Tomorrow’s RSGB News includes some interesting information regarding OfCom’s forthcoming licence review.
“Paul Jarvis of Ofcom addressed the National Hamfest on 27 September with their thinking for the forthcoming Licence Review. He covered the reasons why the review was being undertaken and emphasised that it was not intended to be a radical change, but that the Licence Review was geared to be more explicit with regard to the wording of some of the existing clauses, on operational practice and to help extend the services available to Amateur Radio to encourage development of modern technologies. He explained that his workload and staffing meant that he would not be able to enter into general discussions on the likely topics prior to the consultation which is expected to begin at the end of the year. He did, though, stress that Ofcom were working with the RSGB as part of the pre-consultation preparation, and invited the RSGB to feedback general comments on the topics that he raised.”
To that end, the RSGB website has two so-called “litmus tests” where further details of the OfCom proposals can be found, together with an opportunity for feedback.
The first subject concerns the oft-rumoured “Single call sign” issue.
"In Ofcom’s address at the National Hamfest they indicated their desire to move to a single call sign per station.
The RSGB considers that a move to a single licence per station needs to be handled with great sensitivity in consideration of the following points:
1.Many amateurs have a mix of feelings and attachment with their call sign. Their call sign is a bit like a nickname. It may also indicate their time in the hobby. An earlier call sign may be more attractive to use;
2.That preference should be given to applying any changes only to new licensees, and if possible by issuing a licence that can be varied as the amateur progresses (as opposed to revoking earlier licences);
3.If Foundation and Intermediate licences are to be given up will they be available to pass onto future family members?
4.Would holders of both an old Class A and B licence be included in this change? If so would there be any implications for operating overseas?"
Whilst the first subject probably affects only a minority of radio amateurs, the second is far more significant, especially for activities like SOTA. It concerns the “Regional Secondary Locator”.
"Clause 2(2) of our Licence Schedule states that we “shall modify our call sign prefix with an alternative or secondary prefix letter…”. This identifies the UK Nation in which the station is located. The exceptions are licence variations that allow the use of special short-term prefix letters that are not geographically related, e.g. the recent GV prefix. Ofcom have recently interpreted clause 2(2) as applicable only to the fixed or home station operation. However, Ofcom are aware that standard practice has, for many years, been to change this prefix when applied to alternative, temporary and mobile operations.
An example of this would be where say G4*** operates as a portable station from Wales he or she uses the call sign GW4***/P. For a holder of an Intermediate Licence the practice is for 2E0*** to operate as 2W0***/P. Similarly practice is followed by Foundation Licence holders. Ofcom consider that their intent in the wording of the current licence is that the call sign in these circumstances should be G4***/P , 2E0***/P, etc, as the fixed or home station address is unchanged. If Ofcom need to contact the station concerned they would write to the licensee at that address. Likewise Ofcom consider that they would expect to see GM4*** operate mobile from the Isle of Man as GM4***/M; a similar suffix addition would apply for Intermediate and Foundation Licence holders.
We understand that in raising this interpretation Ofcom are not suggesting that the current practice should change now, but that they are considering including this subject within the Licence Review consultation. They want to see if there is a way forward that is both legally sound, in terms of the licence, and also satisfies the needs of the amateur community.
This unexpected interpretation raises some concerning implications, and the Society is keen to provide Ofcom with some initial views before they frame their consultation question on the subject. This Litmus Test offers the following draft response for discussion and improvement:
The Society understands that the Secondary Regional Identifier 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.
The RSGB is keen to point out the following potential impacts:
1.Current practice is more or less 100% adherence to changing the Regional Secondary Locator as the station operates in different UK Nations. Amateurs outside the UK may be confused where the appropriate Regional Secondary Locator for the actual location of the station is not used, or its application is made optional.
2.Short-term operation from those UK Nations where amateur operations are less common will significantly reduce if the attraction of being able to use the appropriate Regional Secondary Locator is not allowed.
3.Various Amateur Awards and Contest adjudication may be made more complicated if changes are made to the usage of Regional Secondary Locators.
4.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 is maintained by clarifying that the appropriate Regional Secondary Locator should be used for alternative, temporary of mobile operations. Further, that call signs with non-Regional Secondary Locators, such as special prefixes, may be used through variation of the licence at the request of the licensee."
It must be stressed that these are merely indications of OfCom’s initial negotiating position, and are not imminent changes. I strongly suspect that discussions will result in a more user-friendly result. My initial view is that the proposed change to the rules regarding Regional Secondary Locators is unnecessary, unhelpful and probably unenforceable in practice. Let’s hope common-sense prevails.
73 de Les, G3VQO (from England, and potentially from Wales, Scotland and the Channel islands too!)