OFCOM CONSULTATION DOCUMENT

 

OFCOM this week released their consultation document on the future of Amateur Radio in the UK and their proposals to move the hobby forward.

It is an interesting if somewhat long document with one or two minor errors but on the whole, a considered look at the hobby I love.

I am going to attempt here to formulate my thoughts prior to responding in full to the document and I hope that ALL amateurs in the UK will do the same.  This is REALLY important to the future of our hobby and the biggest changes in some time, right across the licence levels.

Before I start, I want to thank OFCOM for their considered approach to modernising Amateur Radio.  It is a complex task, involving parties well outside the UK and outside Amateur Radio as a whole.  I do not envy them the task.  That said, I reserve the right to disagree with them where I feel they have not thought something through well enough.  I also reserve the right to change my mind after due consideration.  This is of course, a working document and the changes are due to happen over a three year period.  We do however, need to respond to this NOW!  The closing date for you to air your views is 4th September 2023.  This will come sooner than you think!

I am going to respond to the questions asked in the document in order and also add some of my own thoughts.  I would appreciate any thoughtful comments on the proposals, or even my answers.

Question 1: Do you agree with our proposal that each licensee should only be able to hold one personal licence? Do you have any other comments on this proposal?

I have never understood why anyone would need to keep more than one callsign, other than to use as a club licence.  When I got my A call, I simply stopped using my B call.  Why would I need more than one?  Of course, both my calls allowed 400W and both were Full licenses.  I have never had a Foundation or Intermediate licence.  If someone wishes to use QRP, they can still do that using their highest level of licence.  I was also under the impression that it was not possible now to actually hold more than one callsign at the same licence level, other than a club call or other NoV?  All this said, I agree with the proposal.

Question 2: Do you agree with our proposals to permit greater supervised use of the radio equipment by others? Do you have any other comments on this proposal?

This is a long needed update and will simplify the rules for everyone.  I am in total agreement with this proposal.  It makes sense to me that anyone with a licence should be able to supervise those without.

Question 3: Do you agree with our proposal to use M8 and M9 for Intermediate licensees going forward? Do you have any other comments on this proposal?

This seems a perfectly good idea to me.  The 2 prefix has always seemed somewhat anomalous to me and would have been better used a a special event prefix or similar, rather than in normal use.  The rules for callsigns do not allow two numbers at the beginning of the call, so that means a forced RSL, even in England.  The whole thing is a mess.  It also seems to me that it has created some friction as Intermediate licensees do not feel they are included in the callsign groupings and therefore feel different to the other licence levels.  (I reserve the right to be wrong on this one!)

Question 4: Do you agree with our proposals to change our policies on the use of RSLs? Do you have any other comments on this proposal?

The whole RSL situation is fraught with problems.  Of course, we are used to it but it makes no sense that forgetting to include a RSL when on holiday is in breach of your licence terms.  I broadly support this proposal as I am sure that those in the countries outside England will wish to continue to use them anyway, being rightly proud of their location.

Question 5: Do you agree with our proposals to allow the use of any suffix? Do you have any other comments on this proposal?

EDIT.  It has been pointed out, quite correctly, that I did not read this section thoroughly enough.  It means I can use G0VGS/SUFFIX, so G0VGS/QRP would finally be valid and I could even use G0VGS/POTA.  Thanks for the correction Mike and I have no problem with this proposal.

Question 6: Do you agree with our proposals to allow a change of call signs? Do you have any other comments on this proposal?

This is one of the proposals that will cause the most debate I think.

Oh dear.  This is quite a mess.  Let's make one thing clear from the start.  There are more than enough unused callsign blocks to go at, without reissuing the callsigns of the deceased!  There are M1 and G0 callsigns that were never released, or that were swapped voluntarily for M0's.  Lots of M5 callsigns that were never released, just as an example.  A callsign is very VERY personal to most amateurs.  The legacy of the callsign can long outlive the Radio Amateur.  What about re-releasing G5RV for example?  I know that is not in the proposed pool but you get the idea.  Looking at my own callsign on your favourite search engine will bring up reams of projects that I have been involved with in the past and the present.  These will never go away.  If G0VGS were to be reissued after my demise, someone would have all that legacy against them and would have to constantly answer questions about it.  Madness!  Two years does not even come close to removing that legacy.  There is simply no need to do this.  The G5+3 callsigns are proving very popular and there are plenty of them.  10 years might be a better option if this really must be done!

The exception to all of this is where a family member wishes to retain the callsign of a loved one.  The rules around this need to be simplified.  It is easy enough to prove ones identity in this day and age and as long as the person requesting the callsign holds the appropriate licence level and can prove their identity and relationship to the deceased, I do not see a problem.  They inherit legacy and callsign.

On top of this, why oh why do we need to be able to change our callsigns 'periodically'?  I mean, just why?  I cannot imagine being anything other than G0VGS.  The callsign defines me.  It is who I am.  This proposal just seems like madness to me and a completely unwarranted complication.  If a callsign needs changing for medical or other reasons, that can be applied for and dealt with on a day to day basis.  I cannot imagine that this is a common occurrence, so why look to make the issue worse?

Question 7: Do you agree with our proposals on the limits to how many call signs can be held? Do you have any other comments on this proposal?

In addition to the first question, this applies to clubs.  Clubs over the years have generally held 2 licenses.  In the old days, this would have been a Class B and a Class A.  This allowed club members to operate using the club call at their own licence level.  The RA saw this as Morse and No Morse licenses.  This was fair enough with the licence structure at the time.  Allowing a club up to 5 licenses is more than enough.  One could have thought that following the RA principles, 3 would have been the obvious choice.  Having an additional 2 is allowing more flexibility and I see no issue with it.

Question 8: Do you agree with our proposal to simplify special event call signs? Do you have any other comments on this proposal?

This makes total sense to me.  A simplification all round.

Question 9: Do you agree with our proposals to increase transmit power? Do you have any other comments on this proposal?

This is another subject that has needed to be addressed for some time.  I am well known for disagreeing with trying to separate licence levels by transmit power but it would seem this is what we have.  Given that this is not going to change, I totally agree with allowing Intermediate licence holders to use 100W.  The VAST majority of Amateur Radio transceivers have 100W PA stages.  I do not agree with giving Foundation licensees 20W though.  This is a pointless and ill thought out level of power.  A lot of VHF/UHF transceivers have a mid power of 25W.  This would mean that the licensee would still be limited to 5W on low power or be in breach of their licence.  I therefore propose that a better power level for the Foundation level would be 25W. 

Question 10: Do you agree with our proposed changes to remote control operation? Do you have any other comments on this proposal?

I see no reason to disagree with this proposal

Question 11: Do you agree with our proposed changes to Beacon operation? Do you have any other comments on this proposal?

This starts to ring some alarm bells with me (see question 12 for more).  I have no issue with the proposal on beacons in principle but they must be subject to frequency allocation.  All beacons should be in the sub-band for that particular allocation and this needs stating.  Currently I see nothing stating this.  Without a statement, anyone could set up a beacon anywhere.  I know that this is supposedly covered by the 'non-interference' clause but the band plans are there for a reason.  Whilst I appreciate that the band plans are not in the remit of OFCOM, I feel the regulator has some responsibility here.

Question 12: Do you agree with our proposed changes to Gateways? Do you have any other comments on this proposal?

Oh dear! Oh dear! Oh dear!  yes, that is 3 oh dears!  Takes a deep breath......

The subject of 'Personal Gateways' has been a thorny one for some time and the whole subject of Third Party Traffic was not helped by trying to include this within the Remote Operation section and dropping the term 'Third Party Traffic'.  The current system of regulation with a NoV requirement for third party traffic has worked very well on the whole and has been very well dealt with by the ETCC.  We all know there are issues at times but the expertise and experience provided by these volunteers is welcome.

That said, I understand those who simply want to go out for a walk with the dog and access Amateur Radio when out of range of a local repeater or gateway on their chosen mode.  I therefore have no objection in principal with this proposal.

There are however, some real potential issues with this.  The proposal even mentions hotspots.

The vast majority of hotspots are constructed of cheaply manufactured boards, mainly from China.  They are meant to be used with a limited aerial at very low powers.  Even then, there can be issues with radio equipment in the same location.  The thought of putting one of these on a high gain aerial makes me shudder!  Amplify them up to 5W and I can only try to imagine the spurious transmissions and harmonic content.  Having this completely unregulated is the thing of nightmares.  Putting a radio actually made for the job, either a radio made for normal Amateur radio use or a commercially built radio such a a Motorola or similar would not cause the same issue.

That said, there is only so much spectrum.  It is not mentioned in the proposal that I can see but I would assume that this would only be available to Amateur Radio Operators on Primary bands?  If this is the case, most hotspots only work at UHF frequencies so would not be eligible.

Also, if these proposed gateways are only allowed on Primary band allocations, that pretty much leaves 2m.  Where in the band will these be allowed?  The proposed power level is in general about 5 times more than the allocated power level given to gateways with a NoV.  This is going to lead to all gateway keepers moving away from the NoV system and will potentially cause chaos, at least in the beginning with inter-gateway interference.  The potential for loops is also much increased.

These are my initial thoughts and I am sure there will be more issues I have not thought of as yet.

Question 13: Do you agree with our proposed changes to repeaters? Do you have any other comments on this proposal?

Carrying on from my comments above, I assume that this proposal only applies to Primary allocations?  If not, then any 5W repeater would have to have expensive cavity filters.  There is no mention of repeater splits but assuming a 600kHz split, where in the band are the proposed to be allowed?  the 2m repeater allocation is very well populated already and I cannot imagine where non-NoV repeaters would actually be able to be deployed without causing interference to other users.

The whole proposal around gateways and repeaters needs a LOT of additional thought in my opinion

Question 15: Do you agree to Ofcom’s proposals to permit some limited airborne use? Do you have any other comments on this proposal?

I have no objection to this proposal

Additional comments:

My first thought when I read these proposals was, who is going to police this?  OFCOM have generally shown a reluctance over the last few years to get involved in policing the Amateur Radio hobby.  There is already an increasing amount of abuse on the bands and even when the abusers are identified, nothing is done.

With the proposals including increased PEP at all licence levels and the relaxing of the NoV requirements for gateways and repeaters, I do wonder just what is going to happen.  One can only hope that the amateur community will try and self police wherever possible but, especially in major population areas, there are going to be problems.  If OFCOM cannot police the current issues, I have real concerns as to their ability to deal with potential issues from these proposals.

I guess, as they say, the truth will out!

I would welcome your comments as always.

73 Ian