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Trevor M5AKA
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OFCOM Amateur Radio BR68 Statement – First Impressions
By Trevor, M5AKA
Tuesday’s announcement by OFCOM represents the most radical shake-up
of BR68 since it was first introduced and is sure to generate considerable
discussion.
A major surprise is that it is a statement rather than a full consultation
as is usually the case. I believe it is a mistake not to hold a consultation
on such an important document.
The statement is on the Ofcom website at
http://www.ofcom.org.uk/consult/condocs/aradio/lifetimelicence/
The PDF is at
http://www.ofcom.org.uk/consult/condocs/aradio/
lifetimelicence/licenceformat.pdf
Club Callsigns
There is no mention of the special club regional designators used in
club call signs. These are currently optional and their absence presumably
means they’ve been dropped.
Some clubs invested considerable sums of money and volunteer effort in
using their club call sign with the Club Regional Designator (eg X for
England) for Internet domain addresses, publicity material, QSL cards,
clothing etc. OFCOM’s proposal will mean all that work will have
to be scrapped and redone.
Changes like this should not be imposed retrospectively. Clubs that wish
to continue using Club Regional Designators should be allowed to do so
or at the very least the clubs should be permitted to continue using their
regional prefix call signs for 6 months after the 1st October to ensure
an orderly changeover.
Foundation
Foundation will have access to the 10 Metre band.
I was surprised that they didn’t get some microwave access as well.
Ofcom in an earlier consultation on 2.4/5 GHz indicated that high power
(up to 125 watts eirp) licence exempt operation was being considered for
the 2.4 and 5 GHz bands. If an untrained licence exempt user can run up
to 125 watts eirp on these frequencies then surely a trained licenced
Foundation holder should be allowed at least the same?
The requirement for CE approval on the equipment used by Foundation holders
has been dropped. Note the wording change to “commercial equipment”.
This is a welcome change, as it should permit the use of cheap ex-PMR
equipment which is not CE approved for 70, 144 and 430 MHz.
Amateur Satellite Service
While Foundation will have access to all bands between 136 kHz and 440
MHz and all modes including Meteor Scatter, SSTV, DATV, FAX, RTTY, PSK-31
Packet etc they are, for some inexplicable reason, denied access to the
Amateur Satellite Service. They can legally transmit on frequencies used
by Amateur Satellites but are banned from carrying out QSO’s via
those satellites!!
The UK is the only country to deny its Entry Level licence holders use
of the Amateur Satellite Service. Allowing Foundation access to satellites
would permit Self-Training in areas such as Doppler shift and orbital
mechanics.
The regulator agreed in 2003 that Foundation holders would be allowed
to have QSO’s with Astronauts in space. Astronauts operate under
the regulations governing the Amateur Satellite Service. Since this matter
is not mentioned elsewhere in the document this privilege appears to have
been removed by the new BR68.
Identification
The old BR68 said you only need to identify “at the beginning and
at the end of each period of communication”. Now period of communication
is taken to mean a QSO so all you currently have to ID is at the start
and end of each QSO and at 15 minute intervals if the QSO lasts longer
than that.
The new BR68 says you have to identify in each transmission.
Now a transmission is the pushing of the PTT (yes CW especially full
break-in CW does complicate the issue!!). With the current BR68 if you
were having a QSO with somebody and they asked you a question you can
reply "Yes" with no call sign, under the new BR68 you would
have to say "M0xxx Yes".
You will now be able to identify in the mode that you are transmitting
in. This is a sensible change as previously in the case of data transmissions
it was necessary to send a separate 20 wpm CW ID.
Identification – Net Operation
The new BR68 says identification shall be “at least once every
15 minutes during net operations”. This is a significant change
from the existing BR68. Current Amateur practice is that participants
in traditional round-robin nets identify when it is their turn for an
over. For a net with 8 participants each taking 3 minutes an over it can
be 24 minutes before each participant gets a chance to ID. OFCOM appear
to be saying that you must identify every 15 minutes regardless of whether
it is “your over” or not.
Identification – Full Duplex Operation
Clause 13(b) appears to be badly worded. It doesn't cater for full duplex
operation. If two Amateurs were having a cross band full duplex QSO they
could transmit for hours without giving a callsign. It should have the
phrase "and every 15 minutes during the transmission" added.
Messages
The old BR68 said
“3(3) The Licensee shall:
(a) have no pecuniary interest (direct or indirect) in any operations
conducted under this Licence; and
(b) except as provided by sub-clauses 1(2) and (3) and except in the case
of activities on behalf of a non-profit organisation established for the
furtherance of amateur radio, not use the Station for business, advertisement
or propaganda purposes including (without limiting the generality of the
foregoing) the sending of news or messages of, or on behalf of, or for
the benefit or information of, any social, political, religious or commercial
organisation.”
The new one removes the “pecuniary interest” clause also
the text relating to transmission of “propaganda” and news
or messages on behalf of a religious organisation. There is no mention
in the new BR68 of any specific ban on political discussions or the transmission
of music.
Remote Operation
Up until now it has been necessary to apply for a separate NoV if you
wished to control your station remotely. Ofcom propose making remote operation
a part of BR68, this eliminates the need for separate NoV’s. It
is however, unclear as to why Ofcom have imposed a 100 Metre limit on
remote control using amateur frequencies.
Log
The mandatory requirement to keep a log has been removed. This has never
been an ITU requirement and there has never been a valid regulatory reason
for Ofcom to insist on mandatory log keeping. In practice I’m sure
Amateurs will continue to keep logs because it’s of benefit to themselves.
/A, /P and /M Suffixes
The use of /A, /P and /M has been made clearer but I have never understood
why Ofcom make them mandatory. There is no ITU requirement to use them
and it is unclear what regulatory benefit Ofcom gets from their use. From
the regulators viewpoint all they need to know is the stations approximate
location. It is already a requirement to give your location to within
at least 5 km if you are not at your home address, that and your call
sign are all that should be required.
QinetiQ are currently developing an Automatic Nationwide Direction Finding
system for Ofcom. This system will enable the regulator to pinpoint any
radio transmission to within a few metres. They will certainly be able
to tell if a signal is mobile.
There would be nothing stopping Amateurs continuing to use /A, /P and
/M suffixes if they wished and I’m sure most would, it just doesn’t
have to be mandated in BR68.
Operation By Licensee in CEPT Countries
Clause 16 only covers operation in CEPT countries for Full licence holders.
CEPT have recently introduced additional licence classes that are the
equivalent of our Intermediate and Foundation. As yet the UK is not a
signatory to these but hopefully this will change in the near future.
CEPT Novice (Intermediate) level licence
http://www.southgatearc.org/news/jun2005/cept_novice_licence.htm
CEPT Entry (Foundation) level licence
http://www.southgatearc.org/news/june2006/cept_entry_level_licence.htm
Internet Gateways
OFCOM appear to wish to maintain the existing cumbersome NoV system for
attended Internet Gateway systems. This severely inhibits the ability
of Amateurs to experiment and develop ad-hoc systems to meet short-term
requirements. There is no valid regulatory reason why Amateurs shouldn’t
be allowed to connect their rigs to the Internet as part of the standard
licence.
Repeater Operation
The ban on setting up attended cross-band repeaters as and when required
remains. It is unclear why. In the United States the FCC has no problems
with allowing Amateurs to operate both in-band and cross-band repeaters
as and when they require.
It would be a good idea to add a clause along the lines of FCC 97.205
into BR-68. (Paragraph (C) covers co-ordination issues). Such a clause
should be applicable to both repeater and Internet Gateway operation.
FCC 97.205 Tiny URL: http://tinyurl.com/pchzy
Full URL: http://frwebgate.access.gpo.gov/cgi-bin/get-cfr.cgi?TITLE=47&PART=97&SECTION=205&TYPE=TEXT
An example of cross band repeater operation for personal use would be
where an Amateur has a standard dual-band mobile rig, 50 watts on 2 metres
and 35 watts 70 cm, installed in their car. They switch it to "repeater
mode" so that any signal that appears on the 70 cm frequency is re-transmitted
on the 2 Metre frequency and visa-versa. The Amateur can then walk away
from the car carrying a 70 cm handheld and use the handheld to converse
with somebody on 2 metres using the rig in the car as a cross band relay.
This is standard practice in the United States but Amateurs who do it
in this country are in breach of their licence. This personal cross band
repeater facility could be incorporated into BR68 by amending Clause 7(3)
and (4) to remove the 100 Metre range limit and increasing the power limit
to 500 mw (all current handhelds have this low power setting).
Greater Clarity
On reading through the new unified BR68 I was struck by how much clearer
it was that the three old BR68’s that it replaces. OFCOM are to
be congratulated on producing such a concise easy to read document.
Responses to the Statement
While there is no formal consultation procedure there is nothing stopping
Amateurs letting Ofcom know their views on the new BR68. It is currently
in draft format, the final version will be produced later, so the more
feedback Ofcom get the better. The email address for comments is:
amateurcb@ofcom.org.uk
73 Trevor M5AKA
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