IMPORTANT STATEMENT FROM THE RSGB

PLEASE RELAY THE CONTENTS OF THIS STATEMENT TO YOUR CLUB/GROUP MEMBERS

Dear Secretary

Amateur Radio Licensing Consultation

As you are aware Ofcom proposes to shortly carry out a public consultation on the future of amateur radio licensing. As a precursor to the consultation they have placed on their website a document entitled; "Forthcoming Public Consultation on Amateur Radio Licensing".

The RSGB has deep reservations over the extent to which there will be 'consultation' and of Ofcom's rationale behind some of the options.

Ofcom have gone to great lengths in recent weeks to stress that the deregulation of amateur radio is not being considered at this time. In fact they are so keen to get this message across that they are by-passing negotiations with the RSGB and taking their message direct to special interest groups, clubs and individual amateurs.

Since the RSGB was given sight of the first draft of the consultation document in December 2004, we have been arguing with Ofcom, that if they do not intend to take steps to deregulate amateur radio now or as soon as International negotiations will allow then why does the option remain as part of the consultation?

Every public statement that Ofcom have made they have stressed that they will not recommend any options to make amateur radio Wireless Telegraphy Act licence exempt (deregulation) at this time. However, they have been unwilling and unable to make the statement that they will NOT consider making amateur radio WT Act licence exempt in the future.

When published, the consultation will not give radio amateurs a real choice. It is our belief that Ofcom have already decided that there will be two changes to the amateur radio licence.

• To make amateur radio licences valid for life;
• To provide licences electronically and free of charge.

Along with this proposal, there will be three further options to consider:

• Continue with the annual licence;
• A longer term licence (5 or 10 years);
• Deregulation - No licence required.

Ofcom are strongly recommending a 'Life time' licence that will be free if obtained via the internet. They have assumed that all amateurs have access to a computer and are computer literate. Those amateurs who do not have a computer can, Ofcom believe, just 'pop' along to their local library or any public place, Internet café etc, to obtain their licence.

They recognise that this may not be possible in all cases, and those amateurs who do not have computer access or do not feel comfortable with computers will still be able to 'purchase' a paper copy. Yes, 'purchase' the paper copy does not come free of charge!

It is difficult for the RSGB to argue against a 'FREE - Lifetime licence' most people will accept that this is a generous gesture by the administrator and the RSGB would have no problems in recommending this proposal if we did not have serious concerns over Ofcom's motives.

Ofcom states that a `Lifetime Licence' will ease the regulatory burden and cut costs. This is not true. The Wireless Telegraphy Act will still make amateurs subject to regulations. The regulatory burden cannot be eased whilst the regulations continue in force. The licence may be free and it may last a 'lifetime' but the administration to issue the licence remains.

Ofcom states that amateurs will be kept informed of any changes to the amateur radio licence terms and conditions either electronically or by post. Ofcom will not be able to rely on their database to achieve this unless every licence holder keeps Ofcom informed of changes of address or internet service provider. Licence holder's next of kin will also be expected to ensure Ofcom is advised should the licence holder become a silent key. We know that this is unlikely to happen. Either way this will incur substantial costs.

The only way that Ofcom can reduce the costs and the administration is to 'Deregulate'

Despite Ofcom assurances it is the RSGB's belief that if it were possible they would deregulate amateur radio now. They are not in a position to do this because the UK government are signatories to a number of international agreements affecting cross border amateur radio operation. It is UK government policy, of long standing, not to break treaty obligations but to 'negotiate out' if it is seen to be beneficial to the UK to do so.

Ofcom have stated that it would take around five years to do this. Five years is a very short space of time!

Why does the RSGB believe that a `Lifetime' licence is the first step to deregulation?

Radio amateurs currently receive their licence from the Radio Licensing Centre in Bristol. The RLC is an agency of the Post Office and they are contracted to Ofcom to issue amateur radio licences. This contract runs out in September 2006.

Will it be renewed?

Ofcom pay the RLC to issue your licence. Costs need to be reduced! There will be a substantial cost saving if that contract is not renewed.

What are the other options post September 2006?

Ofcom could invite tenders. This is most unlikely, as by 2006 the issuing of most other licences including maritime and aeronautical licences will have been hived off to other organisations. In business terms the issuing of just amateur radio licences is not commercially viable. Commercial organisations exist to make profit and there will be no profit in issuing approx 50,000 amateur radio licences particularly with all the administration costs that go with it?

Ofcom could themselves do the work by taking the task 'In House'. This is costly - Staff, Database, ongoing tasks. The reason behind a 'Lifetime' licence is to reduce the regulatory burden and costs not just on the individual radio amateur but on Ofcom also.
Ofcom would need to recruit staff and commission a computer system if they decide on this option. This is at the time when all the experienced amateur radio administrators (formerly from the RA) are leaving Ofcom and are returning to the Civil Service. Even directly employed staff that are less costly in real terms, than civil servants, will still be a substantial cost.

The RSGB is concerned for the future of amateur radio because any relaxing of the controls be it licensing or in the examination structure will be a serious threat. The only way that Ofcom can meet its desire to ease the regulatory burden and related administrative costs is to take the need away and in the case of amateur radio that means to take away the need for a licence in other words - deregulate.

They make statements such as the Repeater and Packet network will be maintained; that current spectrum access rights would be maintained; that Ofcom would continue to manage the spectrum and maintain their enforcement activities. The truth is not so clear, 24GHz and 79GHz has or will be lost to automotive radar. Ofcom has decided not to maintain this spectrum access. How can we accept their statements at face value?

Ofcom are pulling out their representatives at a European and International level because their view is that spectrum users should bear the cost of representation at this level. Can we trust them to look after our interests on the international stage? Amateur radio is not a protected service and even when the Radio Investigations Service (RIS) operated as part of the RA, amateur radio did not receive the protection from intruders or interference that our spectrum allocation warrants. How is Ofcom going to protect our interests when the Enforcement and Policy Unit, as the RIS is now known, has been `cut to the bone' by Ofcom and is now down to quarter of the size it was in 2003?

As you all know RSGB has been looking after the interests of radio amateurs for over 90 years. The Radio Society was formed by early experimenters including Oliver Lodge and Gerald Marcuse. Today it is still run by radio amateurs for radio amateurs. We are mandated by the ITU to represent radio amateur's interests in the UK. That is our fundamental role.

Ofcom was created with a number of core functions including introducing 'Spectrum Trading', easing red tape for the benefit of industry and commerce, and wherever possible cut costs. The organisation is Treasury funded and its ethos is to gain maximum revenue out of the radio spectrum at the same time as reducing the costs of managing the resource. Additionally there is a legal requirement for Ofcom to prove, before removing a burden, that an existing regulatory burden is unnecessary. That proof has never been provided to RSGB.

I started this `brief by saying that it is difficult to argue against a 'Free' Lifetime licence.
I will finish it by saying Beware of the 'Trojan Horse'.

Over the next few weeks the RSGB will be arranging Regional Meetings across the UK and inviting Special Interest Groups to briefings on the licensing consultations. Our regional teams will be visiting as many clubs as possible to put the Society's views and recommendations to members and non members, we will also be providing statements, on our website and elsewhere, that individual amateurs can use to inform Ofcom of their concerns for the future.

We collectively must make Ofcom aware that we will not accept deregulation at anytime.

I hope that we can count on your support.
Warm regards

Peter Kirby, G0TWW
General Manager
Radio Society of Great Britain
April 2005.

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