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Ofcom Updated Amateur Licence Guidance Released

Posted on 2 November 20157 April 2020 By Pete M0PSX 11 Comments on Ofcom Updated Amateur Licence Guidance Released

Ofcom LogoOfcom has just issued its long-awaited updated ‘Amateur Radio – Guidance for Licensees‘ document. This PDF document is intended to offer advice and clarification on the updated licence conditions that started rolling out in April 2015.

The guidance document weighs in at 21 pages, and the licence itself is 23 pages.

The full PDF can be downloaded from here: OFCOM: Amateur Radio – Guidance for Licensees

Note that this article was written in 2015. Since then, the document has been revised by Ofcom. This article remains in place for reference only.

 

What’s included

On our initial look through the new guidance document, we’ve identified a few notes that are worth noting.

Please note that this is only our interpretation – read the guidance yourself before making any judgement. We’d also be interested to hear from you if you disagree with our initial assessment.

Number of licences

There has been discussion of a desire on Ofcom’s part to reduce the number of licences that an amateur holds. The new guidance states in section 1.2 :

“Although it is not currently a condition of the Licence and is not required in order to obtain a licence, it helps us to ensure that our records are up-to-date if licensees surrender the lower class of Licence, when progressing from one class to the next.”

Surrendering callsigns is certainly something Ofcom seems keen to encourage, and the use of ‘currently’ implies that it may at some point become mandatory to resign your Foundation licence when you progress to Intermediate.

Identification / Use of callsign

The new licence conditions removes the old “15 minute” rule, and adds that a station must be “clearly identifiable at all times” and identify “as frequently as practicable”.

This has caused much debate, and the new guidance goes some way to helping.

  • Section 2.88: Re. “clearly identifiable at all times” – another station must be able to identify the transmitting station clearly with relative ease
  • Section 2.89: The callsign must be given “as frequently as practicable“. The guidance notes state that the last licence stated that the “callsign must be transmitted at least once every 15 minutes”, and that for voice and Morse, “this interval seems sensible, but that not every situation may lend itself to such a strict requirement”
  • Section 2.91 adds that digital transmissions may have the callsign embedded in the transmission, and at an absolute minimum would need to identify at the beginning and end of transmissions. It’s not clear if this is referring to digital voice modes (like DMR and D-Star), or data modes (PSK31, JT65, etc) – or both.
  • Section 2.92 includes a note that radios may have embedded callsigns (e.g. D-Star and DMR), and software used for data modes may have pre-configured callsigns. It notes that care needs to be exercised when borrowing equipment containing someone else’s callsign or ID. Deliberately using a false identity is deemed a serious breach
  • Section 2.94 notes that identification may need to be more frequent than the 15 minute guidance for nets or when using a repeater

Finally, we note in section 2.106 that there are references to the use of suffixes ‘/M’, ‘/P’, ‘/T’ or ‘/MM’. If a licensee is unsure which to use, it may be simpler to omit the suffix, which is optional anyway. We’re assuming that the ‘/T’ suffix is a mistake, and should read ‘/A’.

Airborne use

  • Section 2.31 adds guidance on use of amateur radio equipment from high altitude balloons and unmanned vehicles (drones). Neither is permitted.

Maritime Mobile / At sea

Some interesting guidance here, with potential to re-open the debate on where a Foundation and Intermediate licensee can operate.

  • Section 2.15 states that “Under the Licence, all licensees may use their Radio Equipment beyond the baseline to the extent of UK territorial seas”.
  • Section 2.13 states “The UK’s territorial seas extend either for 12 nautical miles from the baseline or until a point is reached halfway to another country, such as France. Generally speaking ‘baseline’ means the mean low water mark but can be a line across the mouth of a river estuary.”
  • Section 2.14 states that “The UK Hydrographic Office has published maps showing the Baseline and the extent of UK territorial seas, which may be of assistance to licensees but these maps are for guidance only.” (Link: UK Maritime Limits Maps)

On the first reading, 2.15 implies that Foundation and Intermediate may be able to operate from up 12 nautical miles out (or up to the halfway point to another country if less than 12 nautical miles): “all licensees may use their Radio Equipment beyond the baseline to the extent of UK territorial seas”

However it is also clearly stated that Maritime Mobile (defined as ‘Vessel at Sea’) is for Full licence holders only. We’re assuming that /MM should therefore only be used when in UK territorial seas or in International waters, and not in Internal Water.

So… all licensees can operate in territorial seas, except those that can’t?

Extract of UK Territorial Sea Limits (For illustrative purposes only)
Extract of UK Territorial Sea Limits showing Essex (For illustrative purposes only)

 

Club Callsigns

  • Section 2.39 implies that use of the “X” prefix for an English club callsign seems to be optional
  • Various items clarify the position for transferring a club callsign to another official. Section 2.49 offers guidance on reissuing a club callsign should a rift develop between a club and the licence holder. The club would have to provide Ofcom with evidence (e.g. extracts of minutes), and Ofcom would seek representation from the existing licensee before revoking the club licence and allowing another club official to apply.

Encryption

Of interest to RAYNET operators re. the relaxation on encryption in emergencies:

  • Section 2.79 offers advice on the recent change to the licence that allows message encryption if requested by a User Service local incident commander in an emergency. It is noted that encryption in these circumstances only applies to messages sent within the UK. Encryption of messages to other countries is not permitted, even in emergencies.
  • If encryption is used, the licensee needs to log the transmission, together with a reason for encryption and who requested it.

Fees

In Section 2.101, it states that Ofcom is likely to address amateur radio licence fees in 2016 or 2017, but that apparently does not mean that a fee is inevitable, and any decision on fees would be subject to consultation.

Summary

That’s all we’ve seen so far – and as stated earlier, this is just our non-legally-binding take.

We’d welcome your comments and interpretations! Please add your thoughts in the comments box below.

News Tags:licence, Ofcom

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Comments (11) on “Ofcom Updated Amateur Licence Guidance Released”

  1. M5AKA says:
    2 November 2015 at 18:33

    Fnd/Int on vessels – operation is only permitted in areas marked dark blue on this map https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/447200/UK_TS_2015_A4.pdf
    But that’s all the Thames Estuary and a considerable way out plus The Wash The Solent and many coastal waters around the Union.
    Note Full licence holders shouldn’t sign /MM in the Dark Blue areas.

    Reply
    1. Pete M0PSX says:
      2 November 2015 at 19:08

      This quote is gonna cause confusion:

      “all licensees may use their Radio Equipment beyond the baseline to the extent of UK territorial seas”

      … All licensees can operate out to the 12 mile limit, except those that can’t?

      Reply
      1. M5AKA says:
        2 November 2015 at 22:59

        My take on that is they are referring to operation from offshore platforms fixed to the ocean bed, such as former WW2 forts and gas/oil platforms out to the 12 mile limit.

        Reply
  2. M5AKA says:
    2 November 2015 at 18:38

    Ofcom also formally confirm what has been known for over a decade, that Foundation and Intermediate holders CAN operate overseas. A Foundation holder who did the CARS course at Danbury was able to operate in the United States during 2004.

    Reply
    1. Kevin Jackson says:
      2 November 2015 at 20:03

      Operating Overseas.

      It is very clear that this is NOT as straight forward as you would have it. It doesn’t mean that a Foundation and Intermediate Licensees can just operate overseas but the must check with the Country they are visiting to see if it allowed. The UK Authority clearly states that this has no bearing on CEPT Recommendation T/R 61-01 or any authorisation by way of the UK Amateur Radio Licence.
      I take that to mean that you would have to obtain a permit from the Country concerned for a Callsign, which in no way, has any part of your UK Callsign involved.

      Reply
      1. M5AKA says:
        2 November 2015 at 23:11

        As the guidance says you apply to the regulator of the country you wish to operate from. This is what all amateurs had to do in the days before the introduction of CEPT T/R 61-01 and these days the Internet makes in considerably easier than it used to be.

        In some cases Fnd/Int can use their UK call signs overseas, I believe Gibraltar is a case in point. A Foundation holder was given permission to operate in the USA in 2004 after contacting the FCC. As I recall they were permitted to use W4/M3xxx.

        Would be interested to hear of people experiences in this area.

        As well as T/R 61-01 the CEPT has two other reciprocal arrangements covering the Novice (Intermediate) licence and Basic Entry Level licence (Foundation), many countries are signed up to both.

        Reply
  3. M5AKA says:
    2 November 2015 at 19:05

    RSL’s do not form part of the official call sign.
    Regarding RSL use 2.40 says “A station that was mobile could change its transmitted call sign”.
    Note it says “could” rather than “shall” or “must”.

    Further down 2.40 “Licensees must decide how best to observe the requirement to include an RSL”
    I suspect there is a degree of intentional ambiguity here. In 2013 Ofcom obtained legal advice that the licence said you should sign your home station call sign when in other Regions of the UK & CD’s – this upset some amateurs and Ofcom then said they would allow people to change the RSL when in different regions if they wanted.
    http://rsgb.org/main/archive/consultation-archive/ofcom-consultations/licence-review-preparation/regional-secondary-locator/

    The words in the licence the legal advice was obtained on have not changed since 2013. Ofcom’s new guidance says licensees themselves must “decide how best to observe the requirement”.

    Reply
    1. Pete M0PSX says:
      2 November 2015 at 19:13

      The actual licence says “shall” – 2(2) The Licensee shall use the following appropriate Regional Secondary Locator after the United Kingdom Callsign prefix “G”, “M” or “2” as specified in Section 1, when identifying the Radio Equipment in accordance with Clause 13. I don’t see RSLs as optional. 2.38 and 2.39 make RSLs mandatory for clubs and Intermediates.

      My take on 2.40 is that the “could” indicates that a mobile station you’re talking to, could suddenly change its callsign as it crossed a border.

      The requirement for a club (2.39) makes it clear that a club *transmitting* in England would have the English club RSL (so TX location, not station address)

      Reply
      1. M5AKA says:
        2 November 2015 at 23:22

        Yes, the licence isn’t as clear as it could be which is why Ofcom took legal advice on the meaning of the words. It’s referring to the RSL used at the Main Station address.

        If you check the link given above it says that should an amateur with a Main Station address in England operate from Wales they should sign they home callsign not add a “W” RSL – the wording of the licence means that the call sign in these circumstances should be G4***/P , 2E0***/P, etc, as the fixed or home station address is unchanged.

        Reply
  4. Tim K says:
    5 November 2015 at 10:27

    The guidance on operating abroad with regard to RSLs is interesting especially as T/R 61-01 isn’t clear in this area. Ofcom appear to want the RSL removed but T/R 61-01 does specify the RSLs in its tables and Scotland, Wales etc as their own entities. A lot of existing operation abroad has kept the RSL. The T/R 61-01definition is below:

    When transmitting in the visited country the licence holder must use his national call sign preceded by
    the call sign prefix of the visited country as indicated in ANNEX 2: and ANNEX 4:. The call sign prefix
    and the national call sign must be separated by the character “/” (telegraphy) or the word “stroke”
    (telephony).

    Reply
  5. John Rowlands says:
    13 April 2016 at 12:24

    There is no reason why this ‘guidance’ can’t be written in a much, much clearer manner. Look at that ridiculous definition of what operating satellites is considered to be – total wordy rubbish!

    For all their words of legalese wisdom, none of the supposed ‘regulation’ of the bands stops RTTY interference with ongoing WSPR transmissions each and every weekend, if not more frequently.

    So far as I’m concerned, there is very little meaningful enforcement of the regulations in the UK.

    Reply

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