I am very impressed by the well-written and well-argued case for amateurs being given primary access to 50-54MHZ provided by the WIA and Michael Owen VK3KI and reported in the "WIA comment" section of the June AR.
For those who don't get AR I hope a legal way will be found to reproduce the document here on the logger.
Some may argue that we are being greedy by going after the whole four meg but this is not the the time to discuss that. An important part of mounting a successful argument for a change of legislation is not to offer to compromise until you have to compromise.
For those who are not WIA members and who have not had a chance to find a copy in the local "paper shop", here is the WIA Comment for the June issue of Amateur Radio magazine, with publication via this medium approved by the author, Michael Owen VK3KI, WIA President:
"WIA comment
Michael Owen VK3KI
The Digital Dividend and the 6 metre band
The Department of Broadband, Communications and the Digital Economy describes the ‘digital dividend’ as the radiofrequency spectrum freed-up as a result of the switchover from analogue to digital television transmission.
One of the questions that we are asked most is what is happening with the 6 metre band following the closure of the Channel 0 television transmitters as a part of that switch-over.
The short answer is, I don’t know.
But I do know what should happen.
Here is the text of a letter that I wrote on 11 May 2010 to Mr Chris Chapman, the Chairman and Chief Executive Officer of the Australian Communications and Media Authority:
“Dear Mr. Chapman
The WIA appreciates that to date the primary focus of the so called ‘digital dividend’, arising from the switchover to digital only television, has been the spectrum around 700 MHz.
The Wireless Institute of Australia, representing the amateur services in Australia, brings to your attention a consequence of the closure of television Channel 0, also resulting from the switchover to digital only television.
Article 5 of the Radio Regulations of the International Telecommunications Union allocates the band 50 – 54 MHz to the Amateur Service in Regions 2 and 3 subject to a number of footnotes, including footnote 168 which provides:
‘Additional allocation: in Australia, China and the Dem. People's Rep. of Korea, the band 50 – 54 MHz is also allocated to the broadcasting service on a primary basis.’
In Region 1 there is an amateur secondary allocation in the band 50-52 MHz in the CEPT European Common Allocation Table.
To accommodate Channel 0, in Australia the band 50 - 52 MHz is allocated to broadcasting primary, with amateur secondary, subject to footnote AUS23, which provides:
‘In the band 50 - 52 MHz, stations of the amateur service shall not cause harmful interference to stations of the broadcasting (television) service. Amateur operations in this band shall be subject to special conditions.’
Australian Radiofrequency Spectrum Plan (ARSP).
The band 50 - 54 MHz is of particular interest to the amateur service. Tropospheric scatter and sky-wave propagation (principally sporadic-E and occasional F-layer propagation at sunspot maxima) are used for longer distances, as well as auroral propagation at the higher latitudes. Meteor scatter has been used for Morse code and voice communications primarily during meteor showers. Newer computer-based techniques make meteor scatter a routine propagation mode for distances up to 2000 km.
Amateur advanced stations, amateur repeater stations and amateur beacon stations in New South Wales, Victoria, Queensland and the Australian Capital Territory are subject to various restrictions, including power and geographic restrictions in the band 50 - 52 MHz. In essence, such stations cannot operate within 120 kilometres from a Channel 0 main station, 60 kilometres of a television Channel 0 translator station and 60 kilometres of a television translator station that has inputs on television channel - see sections 15, 36 and 43 of the Radiocommunications Licence Conditions (Amateur Licence) Determination No.1 of 1997 (the Amateur LCD).
Details of VHF television channel 0 stations are set out in Schedule 7 to the Amateur LCD.
The WIA requests that on the closure of the Channel 0 transmitters the allocation of broadcasting primary in the band 50 – 52 MHz be deleted and that the band be allocated amateur primary and that the ARSP be amended accordingly, with footnote AUS23 also being deleted.
Currently only amateur advanced stations are permitted to operate on the 50 - 54 MHz band, with amateur standard stations permitted to operate on the band 52 - 54 MHz. If the amateur service was to be allocated the band 50 - 52 MHz on a primary basis, the WIA would have no objection to amateur standard stations operating on the whole of the 50 - 54 MHz band.
It will also be necessary to amend the Amateur LCD. In particular Part 1 of Schedule 2 (Permitted frequencies and emission modes (amateur advanced stations)) will require amendment to reflect any changes to the ARSP.
Sections 15, 36 and 43 and Schedule 7 will become redundant.
Currently the Amateur LCD is under review, and given the incredible difficulty the Authority has had in finding resource to deal with such matters, it is suggested that the necessary amendments be formulated as part of the present review and incorporated in a schedule, to take effect when ACMA has published an appropriate notice in the Gazette.
No doubt Australia will seek to withdraw from footnote 168 at the next appropriate WRC.
As this is a matter of general interest, I will assume that you have no objection to its publication unless you advise me otherwise.”
In short, we say that with the closure of television Channel 0 the band 50 - 52 MHz in Australia should revert to the ITU Region 3 allocation of 50 - 54 MHz amateur exclusive.
The letter also illustrates the complex framework of subordinate legislation that surrounds even the most obvious changes to the regulation of the radiofrequency spectrum in this country.
I suspect that to date, as is said in the letter, the focus of the government’s investigations has been on the spectrum around 700 MHz, but we believe that it is now appropriate to draw attention to this important part of the amateur services family of frequencies.
ar"
Published in the interest of the hobby as a whole.
Flame suit on:
The following words are mine - do not blame the WIA for my personal thoughts and observations!
The WIA does try to do the best for us all, regardless of what some seem to think!
Remember that most of the work of the WIA is done by volunteers. It relies on volunteers willing to help PLUS appropriate, well-considered, input from other Australian amateurs who present logical arguments supporting the case being presented by the individual/s.
If you want OUR hobby to continue into the future, what would you rather do:
Sit on the sidelines and rely on the input from a few to the WIA, who will then present a consensus position from those few to the regulator and government. OR
Be in a position to strengthen the position put by the WIA by (i) being a member and (ii) making intelligent input to the WIA (and government consultation processes) so that the WIA can form well-informed positions to put before government?
In my view, adopting (or maintaining) the former position is a complete cop-out. We need to position ourselves as strongly as possible for the challenges that are SURE to come! Our best defence comes from having a strong national body which is willing to consult its members!
Flame suit off!
Peter VK3PF
Editor AR
Yes - I am sort of "on the inside". In my view, the best place to be if one is to attempt to exert some influence!
Yes I had also read the letter by Micheal VK3KI to the ACMA even before it being brought to our attention by Wayne and I also thought it to be presented in a most professional and thorough style.
I also agree wholeheartedly with the comments by Peter and wish to thank Wayne for for bringing it to the attention of the wider Amateur community and Peter for getting it up here on the forum. But (there is always a but), there is something I find equally or even more disturbing than the 6 Metre restrictions currently imposed. That is the bid by ACMA for the so called interim use of 440 to 450 MHz part of the spectrum. I hope we all remember the temporary acquisition of the 420 to 430 MHz segment for the Sydney Olympics? I believe that if ACMA gets a foot hold in the upper section we may as well kiss it goodbye because they will not relinquish it in any time soon and the longer they have the use of it, the stronger their case for keeping it. Even if their intentions are at this stage honourable successive bureaucrats and politicians would be unlikely to let the commercial value of it go unnoticed.
I know this matter has been raised here in another forum where perhaps this post should be but I felt it was closely enough related to this subject to be placed here.
I feel that if we don't oppose the muted spectrum grab by ACMA in a most united and loud manner it will slip into being and be lost for all time. I also think our biggest ally here is the defence department but I don't know how to get them onside with us, any ideas?
