ACMA News.

VK3YNV

VK3YNV

Administrator
Staff member
Copied from Facebook post by Rob Vk2RK.

In the light of the many submissions made and ignored by the ACMA they are going ahead recognizing the WIA and RASA as the ones whose submission mattered.
How can ACMA ignore over 500 submissions against the proposal beats me.

Those that sat on the fence, don't you start winging when the class licence comes into effect, you had plenty of opportunities to do something about it.

BTW no High power either so that carrot has now dissolved in to nothing.


" by eMail

29 March 2023
AMATEUR CLASS LICENSING UPDATE
In September 2022, we published a consultation paper seeking views on an updated proposed amateur class licence and supporting operational arrangements. The paper also consulted on a proposal for a staged implementation of higher power authorisation.
We also received many responses to our proposals for call sign administration and operational arrangements to support the class licence. In light of this, we are considering how to best deliver these arrangements under the class licence. This means the class licence will not commence on 1 July 2023 as previously indicated. We will provide an update on the commencement date for the class licence, as well as next steps for qualification and call sign services, later in 2023.
However, ahead of the class licence commencement, we will begin certain arrangements that will provide amateurs with additional accesses and authorisation pathways, as outlined in the 2022 consultation. In particular, we will:
We’ll keep you updated on progress.
Draft FYSO released: Have your say
  • We are seeking feedback on the draft Five-year spectrum outlook (FYSO) 2023–28. We welcome your feedback by Friday 28 April."

    TAKE CLOSE ATTENTION (HIGH POWER)
    Its all in the wording that one can understand the intent
    "Publish information to assist applicants applying for assigned scientific licences for higher power experimentation uses (from 1 July 2023). This information will help applicants understand what we consider when assessing an application and the type of information that should be supplied to support an application"

    Publish information to assist applicants applying for assigned scientific licences for higher power experimentation uses (from 1 July 2023). This information will help applicants understand what we consider when assessing an application and the type of information that should be supplied to support an application"

    You will be required to apply for a scientific licence yet those across the ditch in ZL have no such requirement.
 
V

VK3TEX

New member
Having read the FYSO relevant sections ,yeah,what a waste of time it was putting objections to the class license….
It seems like they keep delaying all their decisions also, wonder why?
Sorry ACMA, you are just another droll department of the government tied up in red tape to get anything done in a timely manner.
And the wording on page 68 and 69 of the FYSO is laughable at best and very cryptic at worst….(sort of like”yeah we will let you know what’s going on when we feel like it”)
AND, the spiel about higher power….makes me so angry they are still procrastinating on this one…who the hell is going to apply for a scientific license and how much is it going to cost for it?And it ALL depends on if it meets their criteria…Expect PLENTY of knock backs….
We are the laughing stock of the region, with our Kiwi brothers having 1KW for many years now but we in VK are judged NOT WORTHY by our illustrious ACMA…..
Anyway, I predicted all of this before and it has come out in the wash now….With more to come…
All smells like shit to me….

Les, VK3TEX.
 
V

VK2RK

Guest
Write to the minister, email is just as good.
The more do the more likely for a ministerial investigation that is held outside the department and gets a mention in the house.

Not going to make any remarks about those that say I told you so.


The Hon Michelle Rowland MP contact details
Parliament Office
PO Box 6022
House of Representatives
Parliament House
Canberra ACT 2600
Email: Minister.rowland@mo.communications.gov.au
 
V

VK2RK

Guest
Lets rattle a few more cages
Clearly the ACMA is now claiming that we have agreed to the changes following the inclusion of certain conditions.
A fabrication conducted with WIA RASA and the ACMA

email from the ministers office

Ref: MC23-060548

Mr Robert Campiciano
308 Morebringer Lane
BALLDALE NSW 2646
via: rcampiciano@aussiebb.com.au

Dear Mr Campiciano
Thank you for your email of 30 March 2023 to the Hon Michelle Rowland MP, Minister for Communications, about proposed changes to amateur class licensing. The Minister has asked me to reply on her behalf.

The Australian Communication and Media Authority (ACMA) has engaged extensively on proposed changes to amateur class licensing arrangements and sought views from the amateur radio community over two rounds of consultation, first in 2021 and then again in 2022.
As you have noted, submissions came to different conclusions on the proposed transition to class licensing, with many amateur class licence operators not supporting the proposal. However, the majority of submissions to the 2021 consultation stated that if the ACMA modified the proposed class licence to address the key issues raised, then they may be prepared to support a future class licensing arrangement. This is why the ACMA consulted again in 2022, with submissions to that consultation to be published shortly.

The ACMA published all submissions to the 2021 consultation. The majority of individual amateur licence operators made a submission by signing one of several template or proforma documents. These submissions, including yours, are available via a link on the consultation page: www.acma.gov.au/sites/default/files/2021-11/Pro%20forma%20submissions.zip.
Thank you for taking the time to write and I trust that this information will be of assistance.

Yours sincerely
Shanyn Sparreboom
Assistant Secretary
Competition and Spectrum Branch
18 April 2023

My response

Hon. Michelle Rowland MP
Dear Minister

Copy to-
Hon. David Coleman
Shadow Minister For Communications

Thank you for the response provided by Shanyn Sparreboom Assistant Secretary Competition and Spectrum Branch.
However the information is full of distortion such that shows the ACMA input in the response.

As a preamble to this my response I will point the minister to two other organization the “Wireless Institute of Australia” and the “The Radio Amateur Society of Australia Inc.” These organization have been involved in the construct of the so called consensus when no such consensus exists but has been manufactured with the ACMA.
The two groups I mention above represent a very small percentage of the Amateur Radio Community, the exact numbers is not available to me but as of 2016 the Wireless Institute of Australia held 4159 members from a total Amateur population of 15679 this number is decreasing every year but using the 2016 figures the WIA represents 26% of the population.
The other Organization holds an even smaller number and in direct competition with the WIA

Both organizations favoured from the very start the ACMA restructure position, I clarify that this is not the position of the members but that of those in management of these organizations. Without entering into the reasons for such positions been held by both groups, they have helped the ACMA policy division to manipulate the outcome as outlined in your latest response.
It is clear to me that some questions regarding this matter have been asked by your department seeking clarification, unfortunately you are been presented with muddied waters.
If you care to look into the interdepartmental email exchanges with in the policy division there you will find evidence of the corrupt manner in that the policy shall be achieved at any cost.
That some of the officers have cautioned the head of that department that the action been taken could result in a ministerial investigation.

Now responding more directly - The first consultation resulted in an outstanding number of submissions (Over 800 according to published ACMA figures) The proposed changes having been rejected.

What followed are negotiations behind closed doors with RASA and the WIA
Note that RASA has commercial implications with the Australian Maritime College The RASA president was a principle consultant in the negotiations for the ACMA awarding the Licence contract to the college. This alone should ring bells of caution.
Further negotiations took place with the WIA, who are beckoning to the ACMA with the purpose to reobtain the contract in the future.

Both parties have an interest to bend to the policy changes as presented by the ACMA

The result of these closed door consultations resulted in the ACMA requesting that both organizations conduct their own open consultations to all Licence holder (15679)

The RASA consultation process was not accepted by the ACMA due to the manner it was held, no official reason was ever given. The WIA advertised via their closed web page that only parts are available to non members requesting to register and participate to the pending poll.
The WIA failed to send the form to all that registered and the results of the very small sample in my opinion was manipulated to achieve the wanted result, even if acceptable hardly a representative number showing an attitude shift.

This WIA poll is what the ACMA claims to be the one that shows the changes to be acceptable under certain considerations.

Any subsequent consultation been issued with the ACMA was and is stating that the class licence model is accepted that the consultation to seek further refinement. More likely forcing people like myself to give up.

How can the ACMA take such a shallow consultation when the groups negotiating with do not represent the larger community that will be involved in far reaching changes that will for ever alter the manner the service that has provide Australia in times of war and natural disasters a service saving many lives.

How can the Australia government allow such a department that has denuded itself of proper experts that understood the value of the service, becoming totally ignorant and placing reliance upon minority groups whose interest are self serving.

I seek an in depth investigation of the ACMA conduct by an independent group.

Note I am also referring this matter to member of the Opposition

I am tired of the lack of attention given to this matter

Regards
Robert Campiciano
 
V

VK2RK

Guest
ACMA in their usual style to provide results to consultations do so is such a way to make it as hard as possible for one to get to the substance of what they are reporting on.
So here is their latest report that includes the 31/2022 consultation results.
(Submission bottom of the site page)

I am directly linking to this so that those interested can read the submissions from others.
The one submission that I liked was from D. Hunter an ex Radio Inspector and his remarks struck accord with my feelings in the matter.

Not withstanding that in the consultation the high power question was made by the ACMA and according to the submission the majority is in favour of the power increase, in the subsequent published draft of the proposed changes to the act no mention is made of power increases at all....

The ACMA is once again playing games to achieve their wanted outcome against the tide of contrary opinion.

Write to the minister, show your concerns as to the manner that our service is been disrupted.

Links (31/2022 Submission report)
https://www.acma.gov.au/consultations/2022-09/proposed-amateur-class-licensing-arrangements-and-higher-power-operation-consultation-312022?utm_medium=email&utm_campaign=Amateur%20radio%20update%20Proposed%20changes%20to%20amateur%20access%20in%205052%20MHz%20and%203436%20GHz%20bands&utm_content=Amateur%20radio%20update%20Proposed%20changes%20to%20amateur%20access%20in%205052%20MHz%20and%203436%20GHz%20bands+CID_38a434d7c0586b52e2018dde56571679&utm_source=SendEmailCampaigns&utm_term=proposed%20amateur%20class%20licensing%20arrangements%20and%20higher%20power%20operation

In the submissions one by Hunter Douglas an ex Radio Inspector he makes valid comments on the whole process that ACMA is engaged in the abolition of our current system.

Content of ACMA email 1 May 2023 ACMA CONSULTS ON PROPOSED CHANGES TO AMATEUR ACCESS IN THE 50–52 MHZ AND 3.4–3.6 GHZ FREQUENCY BANDS
In September 2022, we consulted on proposed amateur class licensing arrangements and higher power operation.
We proposed changes to the draft amateur class licence to provide access to the 50–52 MHz frequency band for Standard amateur licensees and overseas visiting amateurs with equivalent qualifications (overseas equivalents). We advised that, pending consultation outcomes, we would make these changes to the Radiocommunications Licence Conditions (Amateur Licence) Determination 2015 (the Amateur Licence LCD) and the Radiocommunications (Overseas Amateurs Visiting Australia) Class Licence 2015 (the Overseas Amateurs Class Licence), before the amateur class licence is implemented. All submitters who commented on these changes supported our proposal.
The draft amateur class licence also reflected our intention to remove access from Advanced amateur licensees and their overseas equivalents in the 3.4–3.6 GHz frequency band. This is within areas re-allocated for spectrum licensing under the Radiocommunications (Spectrum Re allocation – 3.4 GHz and 3.7 GHz Bands) Declaration 2022 for Advanced amateur licensees and overseas equivalents. The 3.4–3.6 GHz frequency band has also been identified for possible long-term earth station protection zones (ESPZs).
This is defined in frequency coordination procedures for the earth station protection zones (RALI MS44). We are now consulting on making these changes to the Amateur Licence LCD and the Overseas Amateur Class Licence. We welcome your views on the proposed changes by 5 pm (AEST), Thursday 1 June. Publication of submissions
We have published the submissions received in response to our consultation on the proposed amateur class licensing arrangements and higher power operation. The submissions are available on the ACMA website.
 
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V

VK2RK

Guest
Submission by ex Radio Inspector

Makes an interesting read (Name removed Original can be found in the link to submissions)

The Manager
Spectrum Licensing Policy
Australian Communications and Media Authority
PO Box 13112
Law Courts
Melbourne VIC 8010

to SLPSConsultations@acma.gov.au.


I worked as a “Radio Inspector” in various roles for (respectively) P&T, DOTC and SMA, between 1978 and 1996, in the days when regulatory staff were employed. Today’s lack of such staff seems to be the main reason for the push to move amateurs into Class Licence status, much like occurred with the CBRS. That move did little to the income stream while it substantially reduced the costs to the Government and that de-regulation resulted in chaos. I have held an Australian Amateur Licence since April 1967 so have “seen a lot”, not all favourable.

The push to do the same with the amateur service could result in chaos despite, overall, most amateur operators abiding with The LCD. What it does do is create opportunities for ‘others’ who are not holders of a qualification certificate, just appearing on amateur frequencies as if valid users. And we are unable to do anything about it, mainly because the ACMA has become a ‘toothless tiger’, having generated rules but nothing to ensure that these rules are obeyed.

I have major reservations about the whole devolvement of the existing Apparatus Licence to Class Licence concept and process. At present, amateurs are afforded an interference/protection status under the LCD and we pay an annual licence fee, which includes a tax component. Our licences are recognised overseas, just one of many recognisable features. After the transfer to Class Licence, any protections are degraded or removed and, theoretically, no licence fees will be payable. There will no longer be “licences” as such, and overseas recognition will be made more difficult.

What has not been made apparent is the fees and charges that the callsign management body (currently named as the AMC) will levy on holders of Australian callsigns. In lieu of the current $55 annual licence fee, the AMC will have unlimited options to charge anything they wish to, without controls, and there have not been any details promulgated as to what that they might be. And, that status also refers to existing callsigns, not just new applications.

This whole issue is complicated as there is no true transparency as to what the AMC might do, can do, and will do, without an overlying set of public policies being implemented. There has not been any documentation provided by the AMC (to my knowledge) to explain what the new guidelines, processes and implementation will be – yet we are asked to provide our thoughts on the transition from ACMA to AMC when we are only partially aware of the actual direction and processes. That simply is not good enough.

It could well be that we are better served under the Apparatus Licence regime despite the costs and difficulty to the ACMA in managing the service, and their wish to devolve the service.

Let me preface my comments further with a re-iteration from my last submission (IFC 01-2021), the “Australian Maritime College” should not be named in a piece of Commonwealth Legislation yet it still appears as follows :


Page 1 :

“4 Definitions

In this instrument:

Act means the Radiocommunications Act 1992.

AMC means the Australian Maritime College, an institute of the University of Tasmania.

“

The term AMC appears again as “call sign means a sequence of letters and numbers assigned to a person by the AMC as a call sign.

“

I refer you back to my submission under IFC 01- 2021 which stated my objection to this appearing in the Class Licence Legislation :

“In Section 4 of the proposed Class Licence document under Definitions is the statement : ” call sign

means a sequence of letters and numbers assigned to a person by the AMC as a call sign.“ where

“AMC means the Australian Maritime College, an institute of the University of Tasmania.” I strongly

object that the AMC is named in proposed legislation where instead it should be more like “a body,

or bodies, duly authorised to issue Amateur callsigns”. The existing Deed between the AMC and

ACMA only has a couple of years of tenure remaining and there may be a change away from the

AMC at its expiry, or any subsequent Deed expiry. Naming the AMC in legislation is a severe

oversight by the drafters given that the resulting LCD may be in force for many years.

Even the Consultation Paper refers to “The assignment of call signs will be managed by a third-party provider.“ in the proposed summary of changes.

Further, there could be more than one body responsible for the issue and management of callsigns for the Amateur Service at any one time and the Class Licence LCD must allow for that option in the wording.

---===---​


My responses to your topics are interspersed for ease of inter-relating the details :


Do you see any reason for not extending secondary user access to the 50–52 MHz band for Standard amateurs? If yes, what is your reason? (See section 3.)


In short, no. This has been an inequality ever since other LCD changes were made a few years ago (2019). Broadcasting has long gone from this part of the spectrum and Standard licensees should have been given access back then, but with whatever power limits apply to that Certificate Class.

---===---​


2. What are your views on the proposed policy on call sign transfer? (See section 4.)


It is imperative that a public resource is used to track the holders of amateur callsigns if the ACMA RRL data is to be discarded. Again, I take exception to the term “AMC” as used in this explanation (Operational aspects of call sign management are the subject of a Deed between the ACMA and the University of Tasmania (via the AMC).........) This document (Proposed amateur class licence and

considerations for higher power operation Consultation paper) should NEVER have been issued with this description in place.

Page 2 :



The ACMA renewal fee is $55 per annum for any licence class once issued. My impression was that the introduction of a Class Licence was at $zero per annum, but is the AMC (or other) going to implement an annual charge for an existing callsign holder ? Are there any public statements to confirm or deny ?

Activities generally have a cost to implement and if the AMC (or other) takes on a greater role, real or imagined, then it seems likely that they could introduce a fee at whatever level they like. I would rather pay the ACMA the existing fee than be at the mercy of the AMC (or other).


To state that I am concerned how costs will be attributed by either the AMC (or another authorised body) to manage callsigns is an understatement. The fees attributed for 2X1 callsigns is currently $70 per annum, renewable. What guarantees do we have that they will operate fairly once proposed changes come into effect ?? Are fees only going to be attributed to new persons applying for a callsign(/licence) ?


And then again, what will happen if the 5 year Deed between ACMA and AMC is not replaced and a new body takes over callsign and examinations processes ? Is there going to be another messy situation develop then ?


---===---​


Will the proposed ‘regular check’ – to confirm whether a person is still using their call sign – be a sufficient method of ensuring there are enough call signs (in combination with other factors, for example, the high number of available call signs, deceased amateurs, most amateurs only wishing to hold one call sign)? (See section 4.)

I hold an USA Extra Class callsign and it expires after a 10 year interval, and can be renewed again for another 10 years, etc. The FCC requires changes to mailing addresses to be made of its database by the licence holder (through the FCC License Manager) but otherwise there is no “heartbeat”.


The issue with having regular checks is that if this is undertaken by email or web login then what happens if the email develops no response in the short term, maybe the holder is travelling or in hospital or otherwise unavailable or has no web access. Are the next re-checks going to happen at regular intervals over an extended period of time or is the callsign just going to be cancelled and then made available for re-allocation ? Remember that a lot of callsign holders are ‘getting on in years’ and future access via electronic devices should not be taken as a “given”.

The existing AMC document on 2X1 callsigns was written such that it had a major hole in it, which some individuals have been making use of by having a “contest” which basically runs all year thus allowing these callsigns to be used anytime. The AMC appear to not have the experience to derive documents without such loopholes, and defeat the ‘bush lawyers’ at their game. If there is an alternate interpretation possible, these same ‘bush lawyers’ will find a way to thwart the original intention to provide an ‘acceptable outcome’.


---===---​


What are the benefits or disadvantages of our proposal not to limit the number of callsigns that may be assigned to a person? (See section 4.)


The number of call signs that can be assigned to a single person can vary depending on individual circumstances. Maybe the holder wants the same suffix allocation against other prefixes because

Page 3 :



most international operators still regard the prefix as providing location data. If I wanted VK4ADC plus VK7ADC, VK3ADC and VK1ADC (depending on availability) because I travelled interstate a lot, should the callsign management body inhibit this ?? Sometimes there are ‘personal acquaintance’ reasons for holding a second or third callsign of a deceased amateur(s).

Many operators will have one, and some maybe a second, callsign thus not really depleting the available callsign base significantly. It has only been the more-recent years where a callsign has been selected by the holder where previously it was done by the “Department” and there was no individual choice. If if desired callsign is not available, regardless of how many calls an individual has, so what ??


---===---​


Do you have any concerns with the other proposed call sign management arrangements? If so, what are they? (See section 4.)


Reference the section of Table 2 : Public register of call signs being used


Proposed : “Operators of amateur stations authorised under the proposed class licence would not be included on the RRL, and the ACMA would not maintain any other public register of call signs assigned to class licensed amateurs, nor would it impose an obligation on a third party to maintain such a public register. However, a call sign entity would have to maintain a record of call signs allocated and a ‘reserve list’, under an arrangement with the ACMA.”

“It would be open to the amateurs to develop and maintain one or more opt-in registers.

We are aware that there are a number of online resources that are already used by the amateurs.”


I often refer to the RRL data to cross-check the status of callsigns seen on-air. The odd station is operating outside of their licence conditions but removing the ACMA-managed resource completely – and that is what this section amounts to – will make it impossible to verify anything. So if a Foundation or Standard licensee wants to operate at 400W PEP on 18MHz there is nothing available to show that they shouldn’t.


The equivalent is to ignore the Advanced, Standard and Foundation certificates and just let everyone run at any RF power level on any band. That is the effective outcome.


---===---​


In the absence of amateur and station information being contained in the Register of Radiocommunications Licences, are there any amateur-operated registers or other existing voluntary registers that you would use? (See section 5.)


Such registers have no real meaning if they are not underpinned by callsign issuing authorities. RRL data currently shows licence class for amateur holders, voluntary registers have no data validation process, so are worthless.


Am I aware of any amateur-operated registers ?? Some might say that I have one on my web site (

Australian amateur radio licences data

VK4ADC's Web
www.vk4adc.com
) but in reality it is data re-processed from the RRL data as periodically downloaded. When that RRL disappears then so do any updates to the available data. Due to copyright plus data privacy rules, there is only really accurate beacon and repeater data available there, plus state-by-state Google

Page 4 :



KML files as derived from RRL data for the individuals holding Advanced, Standard or Foundation callsigns. Could an actual name/address/status (F/S/A) list be created ? Yes.

Is it real-time ? No. Could it be ? No.


I think that the privacy concerns that prevented the annual WIA Callbook from being published publicly come into play here. Any non-ACMA register cannot co-exist with privacy laws - but the ACMA can host one – and currently do so as the RRL and the web query interface known as the Public Register.


---===---​


Do you anticipate any difficulties operating your station in Conference of Postal and Telecommunications Administrations signatory countries? (See section 5.)

Given the current economic and COVID statuses, it is unlikely that I will again travel overseas BUT that should not be taken as a NO. There have been family discussions about this topic recently so it could happen, and I would, as in the past, take amateur radio equipment along.

The removal of the RRL data is one factor that might cause issues in that we no longer are provided with a “paper” licence as proof of our licensing status. Nor can we say to the other authority to check the ACMA data lookup as a reasonable option. The Class Licence move removes such links / options to validate an individual’s Australian amateur status.


---===---​


What are your views on the proposal to allow Advanced amateurs to apply for assigned scientific licences for certain experimentation uses, such as reflecting signals from a celestial body as well as inter-continental ionospheric and trans-equatorial propagation experiments? (See section 6.)


The description in the Consultation document suggests a RF power figure of 1500W (as is the case in the USA) might be relevant for activities such as celestial reflection. The comment “Following further deliberation on this matter, we consider these might be appropriately authorised by an assigned scientific licence and propose to expand the access policy for scientific licences to include Advanced amateur frequencies when the proposed amateur class licence commences.” appears to suggest that only through Scientific Licences can there be any increase above 400W PEP.

The ACMA needs to check with their equivalent bodies in other countries where a high power limit is applicable as to the (1) interference issues ; and (2) EMC compliance issues.

The technical knowledge of those who might desire the use of power levels has changed significantly post the 2012-13 outcome. The WIA has made amateurs more aware of EMC though education. I know first-hand because I was a part of that push. The holder of Standard or Foundation licence levels would typically find that their stations would not invoke EMC field strength concerns, however there are the EMC analysis software tools that an Advanced (or other) holder can use to confirm that his/her/their station(s) conform.

I operate on VHF (50 and 144 MHz) and utilise both tropospheric and meteor scatter equipment however my station is modest and therefore there a considerable number of stations in other countries I cannot be heard/seen (digital modes) by. The RF power level is set in the LCD at 120W average power on digital modes (/ 400W PEP) and my typical transmit power is 100W so I am close to the power limit already. The extra 20 watts causes me technical as well as cost issues for a minimal


Page 5 :



improvement in EIRP but an increase to 1KW PEP / 250W average makes a 3dB improvement in EIRP and that becomes a worthwhile improvement for experimentation.

I use meteor scatter modes most weekends (as available) and undertake trans-equatorial communications experimentation for many months of the year.

---===---​

Noting the proposal mentioned in 8, are there other amateur experimentation uses that require higher power that you think should also be considered under assigned scientific licensing arrangements? (See section 6.)


There is no reason that any and all modes should not be available to Advanced holders even at powers to 1KW and beyond without the need to apply for, and subsequently renew, scientific licences.

For higher power situations ( much higher than 1KW ) then MAYBE a scientific licence MIGHT be appropriate. By the same token, very few experimenters would require this RF power level and they would be technically competent to attempt these experiments and already aware of EMC requirements.


The amateur licence is issued for “ the purposes of self training in radiocommunications, intercommunication using radiocommunications, and technical investigation into radiocommunications by persons who do so solely with a personal aim and who have no pecuniary interest in the outcome of the operations of the station “ i.e. gaining knowledge through experimentation and communication.

If the experimentation requires higher-than-normal power to derive useful outcomes then that still falls within the purview of the amateur licence, not an experimental licence.


---===---​


What are your views on the medium-term proposal to allow Advanced amateurs to apply for authorisation for other higher power use-cases under certain conditions? Please provide brief information to help us understand your view. (See section 6.)


My comments in Section 9 apply here also.


---===---​

Is a 1kW power limit appropriate? Why or why not? If not, what alternative do you propose and why? (See section 6.)


A power limit of 1KW (or more) for Advanced holders is a reasonable figure for those who wish to experiment in communications and should become the revised standard, without recourse to a high power permit.

Many will not utilise the higher power as most commonly-available transceivers produce around the 100-200W figure, and without further amplification – adding cost through purchase, design and construction and then finally the increase in their monthly power bills, the EMC trigger conditions are unlikely to be reached.


Those who have a genuine desire to break through the existing limits of signal attenuation will be the only users likely to take up any significant higher power option.



Page 6 :



---===---​

Are there particular bands that you consider should or should not be able to be accessed for Advanced amateur higher power operations? Which band(s) and why? (See section 6.)

There is no reason to limit any high power versus frequency operation in legislation. Those who wish to experiment at these levels will already be aware of EMC concerns and will take evasive action. They are the users who will utilise EMC software to check for Level1 or Level 2 compliance.

The general Advanced user will only trigger Level 2 at 400W PEP if they have (a) high gain antennas,

low antenna heights, (c) extremely close neighbours. The same holds true for higher power operation as the EIRP is raised by about 2.5:1 ( less than 3dB).


Continued awareness is the real answer. Not legislation.


---===---​



What use-cases would require stations to operate at power limits for Advanced amateurs higher than the 400W currently permitted? (See section 6.)


Per Section 12, same comments apply.


For each use-case mentioned in 13, please briefly answer: Why is a higher power limit needed?

The typical free-space loss in dB can be determined for almost any path given distance and frequency, power level, antenna gain and feeder losses, and the effect of obstructions. Those calculations provide a receiver input signal level for a specific transmitter power level. The situation can exist where there is no path workable at the standard power levels and this is where the higher power limits come into effect. Those conditions might be required where is no actual calculable path but brute force scattering may achieve the receipt of signals – not otherwise achievable at low power but easily done at high power. An example of this is true tropospheric scatter at VHF to microwave.


Whether that RF power limit is 1KW or 1.5KW is defined in the legislation is of more concern to the ACMA rather than the individuals pursuing this form of experimentation. By all means, leave the power limit for Advanced class holders undefined.


What are the specific limitations of the current power limit?


In some experimentation styles, it is too low to achieve the desired outcomes.

An example may suit to illustrate this point. Some stations in Japan have high power available and in use. Others do not. The trans-equatorial path experiments and communication at 50MHz reveal that we can hear/see their signals well before the reverse is true. We mostly know which stations are known to operate at high power (identifiable by callsign) so they become markers of TEP. Eventually the lower power stations become detectable – maybe – but not always.



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What power level is required?


That is a question without background and without defined answers. Every circumstance has different parameters applied. In some cases a power level of 100W might be the correct answer, in others 1KW+ is correct. Radio propagation via such paths does not follow the normal path calculations as every path is different.


My personal experimentation in Meteor Scatter activities has proven to me that high power is more than desirable, it is basically mandatory. Unlike historically earlier times, we have easier back-channels to ask details of transmit power and antenna gains are in use. That provides better insight into what ‘power * gain’ product ratio is required to achieve a communication path.

What is the technical description of this power level requirements (for example, transmitter output power, emission mode)?


Much of the experimentation has become easier to evaluate with the introduction of digital techniques using software such as WSJT-X or MSHV on the various amateur bands as low as LF but more commonly at HF, VHF and above. The digital mode implementation brings with it other issues namely equipment frequency stability, timing stability.


By LCD, we are currently allowed to transmit on digital modes with an RF output power of 120W average on any band. In at least some cases, that is not sufficient, and hence my support for a higher power level.


Common names for modes I presently use are FT8, FT4, MSK144,and Q65, but I have been known to use PSK31, RTTY, SSTV and even hand or computer morse previously. Again, all are constrained by the existing 120W power levels (per LCD).


What amateur service frequency bands would be used?


Every band from MF to UHF, and possibly above that also. There are plenty of experimenter types (as against communicators) who would like to explore new boundaries only achievable through higher power.


How often will a higher power level be required?


As required. Not all communication experiments happen all of the time, and not all require the higher RF power levels.


What is the location of the station?


That is a variable factor also. The station might be at an already-known location (eg RRL data) but other times the location might be a short-term stay on/near the top of a mountain. It is entirely dependant on the nature of the experiments, the frequencies used, the antenna style and gain/loss.


There is no defined answer to a generic question.



Page 8 :




Should potential higher power authorisations be limited by location, position, event or something else? (See section 6.) Please provide details to support your answer.





In short, no. The Advanced class holders who wish to utilise a higher-than-average transmit power will already be well aware of their ‘power * gain’ product at any given band and the proximity of those values as EIRP and EMC Level 2 criteria.





Common sense should always be applied : do you walk in front of a microwave dish antenna ? No, because the EIRP can be considerable even with a relatively low transmit power and the transmitter is currently activated. Do you let others do so ? No, even to placing physical barriers to prevent same.



Every case should be considered differently – by the operator given that he/she is more aware of the current operating conditions of the equipment than any ACMA personnel (who might assess this situation) might be.





Summary :



There are too many parts of the transition equation not really confirmed in any of the documentation released, the least of all surrounding the AMC role into the future, or of a body who might replace them.



For a change I am not nit-picking the draft Class Licence document with the exception of previous comments about naming the “AMC” in legislation.



The ACMA wants to devolve the amateur service to a Class Licence status and it appears that wish to do so to decrease the effective cost to the ACMA through funding and resources, and any responsibility that they can divest, and will do so (regardless) without real acceptance of that outcome to the service(s) affected.



Please accept my comments as constructive and contemplate the options suggested above.


28 November 2022
 
V

VK2RK

Guest
Breaking News ---- a Small Victory ----


23 May 2023
AMATEUR CLASS LICENSING UPDATE
We would like to inform you the Australian Maritime College (AMC), has decided not to extend its deed for the provision of amateur licensee services beyond February 2024.
In light of the AMC’s decision and the planned move to class licensing of amateur services, we have taken the opportunity to review how amateur radio qualifications and call signs can be best supported under a class licence framework.
Background
For some time, the AMC managed several functions on behalf of the ACMA, including conducting amateur radio operator exams, issuing qualifications and recommending call signs for successful candidates to the ACMA.
However, after examining how to provide the best continuity of service for amateurs, we are proposing an alternative way to deliver these services.
New, more effective arrangements
We will no longer use a deed arrangement to provide amateur radio qualifications and call sign recommendations. Instead, we have decided to update the amateur radio qualification and call sign framework alongside the class licence implementation, and manage some of these services ourselves.
New accreditation procedures
We propose to use the network of voluntary assessors used by the AMC as accredited assessors under a scheme managed by the ACMA. Assessors will be able to conduct theoretical and practical examinations for amateur radio. Qualified and experienced amateur operators will be able to seek ACMA accreditation to conduct amateur radio examinations. As part of this accreditation work, we are:
  • preparing operational guidelines for accredited assessors
  • developing examination material
  • compiling a list of allocated and available call signs to go on our website.
The ACMA will still be responsible for approving the amateur radio syllabi.
Better alignment of qualification levels
The new framework will keep the Foundation, Standard and Advanced qualification levels for amateur radio examinations. This aligns with the qualification levels in the proposed class-licensing arrangements.
ACMA to issue qualifications and call signs
Under the new arrangement, qualifications will be issued by ACMA staff after an application from a person who has passed an examination. We will continue to be the call sign administrator and issue call signs to amateurs with recognised qualifications.
These arrangements are consistent with our amateur spectrum management obligations under the International Telecommunication Union’s Radio Regulations and the Radiocommunications Act 1992.
Next steps
We want to introduce the new accreditation scheme at the same time as the class licensing arrangements. At this stage, we expect to consult on the new accreditation scheme in August 2023. We welcome your feedback through the public consultation process, and we’ll keep you updated on progress.
To prepare for the move to class licensing, we have changed the renewal periods for non-assigned amateur licences to 12-months only. This will help amateur licensees make a smooth transition to class licensing.
We are grateful for your engagement and assistance in this transition, and look forward to a smoother, more efficient framework.
 
VK3YNV

VK3YNV

Administrator
Staff member
So, in summary, the AMC will be out of the picture after Feb Next Year, the new arrangment will be the ACMA issuing the licenses and maintaining the database, with accreditation being the subject of a consultation process later this year. We are getting a class license come what may, but retaining some of the key features of the current amateur licensing. Thus we retain our obligations under the ITU regulations.

Personally, I would like to see some SADARC members become accredited assessors. Maybe a good topic for a future club discussion.
 
V

VK2RK

Guest
VK3YNV said:
Personally, I would like to see some SADARC members become accredited assessors. Maybe a good topic for a future club discussion.
Click to expand...
When the time comes I will apply
 
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V

VK2RK

Guest
Interesting document found on the internet from ACMA
CRIS (Cost Recovery Implementation Statement)

Page 37 Ref 84 gives me the impression that things had not been well between the ACMA and the AMC, that ACMA was already prepared for the AMC pulling the plug, but this is speculation on my part and I have no evidence however here in the language used you can make up your own mind, the document was dated 1st September 2022

"This service is provided by a third-party provider, but, in the event the third-party provider is no longer able to provide the service, the ACMA is required to perform this function. This now reflects the revised effort required to provide the service applied to the ACMA’s standard hourly rate"

The concerning part is the proposed examination fees that are proposed with an increase of 60%
Well looks like Cris is about to shaft us.


349590026_1460153898087355_218774712266141975_n.jpg
 
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V

VK2RK

Guest
The ACMA has issues another request for consultation to proposed fee increases.
I have submitted a submission that I have posted on this forum under a separate thread, also have sent a similar document to the Minister for communications.
I still think the ACMA is abandoning the class licence model, however the organization is showing inconsistencies. I have knowledge that others have also complained to the minister regarding the kind of changes the ACMA is proposing.

If you wish to contribute please make a submission and also write to the minister, lets take back control of our hobby/service.
 
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