Revision	Date	Description	Distribution
A.00	25^th August 2003	First Draft	WA VHF Group Committee
A.01	22^nd September 2003	2^nd Draft, for review	General Membership, for vote at General Meeting
1.00	31^st October 2003	For Release	WA VHF Group Committee WA VHF Group Website ACA

2 Introduction

This submission is made in response to the Australian Communication Authority’s discussion paper entitled “A Review of Amateur Service Regulation” of August 2003.

A brief overview of the WA VHF Group is provided, followed by the Group’s position in relation to each of the issues raised in the discussion paper.

2.1 WA VHF Group

The West Australian V.H.F. Group (Incorporated) is based in Perth, and is the single largest license holder and operator of terrestrial VHF, UHF and SHF beacons in Australia.

The group has operated continually since 1955, and recently held its 535^th General Meeting.

The Group’s aims include:

q To facilitate the association of persons interested in the encouragement and scientific development of VHF radiocommunication in all its branches;

q To provide a centre of information, instruction and advice on all matters pertaining to VHF radiocommunication and experimentation;

q To form or co-operate with civil defence networks or organisations in any emergency.

The Group’s membership is drawn from a wide demographic, and includes university lecturers and professors, Information and Communications Technology (ICT) professionals, technicians, consultants, as well as individuals purely interested in radio as a hobby. The co-ordinated, long-term investigation of VHF (and higher frequency) radio propagation has resulted in a greater understanding of anomalous propagation; the models developed in the Amateur Service have been used to identify the source and propagation mechanism of sporadic co-channel interference to Emergency Services’ VHF communications, and to develop mitigation strategies. It is also noteworthy that members of the Group established several world records for long distance VHF and microwave propagation.

The WA VHF Group views the Amateur Service as providing an invaluable resource for the development of leading edge skills and technologies in the field of radio propagation and channel coding mechanisms, and welcomes the prospect that this service may soon be made available to experimenters currently disenfranchised by the existing license system.

2.2 National Value of Amateur Radio

Although opinions on the National Value of Amateur Radio were not specifically elicited in the Discussion Paper, we wish to make a submission on this matter, as follows.

As noted in the Discussion Paper, the ITU Radio Regulations define the Amateur Services as:

A radiocommunications service for the purpose of self-training, intercommunication and technical investigations carried out by amateurs, that is, by duly authorized persons interested in radio technique solely with a personal aim and without pecuniary interest.

The ITU definition therefore describes three purposes, only one (intercommunication) of which closely fits the assumption that Amateur Radio is “essentially a hobby”[1]. Whilst it is true that a section of licensed Amateurs are solely interested in the use of the service for establishing intercommunicating with a regular set of contacts, or perhaps in trying to contact as many stations as possible, there are many licensed Amateurs with only incidental interest in talking to other stations. Rather, many stations are interested in advancing their own personal knowledge of advanced radiocommunication techniques (eg, development of Forward Error Correction on fading satellite links). Indeed, the technical investigations conducted by these “passive” or “invisible” Amateurs leads to advances in radio science, which soon manifest themselves in the non-amateur scientific and commercial arenas.

The analogy is often used that the radio spectrum reserved for the Amateur Radio Service in Australia is akin to the land reserved for National Parks. Assuming that the essential use of this “National Reserve”[2] is for hobbyists only, creates an impression that this invaluable asset is wasted on an extremely fortunate elite, similar to saying that National Parks are only useful for people that enjoy bushwalking. Continuing the analogy, we contend that significant National Value is delivered by the amateur researchers active within the environment, similar to the value delivered by amateur botanists, amateur ornithologists, etc.

Sadly, the Amateur Radio Service in Australia is often administered as though the sole value is hobbyist intercommunication; it is our belief that this attitude deters Australian science and engineering students from making use of the spectrum and opportunities available to them under the international Amateur Radio Service, and thus having Australia’s bright young minds develop their own skills for use in their careers, thus helping ensure Australia remains efficient in the 21^st century. It is interesting to note the manner in which countries such as Japan and Thailand have used the Amateur Service to build an entire industry, and to leapfrog past Australia in radiocommunications. For example, internet service delivery to regional Australia will be provided mid 2004 by a Thai satellite, developed by licensed Amateur Radio operators in a commercial environment, as a progression of the technology transfer from University of Surrey in the UK; the technology was predominantly developed and refined within the Amateur Satellite Service. Similarly, India is also advancing its national capacity through Amateur Radio, and will launch an Amateur Satellite in 2004.

It is important that the Amateur Radio Service be defined and promoted in a manner which attracts young engineers and scientists, and that experimentation be facilitated within the technical constraints of the service; often, experimental configurations may be prohibited by legacy administrative restrictions[3].

We therefore propose:

“That ACA policy be amended to deliberately and consistently refer to, and deal with, the Amateur Radio Service in a manner that addresses all aspects of the ITU Regulations, and which facilitates the engagement and support of the educational and scientific communities, thus ensuring that full National Value is derived from the use of the spectrum assets reserved for the Service.”

2.3 Further Information

Should further information be required, please contact the following:

Dr Wally Howse Phone (08) 9317 2967

Mr Don Graham Phone (08) 9446 2864

Dr Alan Woods Phone (08) 9383 2822

Mr Chris Hill Phone (08) 9313 6060

3 Prohibition of international communications under certain conditions

The ACA proposes to:

• maintain the substance of subsection 5(3) of the Amateur LCD.

WA VHF Group Agrees.

4 Content of Amateur Communications

The ACA proposes to:

q maintain the substance of section 6 of the Amateur LCD; and

q require that ‘Transmissions between amateur stations shall not be encoded for the purpose of obscuring their meaning, except for control signals exchanged between Earth command stations and space stations in the amateur-satellite service.’

Modern Communication systems are highly dependent upon higher order modulation schemes and “line coding” in order to achieve high bandwidth efficiencies and/or sustained throughputs in the presence of noise, interference or otherwise impaired communications channels (eg fading, multipath etc). Many of these modulation schemes or line coding algorithms are based on the same mathematics as cryptography; spread spectrum is indeed a form of cryptography, required a priori knowledge of the public key, or considerable processing effort to recover the key if unknown.

Many commercial off the shelf radio systems, available in retail stores throughout Australia, use cryptographic systems, partly to provide a modicum of privacy, and importantly, to provide a higher tolerance to noise and interference. It would be counter-productive for an experimental medium (Amateur Radio) to be less authorized to experiment and develop new improved communications art, than its class licensed cousins.

It is however, recognized that there is a need for Amateur Communications to be “recoverable”, to ensure that unscrupulous users are not using Amateur frequencies for the carriage of traffic which contravenes the LCD.

Finally, cryptographic techniques are also useful in “digitally signing” a transmission or message, so as to ensure the authenticity and integrity of a message. (This can be done without necessarily obscuring the meaning of the message).

WA VHF Group proposes that:

q technical mechanisms which obscure a message may be developed, experimented with and employed, but only if the necessary information is lodged with [ACA or WIA] and made public, such that a third party may successfully monitor the communications. That is, the obfuscation of the message is negated through the compulsory public availability of the necessary recovery mechanism, thus allowing unfettered experimentation to be undertaken.

5 Third Party Communications

The ACA proposes to:

q maintain the substance of subsections 5(1) and 5(2) of the Amateur LCD; and

q amend subsection 5(4) of the Amateur LCD to remove the prohibition of third party communications.

WA VHF Group Agrees.

6 Morse code below 30 MHz

The ACA proposes to:

q discontinue the Morse code requirement in the bands below 30 MHz; and

q combine the AOCP and AOLCP grades, and the NAOCP and NLAOCP grades.

The ACA seeks comment and suggestions about:

q how early removal of the Morse code requirement could be implemented without causing inefficiencies in the implementation of new regulatory arrangements.

The WA VHF Group agrees with the earliest possible merging of the AOCP and AOLCP grades, and the NAOCP and NLAOCP grades.

Please see our comments regarding the Foundation license, below.

7 Amateurs must be qualified—minimum competence level

The ACA proposes to:

q continue to verify the operational and technical qualifications of any person wishing to operate an amateur station, in accordance with Article 25.

The ACA notes that the proposals in section 6.4 of this paper have an impact on the examination structure for amateurs. For example, the discontinuation of the Morse code requirement means that testing that skill in examinations will no longer be required.

The WA VHF Group agrees, however we believe that the existing mechanism for granting advanced standing on the basis of tertiary studies is inflexible, and currently excludes many young professionals that would otherwise use Amateur Radio to develop their skills in radiocommunications.

The register of acceptable tertiary qualifications calls needs to be updated, to reflect the diverse range of courses that cover communications theory to an equal or higher standard than currently required in order to pass the “Full Theory” or “Novice Theory” exams. For example, exemption is currently available for holders of a Bachelor of Engineering (Communications); this qualification was last offered by a West Australian University in 1988. Young Graduates from the Bachelor of Engineering (Electrical) or Bachelor of Engineering (Electronic) courses have the requisite theory, yet must either sit the infrequently held amateur exams, or make special application to the ACA for an individual assessment of their qualifications.

The WA VHF Group therefore proposes:

That a register be maintained of acceptable tertiary qualifications which satisfy the minimum competence level, thus exempting the holder from the need to sit any further examination.

8 Operating parameters—purity and stability of emitted frequency, and maximum power

The ACA proposes to:

q continue to impose limits on the purity and stability of emitted frequencies, and maximum power limits on amateur stations in accordance with the ITU’s requirements for transmitting stations.

As a result of the possible removal of Morse code testing (detailed in section 5.4), the emitted frequency and maximum power privileges for certain amateurs would increase.

WA VHF Group Agrees.

9 Use of Callsigns

The ACA proposes to:

q maintain the substance of sections 8, 37 and 44 of the Amateur LCD.

WA VHF Group Agrees.

10 Amateur Communications During Disasters

The ACA proposes to:

q make no changes to current regulatory arrangements in regard to amateur communications during a natural disaster.

WA VHF Group Agrees.

11 Amateur-Satellite Service

The ACA proposes to:

q make no changes to current regulatory arrangements in regard to interference to other stations by stations in the amateur-satellite service.

WA VHF Group Agrees.

12 How Many Licensing Options?

The ACA seeks comments about:

q the above future licensing options for amateurs, including amalgamation of licensing options and the possible introduction of a Foundation licence.

WA VHF Group supports a two tier model:

q Unrestricted, and

q Foundation

However, WA VHF Group believes that the Foundation License should allow up to 10W P_x (30W P_Y) on all amateur bands, and all modes. This is to encourage the widespread use of the Amateur Service as the preferred range of spectrum for young experimenters to operate in, rather than “working around” the Amateur LCD and experimenting in the Class Licensed ISM band or similar (often unknowingly violating the LCD for that non-amateur service). The 10W limit provides a power limit which is moderately above the power limits for class licensed CB radios and Wireless LAN devices, yet still provides an incentive for demonstrating a high level of knowledge, and upgrading to the Unrestricted license.

Given the current state of the art, it is expected that new entrants to Amateur Radio would seek to experiment in the lower to mid microwave bands, with bandwidths of several Mbps, and using sophisticated modulation and coding schemes. Low bandwidth, narrowband communications are unlikely to be of interest, except perhaps for certain weak-signal modes, and for communications via satellite transponders.

WA VHF Group therefore recommends that:

q the Foundation License should allow up to 10W P_x (30W P_Y) on all amateur bands, and all modes

13 How Are We Going to License?

The ACA seeks comments about:

q the future licensing regime (class or apparatus) for amateurs.

The WA VHF Group prefers that the existing Apparatus license scheme be retained.

As noted by the ACA in the Discussion Paper, the existing Apparatus License “creates a direct relationship between the ACA and individual Amateurs, which is beneficial to both parties in circumstances of interference investigation and resolution”.

Additionally, it seems beneficial for an Australian Amateur to hold an Apparatus License when seeking a reciprocal license from another country.

14 Examinations, Certificates, Callsigns and Station Location

The ACA seeks comments about:

q the administration of amateur callsigns, including whether the current Australian amateur callsign template should be changed to reflect Article 19 post WRC-03.

The ACA proposal to replace the present State indicator following the VK prefix with an arbitrarily assigned digit 0-9 is strongly opposed. The existing geographically based callsign allocation template is much preferred as an aid to station identification. The suggested advantage in callsign portability is of lesser significance than consistency of location information carried by the callsign.

The WA VHF Group prefers that the existing callsign template be retained.

15 Potential Outsourcing—Obligations and Opportunities

The ACA seeks comments about:

q the possible outsourcing of amateur examinations, certificates, callsigns and, if class licensing proceeds, station location information.

The WA VHF Group prefers that the ACA retain the role of issuing licenses, certificates, allocation of callsigns, and maintenance of the licensee database.

Note that several amateurs have expressed a desire that licensee details, particularly address details, be suppressed upon request; this is particularly of interest to serving members of the Australian Defence Force, and other individuals such as school teachers.

16 Reciprocal Licensing

The ACA seeks comments about:

q the possibility of Australia participating in CEPT Recommendation T/R 61-01; and

q the consequential class licensing of overseas amateurs.

The WA VHF Group supports the process whereby Australia participates in the CEPT concept of international interchangeability of Amateur Licences

17 Interference Protection for Other Radiocommunications Services

The ACA proposes to:

q introduce a ‘no interference’ policy for amateur operators in relation to interference caused to domestic equipment.

This is by far the most contentious issue in the Discussion Paper.

The WA VHF Group rejects the assertion that Amateur Radio is essentially a hobby. It is wasteful in the extreme for policy and regulations to be formulated based on this erroneous premise. Rather, the policy and regulations should ensure that the maximum value for Australia is extracted from the spectrum assigned to Amateur Radio; this is best achieved by addressing all aspects of the ITU definition, which states in part that Amateur Radio is a “radiocommunications service for the purpose of self-training, intercommunication and technical investigations”.

The widespread, and increasing reliance in Australia on wireless technologies, and the interaction of wireless technologies with other services, raises the need for a comprehensive national strategy to address the issues of:

q Electromagnetic Compatibility (EMC)

q Electromagnetic Interference (EMI)

q Electromagnetic Radiation Hazard (EMR)

In terms of EMC, Australia is better served now than a decade ago, largely thanks to the “C-Tick” compliance requirements. However, sub-standard equipment is still sold into Australia, and sub-standard installations are routinely deployed which cause compliant subsystems to be rendered vulnerable to even low level radio signals.

It is important that a national awareness and capability be developed for designing, commissioning, and/or troubleshooting systems which involve intentional radiators of electromagnetic energy, unintentional radiators of electromagnetic energy, and devices which are vulnerable to radiated or conducted electromagnetic energy. When driven by appropriate policy, Amateur Radio can provide a key mechanism for the development of such a national capability.

Attempting to override the rules of physics by regulation is extremely unlikely to work; indeed, it may simply serve to exacerbate future problems, as the existing EMC capability atrophies in the face of an unworkable regulation (ie the mooted “no interference” edict).

It is the position of the WA VHF Group that:

q It is essential that Amateur Licencees should not be discriminated against and unjustly held responsible for EMC problems due to a third party’s substandard equipment, or penalized in circumstances where the real or perceived problem cannot be fixed because of non cooperation by a neighbour;

q The ACA’s EMC expert assistance continues to be available for the remediation of difficult to solve issues;

q The Amateur Service itself continue to be protected against interference from other systems, particularly where the offending system is operated in violation of its license conditions;

q That Amateur Radio be incorporated into a National EMC Strategy, and used as an invaluable training ground on how professional, commercial and consumer systems and subsystems should be designed and commissioned.