regime acceptable to ACMA can be implemented.

 

WIA RG

May 2016