ACMA WRAP on HIGH POWER TRIAL

[VK2AVR]

Hi Owen,

I did get my quote from WIA's page. However they have transcribed the information from the ACMA source document correctly, in my opinion. please see the attachment, I have circled the "or" for clarity.

the level 1 criteria can be reached by a) OR b) OR c). within part a) you must comply with i) and ii), same as part b). However if your transmitter average power is 100W or less and the antenna is inaccessible to the public then you are level 1 compliant.

[VK3RX]

examples of a type of place that is inaccessible to a member of the general public:
. the area around an antenna that is fenced and where entry is through a locked gate

So my antennas in my back yard which is fenced all around and both side gates have padlocks is considered inaccessible to the public?

[VK2AVR]

As a side note, I can't help but think that if rules were written in a well-structured programming language like C, that they would be easier to interpret. I was offered a job doing technical writing for a patent firm a while back and wading through legalspeak like this makes me more and more glad I didn't take the job.

Owen, apologies if I've offended but my reading/interpretation of the rules in ACMA's document is the same as the WIA's. I also feel pretty strongly that if the WIA's interpretation is wrong that we should fix it, because wrong information is worse than no information to me.

[VK3ALB]

Seems to me the tough part in all of this is the definition of inaccessible. Yes I've read the ACMA documents but I suppose I'm not the only one that wants to see it more clearly defined.

My antennas are at 7m, I have a lock on the only gate that allows access to my yard, no one can touch any part of my antennas or enter the exclusion zones unless they use a ladder to climb my shed or climb a tree. The ladder is locked inside the shed. Don't mind the dog, he doesn't eat much.

I think that makes my installation inaccessible and I'd be happy to argue the point all day.

[VK2OMD]

As a side note, I can't help but think that if rules were written in a well-structured programming language like C, that they would be easier to interpret. I was offered a job doing technical writing for a patent firm a while back and wading through legalspeak like this makes me more and more glad I didn't take the job.

Owen, apologies if I've offended but my reading/interpretation of the rules in ACMA's document is the same as the WIA's. I also feel pretty strongly that if the WIA's interpretation is wrong that we should fix it, because wrong information is worse than no information to me.

Geoff,

A guiding principle for people drafting these things is that "all ambiguities in the document can be resolved... in a court of law", but you don't want to go there, so making a clear draft is important.

9(1)(a)(ii) does depend on the meaning of "inaccessible to a member of the general public" which is not explicitly defined in the document per se, but 8(1) gives a possible insight into its purpose when it states "The RF field produced by a transmitter operated under the licence must not exceed the reference levels for general public exposure at a place accessible to a member of the general public." A court might determine that the meaning of "accessible to a member of the general public" means that any space that exceeds the reference levels for exposure is accessible to a member of the general public.

Of course, to put bounds on that space requires the assessment required of Level 2 criteria... which assesment this clause is to avoid.

I raised the example of a ground mounted quarter wave monopole on 80m (as was discussed) at 100W average power. It would seem hard to argue that such an antenna if it could for instance be touched by a person, was inaccessible... to what distance could be held to make it inaccessible.

Not though that in the case of a mobile at less than 100W 9(2), they don't specify any minimum distance, and although a different scenario in some ways (by way of being temporary at a location), it might be held that no minimum distance was also intended by 9(1)(a)(ii).

I agree with you, it isn't absolutely clear.

A 'safe' option is to not rely on 9(1)(a)(ii) (which is what I have done for my own assessments), a better option is to seek clarification from ACMA.

I have not seen the detail of the ACMA's consideration of some of the recent high power trial audits, perhaps their comments give insight into their interpretation.

Owen

PS: Ian White raises an interesting fact and that is the ACMA's selective dropping of the concept of reasonably accessible as set out in RPS3: "In areas that are reasonably accessible to the general public, measurements or evaluations of exposure must be undertaken to ensure compliance with the general public basic restrictions of Section 2."

The uses of "reasonably accessible" in RPS3 suggests that a risk managemetn approach is appropriate in considering the likelihood of access rather than the more absolute terms specified and the AL LCD (which nevertheless don't seem absolutely clear).

[VK4TI]

examples of a type of place that is inaccessible to a member of the general public:
. the area around an antenna that is fenced and where entry is through a locked gate

So my antennas in my back yard which is fenced all around and both side gates have padlocks is considered inaccessible to the public?

simply put if the tower is 10m high and can be blocked from climbing then it's fine OR locked in a back yard with certain specification as to power levels and safe distances so imho yes assuming the power levels at the base are safe by measurement or calculation or isolated by physical barrier , simple enough .

[VK2ZRH]

I apologise for maybe disappointing a few fervently help assumptions and opinions, but the WIA web page titled "Amateur Radio And Electromagnetic Radiation Issues" was developed in consultation with the ACMA. And it wasn't done in half an hour, either.

The primary source documents for amateurs' responsibilities in relation to EMR/EMR are listed on your licence. Get it out of the picture frame you may have put it in, or the bottom of a drawer, or in a drop file, and read it.

All the bush-engineering/lawyering that reckons 'it should be this way / it must be that way / I reckon . . .' is not educating any of us except, perhaps, in illustrating the way not to go.

Yes, the language in the Apparatus Licence LCD, as prepared by the Office of Parliamentary Counsel, is quaintly arcane and not 'plain English', but is not impenetrable, as some commentators make out (in order to make a pejorative point). Be sure brain is engaged before putting your keyboard in gear.

Posted in the interests of grounding the debate (and I don't mean pushing it down or shorting it out ).

73, Roger Harrison VK2ZRH

[VK2OMD]

As a side note, I can't help but think that if rules were written in a well-structured programming language like C, that they would be easier to interpret....

Geoff, it is interesting to look at the origins of Boolean Logic. George Boole sought a notation and algebra for evaluating the logical conditions of complex laws, and long before digital computers, it had application to understanding the law.

Owen

[VK2AVR]

Ha, Owen Understanding the law is droolian logic to me, because of the glazed eyes and involuntary reaction I get trying to follow the convoluted language I've read enough standards documents to have a good idea what they mean though.

Although Level 1 does gloss over a lot of detail, the more I look into it and the more calculations I do the easier it seems to comply with maximum exposure limits. There are derating factors for duty cycle and near field effects you can also apply if required. Applying some common sense separation distances using moderate power (100W Px) and basic antennas, you're well under the exposure limits on HF. So the simplistic criteria given by ACMA are good enough for me, and I'm not prepared to worry about the issue any further. If I'm considering operating close to an antenna I'll be doing a level 2 analysis, just to be sure.

[VK2AAF]

Quite right Brian, but the fact that so many studies have been done is really part of the problem. Because there are so many studies being done the public perception is that if so many studies need doing then there must be something sinister going on, and that stirs up the public to demand action.

If so, then it'd be something of a vicious cycle- public anti-science mythology regarding EMR leads to public inquiries, which prompts applications for grants for studies, which prompt public suspicion. I'm not so sure that's what's happening, but it's a viable hypothesis.

If anything, ACMA's obsession with hams being outright experts in EMR exposure could prompt as much public suspicion. If there's no identifiable harms from EMR exposure (and so far, there are none, despite being researched more extensively than just about anything else), what purpose does it serve?

I inquired of Simon Chapman, Professor of Public Health at the University of Sydney, regarding ACMA's focus on hams' knowledge of EMR exposure and the kW power trial. Beyond his well-known work in tobacco control and 'wind turbine syndrome,' Chapman is intimately familiar with the public concerns about health effects of EMR, specifically with regard to mobile phones. I was a bit surprised to find that Chapman was not familiar at all with ACMA's requirements that hams be EMR exposure experts. His specific comment to me was (direct quote) "all Greek to me I'm afraid. Know nothing of this" and he suggested that I write something about it and/or contact Dr Norman Swan on the issue. This is probably a blessing- it means that the public really haven't cottoned on to ACMA concerns about EMR from amateur radio stations.

I think it's time to recognise what direct science and epidemiology quite clearly tell us- there's nothing to fear from radio signals at the levels in common use for communications. Continuing to entertain the anti-science mob's fearmongering is fruitless and even counterproductive. EMR fear enjoys a class with anti-vaccination and 'wind turbine syndrome.'

I'll chase this issue down further with Dr. Swan and post what I find out.

[VK4WDM]

Hi Brian

Very good sensible post!

I think the whole issue is prompted by the ACMA covering their rear end by showing that the are doing something about one source of EMR - radio hams, and there is absolutely nothing wrong with them doing that - it is their job.

IMO the regs work for us, not against us, because we can use them to demonstrate that we are responsible enough to make sure that that our emissions do not pose a safety risk to the general public. If somebody asks, I can give them the file that contains the reg and the parameters of my station. It is also prompts me to reduce emissions by station design and reducing output when I can.

I operated portable at a public event on council-owned land during the RD contest. Before the council gave us permission to operate we had to satisfy their safety officer that there was no risk, including EMR risk, to the public. He was very surprised when I produced a spread sheet showing the EMR calculations and that we had worked out exclusion areas for the vertical antenna and were going to rope off that area to prevent access - he complimented us on our "professional approach."

What I have difficulty get my head around is why some hams are so worried about not being level 1 compliant. It does not mean that the are going to be dragged out by the ACMA inspectors and shot, or even prevented from operating. It means you have to do a level 2 assessment, which is going to tell us what we already know by common sense - keep radiating antennas and people separated by a few metres.

The other factor is this on-going debate is that some of us, myself included, just love to play with numbers, produce data, and argue our points. To us it is interesting. To other hams, who just want to get on with what the have always done, it is a big yawn, and we/me are being a PITA. So I am going to stop being a PITA and cease commenting unless something really BIG turns up like "ham radio proven to cause haemorrhoids."

73

Wayne VK4WDM

[VK2OMD]

... "ham radio proven to cause haemorrhoids."

Or can you prove absolutely that it doesn't, that ham radio is safe and that your only piles problem will be piles of junk!

I do hope with all this concern about the risk of introducing extra heat energy to the human body, that you recognise the potential benefit of taking a cold beer instead of a hot coffee!

Owen

[VK2AVR]

"ham radio proven to cause haemorrhoids."

no causal relationship there, they were haemorrhoids before they got licenced

I'm in agreement with Owen on the cold beer theory! TGIF.