Review of non-assigned amateur and outpost regulatory arrangements – consultation 01/2021 - closes 2nd April 2021
We have reviewed the regulatory arrangements for non-assigned amateur and outpost stations. We are now consulting on options to optimise those arrangements.
https://www.acma.gov.au/consultations/20...ion-012021
This consultation includes and option to change amateur licensing from its current form as apparatus licenced - under an LCD - to a class licence..
Download the two amateur-related documents from the link above, read thoroughly, submit your comments/thoughts.
The
Executive Summary states :
The Australian Communications and Media Authority (ACMA) is reviewing regulatory arrangements for the operation of non-assigned amateur and outpost stations, as indicated in the
Five-year spectrum outlook 2020–24 (FYSO). This paper proposes changes to amateur licensing arrangements and associated administrative functions. A separate consultation paper discusses proposals for changes to the arrangements for outpost licences.
This review aims to identify the best licensing mechanism that would reduce regulatory burden and minimise costs for licensees, while preserving the current operational utility for licensees. The review is examining whether the existing licensing framework best achieves the objective or whether it could be better met through alternative licensing arrangements.
At the same time, the ACMA is seeking to ensure that any changes to the amateur licensing arrangements allow Australia to continue meet its obligations relating to the regulation of the amateur radio service under the International Telecommunication Union (ITU) Radio Regulations (ITU RR) and manage access to spectrum consistent with the objects of the
Radiocommunications Act 1992 (the Act). We are also interested in considering whether there are opportunities for greater self-regulation of some matters relating to the amateur services, such as call sign management, and new arrangements for frequency coordination for beacon and repeater licences, by the amateur radio sector.
The review is consistent with our ongoing work to seek opportunities to deliver better regulatory outcomes, including self-regulation, and is consistent with the Australian Government’s
Deregulation Agenda.
Our review is considering several options to authorise the operation of amateur stations, each with varying degrees of regulatory, administrative and financial burden.
> Option A: keep the existing apparatus licensing arrangements with the same licence conditions
> Option B: simplify the current licensing arrangements and licence conditions by amending the
Radiocommunications Licence Conditions (Amateur Licence) Determination 2015 (Amateur LCD)
> Option C: transition to class licensing arrangements for amateur stations operating on common frequencies (non-assigned amateur stations). The operation of amateur beacon and repeater stations (assigned amateur stations) would continue to be authorised under apparatus licensing arrangements, possibly with new arrangements for frequency coordination and assignment.
Read these two documents carefully !!!
Extract :
As of 27 January 2021, there were 15,300 (14,762 non-assigned and 538 assigned) amateur licensees in Australia; the second largest apparatus licence type after land mobile licences.
Now look at the 14,762 non-assigned licences as generating about $50 each as income to the ACMA, so a little over $700K per annum for existing licences. Not really very much.
New amateur licences being issued produce a little more income as the New Application fee is around $70 (the last time I looked & not recently) while Variation in Licences cost less at $40-$45 (again, the last time I looked & not recently).
Then take a look at what it costs the ACMA for the amateur service, and if you could isolate a figure, it would be far higher than the income figure. No wonder there is a move to adopt Class Licensing.
There were "talks" some years ago (>20) about moving the amateur service in Australia to a Class Licence basis. Its greatest appeal was that a zero fee was contemplated but all interference protection was to be lost, along with a number of other factors. Thw WIA was involved in these discussions at the time but the concept was eventually dropped as agreement was not reached.
But the world has moved on from then so maybe a Class Licence might be applicable now.
The bit in the Consultation Paper refers to it this way :
"All apparatus licences are subject to charges for licence issue and renewal, and an annual tax amount.
Class licences are general authorisations to operate a radiocommunications device of a specified kind, or for a specified purpose, or of a specified kind for a specified purpose on shared frequencies specified in the class licence, subject to the operation being consistent with any conditions in that class licence. As class licences are broad legislative authorisations, there is no licence issue or renewal, and therefore no associated licensing costs.
Class licensing is broadly similar to non-assigned apparatus licensing, as both enable people to operate devices on a shared set of frequencies. However non-assigned apparatus licensing relies on individual licences being issued before operation, which enables greater regulatory oversight of licensees where necessary, but at a greater cost to both the ACMA and licensees.
Given the similar utility that both non-assigned apparatus licensing and class licensing can provide for users, it is worth considering whether the additional regulatory oversight (and associated costs) for non-assigned licensees is warranted to facilitate the amateur service.
"
The line "As class licences are broad legislative authorisations, there is no licence issue or renewal, and therefore no associated licensing costs." becomes interesting to interpret.
My current view/interpretation is that the callsign issuing authority (ie A.M.C. at present) confirms the qualification of a candidate through an examination process (at a fee), issues a callsign (for a fee), then the person can start operating on amateur frequencies - no actual licence is issued.
I'm not too sure if such a "licence" would be recognised internationally, for those planning on visiting other countries and operating there, where the existing apparatus licences are recognised, at least at Advanced level. (Sure the user gets a Certificate of Proficiency but these are not the basis for overseas recognition, the Australian Licence documents are.)
Would there still be entries on the ACMA's Public Register ? No, because licences are not issued.
How would you check on someone you heard on air ? A public AMC register of all callsigns and quallification levels ??
The no-protection state is referred to in the very last line of the extract, although it does not expand on it. What is known is that CB licensees are a no interference-protection basis, either suffering from - or - generated by. That would then apply to amateurs too.
The entire amateur-related documents require in-depth study, and the closing date for submissions is the 2nd April 2021.
What do you see happening to the amateur service in Australia ?? This is your chance to assist in determining it's future.
(04-02-2021, 07:16 AM)VK4ADC Wrote: [ -> ]The no-protection state is referred to in the very last line of the extract, although it does not expand on it. What is known is that CB licensees are a no interference-protection basis, either suffering from - or - generated by. That would then apply to amateurs too.
The amateur service is already in a defacto no-protection state, most times anyone complains about interference, you get told to go sort it yourself these days, so nothing will change on that basis.
The one thing that does bother me in the new proposal is devolving the power to issue callsigns away to a private body.
With all the current animosity between various bodies and other issues within the amateur service, I don't think this is a particularly good idea.
Terry
You are not alone in your concern.
The AMC <--> ACMA Deed is now about 3 years into a 5 year deal so that would have to continue until, at least, it's expiry. The AMC has been issuing callsigns and assessing qualifications almost from the beginning of that Deed. So really the only change anticipated is a public register factor.
An alternative concept might be for the WIA, as the majority body representing the amateurs in Australia, to re-commence the testing of candidates, and issuing of Certificates and subsequently callsigns, plus maintaining a public register, so nominally an extension of the circumstances prior to the current Deed.
Either way, it is a non-Government entity with ultimate control. The problem is that the amateur service does not operate 'for profit' so there is nothing to encourage the ACMA to continue its role.
It used to be (way back when I started work in the late 1960s) that Government was 'public service' oriented, where it is now profit/loss oriented and ignores any facade of public service. Devolvement of loss-making functions seem almost standard now and the amateur service would certainly be classified as such.
I suspect that it will go Class Licence regardless of what our submissions suggest. That is the only way to take the loss factor off the ACMA 'bottom line'.
While you pay a licence fee you at least have some bargaining power with the ACMA but as soon as you go to a Class Licence system you finish up having none.
73s
Igor
I am not convinced we, as amateurs, actually have any bargaining power due to licence fees.
The estimates I can find for the number of amateurs in Australia range from 10,000 to 20,000. Let's be optimistic and say 20,000.
At $55 for a renewal, then that is $1.1 million. That is not very much when you consider the ACMA's total income to June '20 was $1,415,245,000 (according to their annual report).
So about 0.078% of their total income. I wonder what their expenditure on the service amounts to? I could easily see them burning through $1.1 million given the changes to the Act and LCD, ITU and other regulatory activities.
So if we are a net loss to ACMA we really don't have a lot of clout.
14,762 from the ACMA's own figures (see Doug's second post), so at $55 = $811,910.
Not much bargaining power there.
I knew I'd seen the number recently...
(05-02-2021, 07:37 PM)VK5TM Wrote: [ -> ]14,762 from the ACMA's own figures (see Doug's second post), so at $55 = $811,910.
Not much bargaining power there.
Not quite true. The $55 figure quoted previously includes GST. So the real income figure (at 10% GST) is $50, as the ACMA does not get to keep the GST component.
The calculator tells me $50 * 14762 = $738,100, so well under the $1M mark. Makes the amateur service less attractive to maintain by the ACMA.
All of the $ figures mean nothing in the greater scheme.
The question to be asked is about whether we are going to be happy with having the Class Licence changes - apart from there be no annual fees ??
I note this week's WIA news mentions this consultation but the WIA itself has not yet expressed their point of view. Then again, it
is early days.
I mean to sit with the existing apparatus-based LCD on one screen and the Class Licence conditions on the second and scroll each document to see what actual changes there are between them, noting these down. It hasn't happened - yet.
I agree that the "no interference / no protection" state has been in place for years, even if not officially.
There could be a side effect on the likes of our Intruder Watch operations under a Class Licence where we are not afforded ANY protection. Is that important ?
The main consultation document expresses three options for the future, and we should probably look much more closely at all of these options before anything else happens about it.
(06-02-2021, 07:04 AM)VK4ADC Wrote: [ -> ]I agree that the "no interference / no protection" state has been in place for years, even if not officially.
There could be a side effect on the likes of our Intruder Watch operations under a Class Licence where we are not afforded ANY protection. Is that important ?
There are already a multitude of countries that ignore any complaints about interference and do absolutely squat about it, so is it going to make much difference?
Need to do some more reading, but don't the international regulations and agreements cover interference regardless of any particular country's licensing scheme?
No GST on licenses.
I'm on the fence at the moment, I need more information before i can draw an adequate conclusion.
Do we have any Kiwi hams here that can tell us before and after experience when they changed over?
The whole no fees thing is attractive, but at what cost? Do we then get the chance for 5year or even 10year licence periods? Or maybe a true licence for life deal with the need only to inform when we change address?
The fine print really has to be discussed and voted on before anything so important is changed.
I found my last renewal notice which shows :
Renewal Notice No.: xxxxxxxxx
Total Tax: $ 51.00
Total Charge: $ 4.00
Total GST: $ -
AMOUNT DUE: $ 55.00
Ok, so the GST is $0 (zero) but there is a Charge of $4 included in the $55 - WHICH IS NOT EXPLAINED ON THE DOCUMENT ITSELF.
Oversight or on purpose ? Then again, do they actually get to keep the $4 fee (sorry, Charge) or does it go to the ATO or into Consolidated Revenue?)
But please don't let any of this distract from the main topic : Prospective changes to licensing of the amateur service in Australia.
In relation to :
"The whole no fees thing is attractive, but at what cost? Do we then get the chance for 5year or even 10year licence periods? Or maybe a true licence for life deal with the need only to inform when we change address?"
I have my suspicions that since a Certificate of Proficiency is for life then any Class Licence would be for life also. The ACMA would not care if you changed address if they aren't issuing any individual licences, only any organisation/body providing a callsign register would like them up-to-date. There would be no need for licences or renewals to be sent out so any address detail becomes inconsequential. (...duh... just like CB ! ...)
So, I have had a chance to put the current LCD on one screen, the Class Licence LCD on a second and what strikes me most is what isn't there...
There have been whole sections dropped into just a few words in the proposed LCD. The most obvious of these is this :
Part 2 Class Licence
6 Class Licence
This instrument authorises a person to operate an amateur station, subject to the conditions specified in Part 3.
..and..
Call signs (in the current LCD)
(1A) For the purposes of this section, the licensee of an amateur station (other than an amateur beacon station or amateur repeater station) may, on the following days, substitute the prefix letters VK in the call sign of the station with the prefix letters AX:
(a) 26 January;
(b) 25 April;
© 17 May.
Example If the call sign specified in the licensee’s licence is VK1ZZZ, the licensee may use the call sign AX1ZZZ on the days mentioned in paragraphs (a) to © above.
Note 26 January is Australia Day, 25 April is Anzac Day and 17 May is World Telecommunication Day.
... has been transformed into ...
call sign means a sequence of letters and numbers assigned to a person by the AMC as a call sign.
I think that the persons involved in deriving the LCD were short-sighted by inserting "AMC" as the assigning source, and it should have been something like "an authorised body" instead, given that the Deed between AMC and ACMA has an expiry only 2 years away. There are no guarantees that the AMC will continue in that role under a new deed.
Probably the largest portion of the Class LCD wording falls under this topic:
HCIS identifier means a unique identifier used to describe a geographic area in the ASMG.
where Schedule 2 Amateur station excluded bands and areas details the applicable HCIS regions
I won't go on to suggest that comparing the 'two LCDs' is compelling reading. It is not, but it should be done anyway.
Outwardly, nothing much really changes. Same classes of licence, frequency bands, power levels, callsigns, just no actual licences or annual fees. Any interference protection - not that has been much in the last few years anyway - no longer exists in legislation.
One thing that should be made apparent is that everyday amateurs would be in the Class Licence category if this is introduced.
Repeaters and Beacons (etc..) wil remain in the apparatus licence area, require frequency coordination, require annual licence fee payments with details remaining on the ACMA Public Register.
Closing date for submissions is 2nd April 2021. Do yours soon !
Just to keep you up-to-date :-
From text edition for :
http://www.wia.org.au/members/broadcast/wianews/ for 14 Feb 2021 :
"
Last week President Greg and Vice President Lee spoke about the upcoming consultation by our regulator, the Australian Communications and Media Authority (ACMA).
tinyurl.com/1wa5pu7e
Greg mentioned that this consultation is "Something that should be of both interest and concern of all Radio Amateurs in Australia". Greg also said the this very important consultation has the potential for major changes to the Amateur Radio Service and its licensing regime.
We as amateurs must carefully consider and weigh up the options that have been proposed by the ACMA.
The board of the Wireless Institute of Australia met last Tuesday to discuss the proposed consultation and the WIA response.
At this stage, the board will require more information in order to form an opinion on the proposed changes. The board has decided to meet with experts within our Amateur Community and for them to write
a discussion paper which will be put out to members for comment, probably in the form of a poll like that recently conducted by the WIA.
That panel will meet next week to commence the process.
"
Keeping you up-to-date :
From WIA News for 21 Feb 2021 :
"
Recently the Spectrum regulator, the Australian Communications and Media Authority (ACMA) issued a consultation document which details 3 options concerning the future of Amateur Radio in Australia. Significantly,
the ACMAs preferred option is changing to a Class Licence instead of the current apparatus licence.
This is a non-trivial change and has long term major ramifications on the Radio Amateur Service in Australia.
Note that a change to a class licence was rejected in a 2004 determination issued by the ACMAs predecessor organisation.
Any changes to the Radio Amateur Service licensing framework as proposed as the preferred option in the ACMA consultation
are likely to be permanent and irrevocable. Hence it is vitally important that the WIA response reflects the views of our members as well as, to the extent it is feasible, the views of the wider radio amateur cohort.
Next week the WIA will be releasing its position paper on the consultation and
initiating a poll to gather feedback from the amateur community. The WIA board and its supporting volunteer technical team have been investigating and researching the implications of the various options and burning the midnight oil since this consultation was released. The technical team has a great depth of skill and experience in the radio communications sector and its regulatory environment.
The WIA will be seeking feedback from its members and other interested amateurs via a registered poll. You must be registered to receive the poll with only one vote per ACMA id (persons only not repeaters!). Please note WIA members do not to need to register as you are pre-registered and will automatically receive the poll via MemNet email. In line with our previous practice, this poll will open to all Australian radio amateurs via pre-registering to receive the poll. I also ask that club presidents relay this registration information to their members as soon as possible.
You can register by entering the URL:
poll.wia.org.au into your internet browser.
We have had feedback from some (not all) Chrome browser users being unable to access the registration page due to a re-direction failure, in which case use the URL:
tinyurl.com/wiapoll
"
Closing date for YOUR submission (and everyone else's) is 2nd April 2021. Details about submissions ? Follow the links in the first post.
Latest from the WIA :
The WIA has reviewed the paper and conducted an analysis of the opportunities and risks each option poses to the operation of the amateur and amateur-satellite services in Australia. The major items for consideration follow:
Option A: keep the existing apparatus licensing arrangements with the same licence conditions
Option B: simplify the current licensing arrangements and licence conditions by amending the Radiocommunications Licence Conditions (Amateur Licence) Determination 2015 (Amateur LCD)
Option C: transition to class licensing arrangements for amateur stations operating on common frequencies (non-assigned amateur stations).
The operation of amateur beacon and repeater stations (assigned amateur stations) would continue to be authorised under apparatus licensing arrangements, possibly with new arrangements for frequency coordination and assignment.
The WIA board in consultation with the WIA Spectrum Strategy Committee have analysed the proposal, and has carefully considered the opportunities and risks it presents to the amateur service in Australia. We are now presenting our findings to members and the wider amateur service community and are inviting feedback on our findings and recommendations at this time that the WIA can then take into account when formulating our final submission to the ACMA.
To help with the feedback process, the WIA has presented two poll questions for consideration. The poll will be shortly open, and will be open for two weeks. The WIA then intends to publish its findings and will provide information and assistance at that time on ways you can support the WIA's position presented to the regulator. A copy of the polling paper and preliminary investigations is attached which also outlines the WIA committee position currently.
Your input will be important in shaping our final direction.
Please take the time to read and respond to the poll as your input is important. Only information from the poll can be used for the WIA submission.
Position Paper : weblink to PDF
Editor's comment : Please read the WIA position paper which will download via the above link. It raised some interesting thoughts in my mind as well as providing a suggested response to the ACMA. The ACMA's (b) option needs further investigation.
I received the WIA's missive and poll a couple of days ago.
I have read through it and I understand the WIA's position (I think).
What I don't have is an opinion, one way or the other, of my own. I really don't have a meaningful grasp of all of the ramifications of each of the options and I really don't have the will or time to make myself better informed.
My gut feeling (based on dealings with government departments in my real job) is that this is a fait accompli with the discussion/consultation phase little more than a box ticking exercise from the bureaucrats POV.
As it is a cost cutting exercise the Class Licence option is most likely, which is sad as it would remove the CEPT approval and thus reciprocal licencing but otherwise I am not sure it would have that much impact.
I have done a bit of reading of various bits and pieces of paperwork relating to this and I agree, it appears it will end up being a Class license regardless of what the outcome of the poll is.
From what I can glean, there seems to be a lot of holes in the proposed changes (other than keeping the status quo).
The one thing that absolutely needs to be changed, regardless of the final outcome is what Doug referenced previously - the naming of a body, ie AMC, to issue callsigns etc in legislation rather than the wording of "an authorised body" or some such similar wording.
(09-03-2021, 11:47 AM)VK2CSW Wrote: [ -> ]As it is a cost cutting exercise the Class Licence option is most likely, which is sad as it would remove the CEPT approval and thus reciprocal licencing but otherwise I am not sure it would have that much impact.
Colin
In view of COVID and all that stuff, I doubt that I will be travelling overseas in the next few years. I have a severe reluctance to hop aboard a 'silver bird' with 300 others who may - or may not - have COVID infection effects, immunisations aside.
That means that CEPT availability is not really an issue to me personally but there is a possible escape clause for me anyway : I gained a USA Extra Class licence (call KX4SX) just under two years ago. I
MIGHT be able to use that if I make it overseas. I haven't really looked into what use it might be as I did it more as a technical challenge rather than having any real plan to utilise it.
I have yet to re
-read the ACMA documents to see what explanations for the 'streamlining' have been supplied for option 2 before I make up my mind.
Thus my vote in the WIA poll hasn't happened as yet, and my own separate submission to the ACMA has yet to be done, but I (too) think it is mostly fait accompli as a Class Licence in the near future.
It is one year and nine days since we last came home from O/S. We would normally head to somewhere in the Pacific at least once or twice a year.
Maybe I should look into getting an F8, T31, E6 or YJ call, just for coverage
