ARLA/CLUSTER: Ofcom consulta a RSGB acerca das licenças de amador no Reino Unido

[João Costa > CT1FBF]

Amateur Radio Licence Consultation

The RSGB General Manager Graham Coomber G0NBI has released a statement
regarding the Ofcom amateur radio licence consultation

To assist Ofcom prepare for their consultation the Society ran several
Litmus Tests last year to provide feedback to Ofcom prior to their
setting up of the consultation questions. The outcome of the process
and the submissions that the Society made to Ofcom are available on
the RSGB website -
http://rsgb.org/main/rsgb-consultations/consultation-archive/
ofcom-consultations/licence-review-preparation/

In respect of RSLs, the response is available at
http://rsgb.org/main/rsgb-consultations/consultation-archive/ofcom-consultations/licence-review-preparation/regional-secondary-locator/
and reproduced below.

The Society understands that the Secondary Regional Identifier (RSL)
is not an ITU-R Radio Regulations requirement, but can be requested at
the discretion of the national administration (in our case Ofcom). The
RSGB also recognizes that Ofcom are best positioned to determine the
legality of the current or possible changes to the wording of clause
2(2) of the Licence Schedule, so this response does not consider the
legal aspects; but equal attention must be given to functional issues
and to the impact of any change. The function of an amateur call sign
is to identify each individual station concisely and unambiguously to
any listener around the world (including the monitoring services of
other administrations). The established UK system of RSL achieves that
in a way that is widely known and understood. Any unilateral change by
OFCOM would thus have a negative impact on stakeholders, not only in
the UK but around the world. That impact would need to be formally
assessed and could only be justified in terms of some overriding need.
RSGB sees no such need or justification for changing the existing
system.

The purpose of this document is to give RSGB views on the potential
impact of changes to usage of the RSL.

The overriding view from those participating in our consultation,
which was paralleled at the Ofcom session at the recent RSGB
Convention, is that the current practice of using the appropriate RSL
at the point of where the transmitter is located should stand. Ofcom
may wish to consider if the wording in the Licence Schedule needs to
be improved to make this clear.

The RSGB is keen to point out the following potential impacts:

a) Current practice is to change the RSL as the station operates in
different UK Nations. Amateurs outside the UK may be confused where
the appropriate RSL for the actual location of the station is not
used, or its application is made optional.
b) Short-term operation from those UK Nations where amateur operations
are less common will significantly reduce if the use the appropriate
Regional Secondary Locator is not allowed.
c) Various International Amateur Awards and Contest adjudication may
be made more complicated if changes are made to the usage of RSLs.
Some contests too rely on the RSL attract activity.
d) There may be an impact in terms of usage by amateurs visiting from
overseas and operating under the CEPT TR61-01 arrangements.

The RSGB proposes that the current interpretation of Clause 2(2) in
the licence schedule be strengthened by clarifying that the
appropriate RSL must be used for alternative, temporary or mobile
operations. Further, that call signs with non-RSLs, such as special
prefixes, may be used through variation of the licence at the request
of the licensee.

Within our consultation on the RSL there were several comments about
the shortcoming of lack of regional location with the use of the GB
prefix for Special Event Stations. The RSGB is willing to work with
Ofcom to reach an outcome that will better meet UK amateur’s needs.

Comment was made in our consultation that inclusion of the RSL issue,
with its implications about regional identity, would be inappropriate
to include in the Licence Review if this was to take place during the
course of the Scottish Referendum Campaign.

To inform its response to the consultation document, the Society will
be once more giving all amateurs the opportunity to contribute their
views via a discussion forum. This will be available at
http://rsgb.org/main/operating/licensing-novs-visitors/licence-review/ shortly.

The full 32-page consultation document is here:
http://stakeholders.ofcom.org.uk/consultations/amateur-radio-licence

Essex Ham's shortened summary is here:
http://www.essexham.co.uk/news/
licence-changes-ofcom-consultation.html