28-10-2022, 05:45 AM
Terry et al
RE the hard-coding, back in my IFC01-2021 submission :
"
In Section 4 of the proposed Class Licence document under Definitions is the statement : ” call sign means a sequence of letters and numbers assigned to a person by the AMC as a call sign.“ where “AMC means the Australian Maritime College, an institute of the University of Tasmania.” I strongly object that the AMC is named in proposed legislation where instead it should be more like “a body, or bodies, duly authorised to issue Amateur callsigns”. The existing Deed between the AMC and ACMA only has a couple of years of tenure remaining and there may be a change away from the AMC at its expiry, or any subsequent Deed expiry. Naming the AMC in legislation is a severe oversight by the drafters given that the resulting LCD may be in force for many years.
Even the Consultation Paper refers to “The assignment of call signs will be managed by a third party provider.“ in the proposed summary of changes.
Further, there could be more than one body responsible for the issue and management of callsigns for the Amateur Service at any one time and the LCD must allow for that option in the wording.
"
I note that the newer Draft Class Licence has been altered from the original Draft version regarding this but I (too) am still not sure they have the wording correct in this latest release. There is no real need to define the AMC in legislation, only that it be a management body duly authorised for the specified purpose.
In due course the AMC may decide that it cannot make enough income/profit to continue handling the amateur proecesses and decide to withdraw, and then the defined Class Licence legislation falls over. One only has to see that the number of callsigns has mostly reached a plateau and fewer numbers of new callsigns/licences are being issued as numbers seem to have stopped growing - the total amateur licence records in the ACMA's RRL have stayed static around 15000 for some time as proof. A drop in callsign change numbers (new/altered) means less income to the AMC, and now that the "lifetime" flurry seems to have settled a bit, that looks to me to likely be the ongoing state.
Despite Roger's link to the WIA website, it is now only a few days to November and nothing has been received/heard at this QTH from the WIA. My plan is develop my own response to the ACMA and get it in before the end of November, and not as a "me too" form letter. My eventual points may not agree with WIA's but that is for the ACMA to handle.
Doug VK4ADC
RE the hard-coding, back in my IFC01-2021 submission :
"
In Section 4 of the proposed Class Licence document under Definitions is the statement : ” call sign means a sequence of letters and numbers assigned to a person by the AMC as a call sign.“ where “AMC means the Australian Maritime College, an institute of the University of Tasmania.” I strongly object that the AMC is named in proposed legislation where instead it should be more like “a body, or bodies, duly authorised to issue Amateur callsigns”. The existing Deed between the AMC and ACMA only has a couple of years of tenure remaining and there may be a change away from the AMC at its expiry, or any subsequent Deed expiry. Naming the AMC in legislation is a severe oversight by the drafters given that the resulting LCD may be in force for many years.
Even the Consultation Paper refers to “The assignment of call signs will be managed by a third party provider.“ in the proposed summary of changes.
Further, there could be more than one body responsible for the issue and management of callsigns for the Amateur Service at any one time and the LCD must allow for that option in the wording.
"
I note that the newer Draft Class Licence has been altered from the original Draft version regarding this but I (too) am still not sure they have the wording correct in this latest release. There is no real need to define the AMC in legislation, only that it be a management body duly authorised for the specified purpose.
In due course the AMC may decide that it cannot make enough income/profit to continue handling the amateur proecesses and decide to withdraw, and then the defined Class Licence legislation falls over. One only has to see that the number of callsigns has mostly reached a plateau and fewer numbers of new callsigns/licences are being issued as numbers seem to have stopped growing - the total amateur licence records in the ACMA's RRL have stayed static around 15000 for some time as proof. A drop in callsign change numbers (new/altered) means less income to the AMC, and now that the "lifetime" flurry seems to have settled a bit, that looks to me to likely be the ongoing state.
Despite Roger's link to the WIA website, it is now only a few days to November and nothing has been received/heard at this QTH from the WIA. My plan is develop my own response to the ACMA and get it in before the end of November, and not as a "me too" form letter. My eventual points may not agree with WIA's but that is for the ACMA to handle.
Doug VK4ADC
Doug VK4ADC @ QG62LG51
http://www.vk4adc.com
This Forum is only going to be as interesting as the posts it contains.
If you have a comment or question, post it as it may trigger or answer the query in someone else's mind.
http://www.vk4adc.com
This Forum is only going to be as interesting as the posts it contains.
If you have a comment or question, post it as it may trigger or answer the query in someone else's mind.