ACMA replies to WIA questions on the High Power Trial

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VK2ZRH
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ACMA replies to WIA questions on the High Power Trial

Post by VK2ZRH »

In August last year, when the ACMA told the WIA that it would not make regulatory arrangements for Advanced Licensees to run up to 1 kW, the WIA Board discussed the issues raised and decided in September on providing a strong response and to ask six questions.

The ACMA wrote to the WIA in August, formally advising of their decision, making a number of observations on the Trial and listing four detailed reasons for their decision.

In September, the WIA responded in writing, putting forward rebuttals to the ACMA's observations on the conduct of the Trial, and asked these questions:
Q1. As “an evidence based regulator”, is the ACMA’s concern with the use of higher power by amateurs based on a formal risk assessment/management methodology?

(a) And if so, how did the outcome/s derived from that methodology influence the ACMA’s decision?

Q2. Noting that the ACMA wrote to 90 Advanced Licensees that participated in the Trial, what was the basis and methodology used by the ACMA in choosing these 90 participants, and:

(a) what criteria were used to conduct the assessments?

Q3. What level of compliance from the desk audit would have been considered acceptable?

Q4. Noting that, of the 90 licensees that were audited, 17 did not meet the ACMA’s expectations on compliance, would the ACMA please provide a breakdown of those 17 into defined categories?

Q5. Noting that the ACMA wrote to those 17 participants inviting them to provide new records to demonstrate compliance with the current EME requirements, what has been the outcome?

Q6
. Concerning station inspections in relation to the Trial:
(a) how many were conducted?;
(b) in what states?; and
(c) would the ACMA please provide details of the outcomes?
The ACMA's response is now posted on the WIA website, here: http://www.wia.org.au/newsevents/news/2 ... /index.php

Posted in the interests of disseminating the news. :)
73, Roger Harrison VK2ZRH
VK6MB

Re: ACMA replies to WIA questions on the High Power Trial

Post by VK6MB »

Thanks Roger,
interesting reading.

73 Mike VK6MB
VK2AVR

Re: ACMA replies to WIA questions on the High Power Trial

Post by VK2AVR »

Reading deeper, It's interesting that a lot of the incorrect submissions were as a result of relying on "software tools" to complete the desk audit. There was one common tool in use during the trial and there was much discussion about the accuracy of the calculations. I believe those issues have now been fixed, and it's unfortunate that it may have tinted the outcome. It's also certainly true that a software tool can't accurately simulate RF in all situations and configurations. That's where common sense and going back to ACMA's papers on EME exposure limits and separation comes into play. The biggest take-home message from their response was that the quality of submissions from "advanced" licencees was not up to scratch. One of the participants who was desk audited had to make 3 or 4 submissions before their report was satisfactory!! We can definitely do better, hopefully we're given a chance to prove it.

I would love to have a crack at the high power trial, and making a proper submission. But a unit is no place for QRO. Maybe one day I'll have space for a real antenna (and amplifier to drive it!).
VK3BSF

Re: ACMA replies to WIA questions on the High Power Trial

Post by VK3BSF »

The first rule of any trial/assessment is to know the outcome in advance...ACMA knew the trial would get the thumbs down as AR operators had no idea of their beaurocarcy....next time we have a trial WIA shud have a pre-trial before any formal procedures are applied...in other words be prepared for a result!!
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Re: ACMA replies to WIA questions on the High Power Trial

Post by VK3ZAZ »

Come to my workplace you sight and sign the site radiation folder.
You indemnify us against injury from emr.
You have a pictorial representation of the go no go areas.

Even so we have a recorded announcement warning 3rd party vendors that if they climb they MUST have demonstrated EMR understanding and carry an alerting device.


Public don't have such things so its up to us to keep people away from antenna under any power levels.

The emr calculators were a bit sus, so you do it manually like we did earlier or use the Dave Burger one.

I have no issues here and have had HP 6M from 1993-1998 and again now for two years if you want to know how to keep acma happy I can show you my HF and VHF calcs and my site radiation folder depicting go and no go areas.


Don't expect WIA to have all the answers they cant indemnify you if you stuff it up and it sounds like some of you did.

At my workplace you get injured by emr becomes a BIG problem.
We just warn you with signs and an SRF
But what horrifies me the most is seeing the videos on u-tube of guys running up TV TRPAs with the covers off converting them to 6M and 2M.

if you read the handbooks TRPAs are never run with covers off under any circumstances, and if this is typical of amateurs disregard or lack of EMR knowledge, then we have problems.

I imagine every ham with ANY Power level needs an srf just like even the lowly little police station with a Nally tower and 25 watts VHF.
Its common sense and a legal requirement.

Q? HM have done a site/risk survey even at 100 watts.
Q?HM have even a cheaper EMR rad monitor alerting beeper?
Q? HM have a peak reading power meter.
All you guys on air stating running legal power with your 1kw and 2kw amps, how do you do that?
Did you know its 400 w pep ssb
and 110 watts of CW?
CW is not measured by PEP.

Have any of you done an emr check on what leaks out of the amp?

Try doing a Dentron for starters you might get a rude awakening what streams out of the fan holes.

73

VK3OT


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Re: ACMA replies to WIA questions on the High Power Trial

Post by VK2CSW »

VK3ZAZ wrote: Q? HM have done a site/risk survey even at 100 watts.
Q?HM have even a cheaper EMR rad monitor alerting beeper?
Q? HM have a peak reading power meter.
I imagine Her Majesty would have someone to do that for her.
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Re: ACMA replies to WIA questions on the High Power Trial

Post by VK2AVR »

VK3BSF wrote:The first rule of any trial/assessment is to know the outcome in advance...ACMA knew the trial would get the thumbs down as AR operators had no idea of their beaurocarcy....next time we have a trial WIA shud have a pre-trial before any formal procedures are applied...in other words be prepared for a result!!
the trial was a perfect demonstration of why we shouldn't have 1kw then.. clearly we need more education before we can be trusted with it
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Re: ACMA replies to WIA questions on the High Power Trial

Post by VK4TS »

Perhaps the 1KW needs to be allowed for other than EME - special paths - and individual application as per the current EME arrangements .
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Re: ACMA replies to WIA questions on the High Power Trial

Post by VK4TI »

VK4TS wrote:Perhaps the 1KW needs to be allowed for other than EME - special paths - and individual application as per the current EME arrangements .
I always thought a small additional training be added and cited for a 1kw ticket perhaps ? , easy to organise online as we know no one would cheat and it ensure all have the required rear covering
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Re: ACMA replies to WIA questions on the High Power Trial

Post by VK4TS »

maybe
Trent VK4TS
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Re: ACMA replies to WIA questions on the High Power Trial

Post by VK2LK »

VK2MIA wrote:
VK3BSF wrote:The first rule of any trial/assessment is to know the outcome in advance...ACMA knew the trial would get the thumbs down as AR operators had no idea of their beaurocarcy....next time we have a trial WIA shud have a pre-trial before any formal procedures are applied...in other words be prepared for a result!!
the trial was a perfect demonstration of why we shouldn't have 1kw then.. clearly we need more education before we can be trusted with it
Why? I was audited and passed with flying colours....
Matt, VK2LK
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Re: ACMA replies to WIA questions on the High Power Trial

Post by VK5PO »

I got my license renewal last November, It states that I can run the 1kW on the approved HF bands as
the same as previous license...

Work that out?


I passed with flying colours also.

73, John
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Re: ACMA replies to WIA questions on the High Power Trial

Post by VK3AUU »

According to the ACMA web site at
http://www.acma.gov.au/Industry/Spectru ... tion-paper


"High power transmissions

To enable experimentation involving earth-moon-earth communications, advanced amateur licence holders can apply to the ACMA to use a transmitter power higher than that permitted under the Amateur LCD.
Requirements

You should be aware of the following requirements:

The applicant must be the holder of an Advanced amateur licence.

Use the the ACMA's form R077 (Additional Station Information) to provide supplementary information.

High power operation will only be approved for experimentation involving the reflection of signals from a celestial body.

Operation must be in amateur bands above 50 MHz."

It makes no mention of high power permits either for HF bands or for non-EME operations.

While pointing the finger at no one in particular, it would appear that some amateurs are in breach of the requirements.

David
VK3AUU
VK5PO

Re: ACMA replies to WIA questions on the High Power Trial

Post by VK5PO »

The ACMA have made a mistake then?

My LICENSE CLEARLY states the HF Bands etc.... It expires on NOVEMBER 17th 2014.

It also includes 1kW on any approved frequency above 50Mhz

So what the hell is going on?
I will scan the paperwork if i have to.

I have not been on HF for months anyway, but if I decided to run 1kW, I cannot see that I would have breached any license conditions,
as my AR license has the approval on it.

bizarre!!

73 again..John
VK5PO

Re: ACMA replies to WIA questions on the High Power Trial

Post by VK5PO »

VK5PO_AR_LICENSE_20140001.JPG
The scanned front page of my current AR license, clearly showing that I can operate 1kW on HF (still?)

This is a personal document put up on this forum in the interest of AR, and I respectfully ask that it is NOT copied thank you!

If you want to copy it. Ask me first.



73, John
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Re: ACMA replies to WIA questions on the High Power Trial

Post by VK3ZAZ »

VK3AUU wrote:According to the ACMA web site at
http://www.acma.gov.au/Industry/Spectru ... tion-paper


"High power transmissions

To enable experimentation involving earth-moon-earth communications, advanced amateur licence holders can apply to the ACMA to use a transmitter power higher than that permitted under the Amateur LCD.
Requirements

You should be aware of the following requirements:

The applicant must be the holder of an Advanced amateur licence.

Use the the ACMA's form R077 (Additional Station Information) to provide supplementary information.

High power operation will only be approved for experimentation involving the reflection of signals from a celestial body.

Operation must be in amateur bands above 50 MHz."

It makes no mention of high power permits either for HF bands or for non-EME operations.

While pointing the finger at no one in particular, it would appear that some amateurs are in breach of the requirements.

David
VK3AUU

A copy of my permit is on the wall David
And it has more modes than what you quote
But you seem to know all about what we are doing
so over to you.

HP 6m permit
1993-1998 50.053 50.105 EME CW
2011-2015 50.00-50.108. EME, MS FS
Tread your own path :om:
VK2AVR

Re: ACMA replies to WIA questions on the High Power Trial

Post by VK2AVR »

VK2LK wrote:Why? I was audited and passed with flying colours....
Well done, I would expect that from an Advanced licencee. There were a number of respondents however who demonstrated incompetence. That's unacceptable at the Advanced level.
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Re: ACMA replies to WIA questions on the High Power Trial

Post by VK4TS »

Not really Geoff - there are plenty of Road Drivers who wouldn't pass a competency test and still hold licences ...I see them everyday. The actual % of failure was below norms for competency exams conducted every day in industry...where shortcomings are identified, training is implemented.

What was put forward as reasons by ACMA was purely an effort at Yes Minister 2013 episode 1

First We charge them for the Trial - Why are we conducting a trial ? To see if it is worthwhile - What is the response of the majority ? If its only a trial I will wait until its over to respond - Why pay the money... That is the natural response of many people..

So immediately the Yes Minister crew use the excuse that there was not enough interest....I could go on but frankly it's an exercise in total frustration at the inability of ACMA to assist the hobby of Amateur radio.

And yes I did like Mr Mundine's T-Shirt comments having coached many aboriginal youths over the years in sports.... Of interest in 1788 the Colony was New South Wales...Not Australia
Trent VK4TS
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Re: ACMA replies to WIA questions on the High Power Trial

Post by VK2MUS »

hey if a foundation operator can qso with the world (or so we are told) on 10W then why do advanced operators need 1000W
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Re: ACMA replies to WIA questions on the High Power Trial

Post by VK3DXE »

VK2MUS wrote:hey if a foundation operator can qso with the world (or so we are told) on 10W then why do advanced operators need 1000W
Because there is SO much more to propagation studies (on pretty well all bands) which require high ERP than the casual HF ragchewer seems to care about. There are also the contesters...
Alan VK3DXE
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