VK2RK
Active member
Submission for consultation of fees 2023-24
Robert Campiciano
308 Morebringer Lane, Balldale, NSW, 2646
Manager, Revenue Assurance, Grants and Financial Operations
Australian Communications and Media Authority
PO Box 78
Belconnen ACT 2616
Fees 2023 - 24
Consultation request radio-communications, telecommunications and broadcasting services that are subject to charging arrangements via the draft 2023–24 Fees CRIS.
In response to the request for an opinion regarding the fees for 2023-24 please consider the following.
My remarks are solely aimed at those parts in the proposal that encompasses the Amateur Radio Service.
Presently I am very confused on the position that the ACMA is taking regarding licencing of the Amateur Radio Service, considering the last announcement from the ACMA that the Australian Maritime College (AMC) is not renewing the deed instrument beyond February 2024 (ACMA email issued on 23 May 2023.)
The ACMA released document "Class Licensing Update" the following statements are:
“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:
1/ preparing operational guidelines for accredited assessors
2/ developing examination material
3/ 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. “
Further states in the same document -
“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.”
and that –
“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.”
From the above statements:
It seems that the ACMA is proceeding with the changeover to a class licence. (Regardless of the overwhelming opposition)
Confusion:
Confusion arises when careful examination of the CRIS consultation document that was received June 5, 2023 in the following is found on Page 2 Table 1 (Key Stake Holders) tabulated definitions -
“Apparatus Licences
Community, commercial and national broadcasters
Individuals (for amateur and marine services)
Government entities
Commercial organizations (mining, construction, communication)”
from this table I get the impression that the ACMA is no longer proceeding with the Amateur Radio class licence change over, a contradiction within the document released prior to the CRIS consultation on the 23 May 2023.
This confusion will exist in many that respond to this consultation.
I then consider that since the Manager of Revenue Assurance, Grants and Financial Operations releases a document in which the Amateur Radio Service is defined under an apparatus licence, is further confirmed by the tabulated examination charges for the 2023-24 period, that this will be the case for 2023-24 contrary to the previous release by the ACMA, a very confusing situation in understanding the final intent of the ACMA in regards to Amateur Radio Licencing and procedural.
Cost recovery model:
Returning to the CRIS proposal. Since the intent of the ACMA as affirmed in the released document on the 23rd May 2023 that it will be using assessors that are not employed by the ACMA, but Radio Amateur Volunteers that provide said service for the furtherance of the Hobby/Service free of any charges, there is no cost associated in the examination process aside the formation of a examination question pool that already exists, how can the ACMA justify such fees and charges as stated in the CRIS proposal. Then the fact that the ACMA is a public service department largely financed by public tax payers, that the Amateur Radio service is a non-profit organization that provides benefits to the Australian public free of charge, how can the ACMA treat the Amateur service the same as a commercial entity that profits from the use of a public asset (Radio Spectrum)
The Amateur Radio service should not be considered or treated the same as commercial services that the ACMA oversees.
Previous conduct of the ACMA in administration of licencing:
In the past the ACMA prior to the AMC failure, had contracted the Wireless Institute of Australia in the administration and examinations pursuant to all to do with the allocation of licences and call-signs to be used in the Amateur Radio Service, the only role of the ACMA in this process was to apply the allocated call sign in its data base and collect the licence fee.
I am not privy as to the reasons why the ACMA decided to use a commercial entity (AMC) that would do so for profit regardless of the then promoted by the ACMA to be the principle of cost recovery in that the change over from the WIA to the AMC would not incur any cost increases to the Amateur fraternity, this aside it is not clear why the ACMA went down the AMC path only to say that the experiment failed with costs to the end user increasing, the whole process was and is shrouded by privacy agreements that hides the true intent of the AMC and that of the ACMA in so far the reasons of the AMC terminating the contract with the ACMA will never be known.
Clearly the attempt of the ACMA to divest its administrative duties under the act having done so at the expense of the Amateur Radio Service, with little thought of the impact it would have on the service, the policy decisions made by those that have a poor understanding of what the Amateur service is about has done a lot of damaged, if the self-governance principle that was introduced by the then DOC is to be applied then that self must be the governing body representing the true interests of the Amateur service without any pecuniary element.
I must once again be critical on the manner that the ACMA has and is engaging the public, forcing a position so designed and contrary to the opinion of the very public it’s consulting by manipulating the results in favour of the designed position that the ACMA wishes to achieve.
Self-Governance and Compliance:
The role of the ACMA in a self-governance model is that to oversee the adherence to the Radio Communication act in force at the time.
With the overseen responsibility the ACMA has to discharge its duties in the compliance area with diligence, when it comes to Amateur Radio the AMCA has miserably failed.
I can point to many points of failure in this compliance area but no point in doing so in this document but happy to provide evidence is so required, on the other hand the ACMA is well aware of its failures.
The ACMA fees:
I would like to address the cost recovery principle and fees that the ACMA is proposing
The ACMA claims that a fair cost recovery amount is $226.00 per hour and so proposes. With all due respect these public service and their efficiency comes into question.
In today’s economic climate this amount is excessive, a public service who is already funded by Tax dollars to then charge $226.00 per hour for their time in handling what is required under the act that places this responsibility onto the ACMA is simply outrages the Amateur Radio Service is a non-profit organization afforded protection via the legislation and the ACMA wishes to charge time to provide said protection?
What is the ACMA is placing at risk.
It’s clear that the ACMA has lost the understanding of the true value of the Amateur Radio Service, In the past the department employed people that either belonged as Amateurs or technically understood the service and its advantages it provided to the Australian community.
Services we provide-
1/ At short notice the Amateur community can mobilise communications under disaster scenarios with self-funded equipment at no cost to the Australian government.
This has been the case since WW2 to Ash Wednesday to the several QLD floods and more recent floods etc. the list is very long.
2/ Many lives have been saved due to Amateur Radio interventions, the soon forgotten or acknowledged, I personally am responsible for saving the lives of two soles lost on a mountain in that I directed a Victorian police helicopter to the location utilizing Amateur Radio equipment, there are many more stories of others contributing in similar manners that are not considered by todays administration as to have no value and been ignored.
All indicators and actions of the ACMA point to this my conclusion, that the ACMA considers the Amateur Radio service a nuisance, contributing only costs to the department that can be minimised by divesting its responsibilities under the act progressing to their class licence model, in doing this ignoring the damage it will do to the Amateur Service.
Social and cost benefits the service provides.
As our population ages, more mental issues associated with Anxiety and depression become a cost to the Australian society, the Amateur Radio service provides mitigation and therapy at no cost to the medical system, by providing the means to combat loneliness driven depression, doing so by allowing the immediate ability to communicate with likeminded individuals via radio. As time progresses and the number of widow’s increases this situation will further benefit the Australian community.
With disabled and intellectually challenged individuals the service further provides benefits from blind people to speech therapy for those that have issues if forming words or sentences and so much more, we as a service are a conduit providing many human health therapies to the many.
Educational advantages.
The Amateur Radio Service acts as a doorway in to the Electrical, Electronic, Digital, Communication and Information Technologies, it does this by the wide range of self-learning topics.
In the past, many via the Amateur Radio service progressed into engineering and I am sure can if allowed do so in the future, we are no longer recognised to have value to the Australian society as demonstrated by the recent proposed actions and proposed changes of the ACMA.
Australia has a shortage of trained people such as engineers and trades skilled individuals, the result of many years of neglect of those institutions that provided such training, Amateur Radio is part of that past training mechanism.
Is the ACMA prepared to compromise one of the no cost to government organizations that aids in the purpose of training future engineers or trades persons?
Proposed Examination Charges
The proposed examination charges are just nonsense, when using the Australian Martine College fee is $95.00 that it is considered an excessive fee already, when the CRIS proposes $490 for Advanced and Standard with $377 for foundation the response will be that of dismay towards the preposterous amount and that the ACMA is even thinking of such sums.
The majority of new operators are likely to be retired or widowed on social security payments, or young person’s yet to join the work force, the proposed charges will act as a disincentive becoming a huge cost to the future of Australia.
I understand that many of my above comments are really not in line with what the consultation seeks, however I felt it important to be said in view that the Revenue Assurance Department could be disconnected from the Policy division that is driving the proposed changes to the detriment of the service.
In respect to the consultation
a/ There is no valid reason for the ACMA to conduct examinations, in the past it provided the examination papers to the clubs that then would hold the examination returning the candidates papers to the department for marking. A simple low cost exercise.
b/ Under the self-governance model that was introduced by the then Department of Communications back in the early 2000. The Amateur radio community via its clubs is more than adequate to instruct and examine candidates, further the ACMA had appointed the Wireless Institute of Australia prior to the AMC under a deed to conduct said administration via the clubs and authorized assessors, such that the ACMA had divested itself of any administrative conduct only retaining the licencing allocation and renewal mechanism with the current call sign register.
It should be mentioned that the Amateur Radio fraternity due to its diverse type of members is adequately qualified to control the technical requirements of training and examinations. Many are technicians or Engineers with many years of experience.
c/ The training and examination should be either returned to the Wireless Institute of Australia or the individual clubs as it used to be under the old Department of Communications, with the use of no cost to the ACMA of approved assessors as mentioned in the ACMA statement 23rd May 2023 in turn will remove the cost to the ACMA negating the proposed charges to the Amateur Radio service, reiterating that the proposed charges and fees will act as a disincentive to attracting newcomers into the service negating them and the Australian community the prospective values mentioned above.
Thank you for the opportunity to comment
Robert Campiciano
308 Morebringer Lane Balldale, NSW, 2646
Robert Campiciano
308 Morebringer Lane, Balldale, NSW, 2646
Manager, Revenue Assurance, Grants and Financial Operations
Australian Communications and Media Authority
PO Box 78
Belconnen ACT 2616
Fees 2023 - 24
Consultation request radio-communications, telecommunications and broadcasting services that are subject to charging arrangements via the draft 2023–24 Fees CRIS.
In response to the request for an opinion regarding the fees for 2023-24 please consider the following.
My remarks are solely aimed at those parts in the proposal that encompasses the Amateur Radio Service.
Presently I am very confused on the position that the ACMA is taking regarding licencing of the Amateur Radio Service, considering the last announcement from the ACMA that the Australian Maritime College (AMC) is not renewing the deed instrument beyond February 2024 (ACMA email issued on 23 May 2023.)
The ACMA released document "Class Licensing Update" the following statements are:
“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:
1/ preparing operational guidelines for accredited assessors
2/ developing examination material
3/ 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. “
Further states in the same document -
“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.”
and that –
“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.”
From the above statements:
It seems that the ACMA is proceeding with the changeover to a class licence. (Regardless of the overwhelming opposition)
Confusion:
Confusion arises when careful examination of the CRIS consultation document that was received June 5, 2023 in the following is found on Page 2 Table 1 (Key Stake Holders) tabulated definitions -
“Apparatus Licences
Community, commercial and national broadcasters
Individuals (for amateur and marine services)
Government entities
Commercial organizations (mining, construction, communication)”
from this table I get the impression that the ACMA is no longer proceeding with the Amateur Radio class licence change over, a contradiction within the document released prior to the CRIS consultation on the 23 May 2023.
This confusion will exist in many that respond to this consultation.
I then consider that since the Manager of Revenue Assurance, Grants and Financial Operations releases a document in which the Amateur Radio Service is defined under an apparatus licence, is further confirmed by the tabulated examination charges for the 2023-24 period, that this will be the case for 2023-24 contrary to the previous release by the ACMA, a very confusing situation in understanding the final intent of the ACMA in regards to Amateur Radio Licencing and procedural.
Cost recovery model:
Returning to the CRIS proposal. Since the intent of the ACMA as affirmed in the released document on the 23rd May 2023 that it will be using assessors that are not employed by the ACMA, but Radio Amateur Volunteers that provide said service for the furtherance of the Hobby/Service free of any charges, there is no cost associated in the examination process aside the formation of a examination question pool that already exists, how can the ACMA justify such fees and charges as stated in the CRIS proposal. Then the fact that the ACMA is a public service department largely financed by public tax payers, that the Amateur Radio service is a non-profit organization that provides benefits to the Australian public free of charge, how can the ACMA treat the Amateur service the same as a commercial entity that profits from the use of a public asset (Radio Spectrum)
The Amateur Radio service should not be considered or treated the same as commercial services that the ACMA oversees.
Previous conduct of the ACMA in administration of licencing:
In the past the ACMA prior to the AMC failure, had contracted the Wireless Institute of Australia in the administration and examinations pursuant to all to do with the allocation of licences and call-signs to be used in the Amateur Radio Service, the only role of the ACMA in this process was to apply the allocated call sign in its data base and collect the licence fee.
I am not privy as to the reasons why the ACMA decided to use a commercial entity (AMC) that would do so for profit regardless of the then promoted by the ACMA to be the principle of cost recovery in that the change over from the WIA to the AMC would not incur any cost increases to the Amateur fraternity, this aside it is not clear why the ACMA went down the AMC path only to say that the experiment failed with costs to the end user increasing, the whole process was and is shrouded by privacy agreements that hides the true intent of the AMC and that of the ACMA in so far the reasons of the AMC terminating the contract with the ACMA will never be known.
Clearly the attempt of the ACMA to divest its administrative duties under the act having done so at the expense of the Amateur Radio Service, with little thought of the impact it would have on the service, the policy decisions made by those that have a poor understanding of what the Amateur service is about has done a lot of damaged, if the self-governance principle that was introduced by the then DOC is to be applied then that self must be the governing body representing the true interests of the Amateur service without any pecuniary element.
I must once again be critical on the manner that the ACMA has and is engaging the public, forcing a position so designed and contrary to the opinion of the very public it’s consulting by manipulating the results in favour of the designed position that the ACMA wishes to achieve.
Self-Governance and Compliance:
The role of the ACMA in a self-governance model is that to oversee the adherence to the Radio Communication act in force at the time.
With the overseen responsibility the ACMA has to discharge its duties in the compliance area with diligence, when it comes to Amateur Radio the AMCA has miserably failed.
I can point to many points of failure in this compliance area but no point in doing so in this document but happy to provide evidence is so required, on the other hand the ACMA is well aware of its failures.
The ACMA fees:
I would like to address the cost recovery principle and fees that the ACMA is proposing
The ACMA claims that a fair cost recovery amount is $226.00 per hour and so proposes. With all due respect these public service and their efficiency comes into question.
In today’s economic climate this amount is excessive, a public service who is already funded by Tax dollars to then charge $226.00 per hour for their time in handling what is required under the act that places this responsibility onto the ACMA is simply outrages the Amateur Radio Service is a non-profit organization afforded protection via the legislation and the ACMA wishes to charge time to provide said protection?
What is the ACMA is placing at risk.
It’s clear that the ACMA has lost the understanding of the true value of the Amateur Radio Service, In the past the department employed people that either belonged as Amateurs or technically understood the service and its advantages it provided to the Australian community.
Services we provide-
1/ At short notice the Amateur community can mobilise communications under disaster scenarios with self-funded equipment at no cost to the Australian government.
This has been the case since WW2 to Ash Wednesday to the several QLD floods and more recent floods etc. the list is very long.
2/ Many lives have been saved due to Amateur Radio interventions, the soon forgotten or acknowledged, I personally am responsible for saving the lives of two soles lost on a mountain in that I directed a Victorian police helicopter to the location utilizing Amateur Radio equipment, there are many more stories of others contributing in similar manners that are not considered by todays administration as to have no value and been ignored.
All indicators and actions of the ACMA point to this my conclusion, that the ACMA considers the Amateur Radio service a nuisance, contributing only costs to the department that can be minimised by divesting its responsibilities under the act progressing to their class licence model, in doing this ignoring the damage it will do to the Amateur Service.
Social and cost benefits the service provides.
As our population ages, more mental issues associated with Anxiety and depression become a cost to the Australian society, the Amateur Radio service provides mitigation and therapy at no cost to the medical system, by providing the means to combat loneliness driven depression, doing so by allowing the immediate ability to communicate with likeminded individuals via radio. As time progresses and the number of widow’s increases this situation will further benefit the Australian community.
With disabled and intellectually challenged individuals the service further provides benefits from blind people to speech therapy for those that have issues if forming words or sentences and so much more, we as a service are a conduit providing many human health therapies to the many.
Educational advantages.
The Amateur Radio Service acts as a doorway in to the Electrical, Electronic, Digital, Communication and Information Technologies, it does this by the wide range of self-learning topics.
In the past, many via the Amateur Radio service progressed into engineering and I am sure can if allowed do so in the future, we are no longer recognised to have value to the Australian society as demonstrated by the recent proposed actions and proposed changes of the ACMA.
Australia has a shortage of trained people such as engineers and trades skilled individuals, the result of many years of neglect of those institutions that provided such training, Amateur Radio is part of that past training mechanism.
Is the ACMA prepared to compromise one of the no cost to government organizations that aids in the purpose of training future engineers or trades persons?
Proposed Examination Charges
The proposed examination charges are just nonsense, when using the Australian Martine College fee is $95.00 that it is considered an excessive fee already, when the CRIS proposes $490 for Advanced and Standard with $377 for foundation the response will be that of dismay towards the preposterous amount and that the ACMA is even thinking of such sums.
The majority of new operators are likely to be retired or widowed on social security payments, or young person’s yet to join the work force, the proposed charges will act as a disincentive becoming a huge cost to the future of Australia.
I understand that many of my above comments are really not in line with what the consultation seeks, however I felt it important to be said in view that the Revenue Assurance Department could be disconnected from the Policy division that is driving the proposed changes to the detriment of the service.
In respect to the consultation
a/ There is no valid reason for the ACMA to conduct examinations, in the past it provided the examination papers to the clubs that then would hold the examination returning the candidates papers to the department for marking. A simple low cost exercise.
b/ Under the self-governance model that was introduced by the then Department of Communications back in the early 2000. The Amateur radio community via its clubs is more than adequate to instruct and examine candidates, further the ACMA had appointed the Wireless Institute of Australia prior to the AMC under a deed to conduct said administration via the clubs and authorized assessors, such that the ACMA had divested itself of any administrative conduct only retaining the licencing allocation and renewal mechanism with the current call sign register.
It should be mentioned that the Amateur Radio fraternity due to its diverse type of members is adequately qualified to control the technical requirements of training and examinations. Many are technicians or Engineers with many years of experience.
c/ The training and examination should be either returned to the Wireless Institute of Australia or the individual clubs as it used to be under the old Department of Communications, with the use of no cost to the ACMA of approved assessors as mentioned in the ACMA statement 23rd May 2023 in turn will remove the cost to the ACMA negating the proposed charges to the Amateur Radio service, reiterating that the proposed charges and fees will act as a disincentive to attracting newcomers into the service negating them and the Australian community the prospective values mentioned above.
Thank you for the opportunity to comment
Robert Campiciano
308 Morebringer Lane Balldale, NSW, 2646