Proposed amateur class licensing arrangements and high power operation Comnsult.31/22

[VK3RX]

Latest ACMA consultation paper:

Proposed amateur class licensing arrangements and higher power operation - consultation 31/2022

Interesting they state:

  We received over 800 submissions in response to the consultation paper, including submissions from amateur radio clubs, representative bodies and individual amateurs. Most submitters expressed conditional preparedness to support a future class licence,   

But their response to submissions document stated:

Most submissions to the consultation preferred that the ACMA adopt Option A and maintain the status quo by keeping the current apparatus licence arrangements and conditions.

[VK4ADC]

Make sure that you download the Consuatation paper (https://www.acma.gov.au/sites/default/fi...per_1.docx  - extracted from the link supplied previously) and read it carefully.

THEN : Submit your response before 29th November 2022.

[VK2EMF]

Latest ACMA consultation paper:

Proposed amateur class licensing arrangements and higher power operation - consultation 31/2022

Interesting they state:

  We received over 800 submissions in response to the consultation paper, including submissions from amateur radio clubs, representative bodies and individual amateurs. Most submitters expressed conditional preparedness to support a future class licence,   

But their response to submissions document stated:

Most submissions to the consultation preferred that the ACMA adopt Option A and maintain the status quo by keeping the current apparatus licence arrangements and conditions.

I am a bit concerned that there has been little to no discussion on any of the facebook or forum sites about that latest ACMA request for submissions, especially after the first round discussions went fairly viral. Does no one care at this stage or are they just resigned to the opinion that the ACMA is just going to to what they want. I think that due to the number or submissions from the first round that the ACMA were a bit shocked and are now forced to get our opinions on tailoring the Class license to suit our needs. So I think we should be discussing this topic and supplying submissions. 

[VK2ZRH/4]

I point out the recent posting to the WIA website: https://www.wia.org.au/newsevents/news/2.../index.php

[VK3RX]

It's still a mystery to me what the ACMA is going to save itself $-wise by moving us to a class licence, given that (I think) 99.5% of our annual renewal fee is a "spectrum tax", and the remainder is an admin/issue charge.

[VK5TM]

Just checked my last bill $51 tax and $4 admin - it probably costs them well in excess of the $55 to collect it.

My concern is hard coding a non govt body (AMC) in to govt legislation/regulations instead of using terms such as authorised body etc and in the definitions of such regulation, defining who/what is considered to be an authorised body.

[VK4ADC]

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

[VK6ZFG]

Hi All

The presence of AMC in the original documents struck me as being an obvious mistake which I presumed would be corrected in the subsequent redraft. 

I was wrong. 
 
AMC is not a federal government body and should as such not appear in the document. 
 
The AMC is operating under a contract and when the contract term expires they may no longer be involved in which case this will require an amendment to the document to be issued.  Additional unnecessary work generated directly as the result of the wording in the document.
 
To me this demonstrates that the ACMA has been wound down to such a level that what is now somewhat lacks the skills needed for the proper thought out drafting of regulations/legislation for government. 

73

Igor
VK6ZFG

[VK5TM]

AMC is not a federal government body and should as such not appear in the document. 

A little digging in govt law archives suggests hard coding a non govt body in to a legislative document could leave the whole thing open to a legal challenge (such would of course need proper legal advice to be sure that was the case).

[VK2EMF]

I point out the recent posting to the WIA website: https://www.wia.org.au/newsevents/news/2.../index.php

That is only saying that the WIA is looking at the proposal  and formulating a response, no other discussions in other public domain areas.

[VK2ZRH/4]

The WIA Working Group is preparing content for an online public survey (members + non-members) on the ACMA proposals to be available very shortly.

Apart from compiling questions concerning key issues, survey participants will also be able to provide 'free form' written responses, similar to the survey conducted last year.

[VK2EMF]

I think the WIA is running out of time to produce a general survey, get responses, analyse the data and form a response and get it to the ACMA by the end of November. We will have to move on personal and /or club style responses ASAP.

[VK4ADC]

From the ACMA Update of 15 Nov 2022 :

"Two weeks left to have your say on the proposed amateur class licensing arrangements

We are currently consulting on the proposed amateur class licence and supporting operational arrangements, along with options for higher power operation.

Our consultation paper includes the proposed class licence for amateur radio, incorporating changes suggested by representative bodies, amateur radio clubs and individual amateurs. It also poses a number of questions relating to supporting operational arrangements and higher power operation.

We welcome your views on these issues by 5 pm AEST, Tuesday 29 November 2022.

The consultation paper, proposed class licence and details about how to make a submission are available on the ACMA website. If you have a specific question about the consultation, please email spectrumlicensingpolicy@acma.gov.au.

"

To that we need to add some of yesterday's email from the WIA :

"Thank you for being a member of the Wireless Institute of Australia!

The Australian Communications & Media Authority (ACMA) have released a new consultation paper 31/2022 entitled "Proposed amateur class licence and considerations for higher power operation" outlining their revised proposals for converting the amateur radio service from an apparatus to a class licence in 2023.

The ACMA has also commenced consultation on how AOCP(A) amateurs could be given access to higher transmitter power limits.

The ACMA consultation can be viewed here: ACMA Consultation 31/2022

The WIA is seeking your feedback on our proposed responses. To outline the issues we have prepared an information paper, below:

Download "EXPOSURE DRAFT - WIA Response"

Along with this paper, we are inviting you to participate in a survey so that we can gain a clearer understanding of member views on the issues before us.

"

[VK2ZRH/4]

To flesh-out what Doug has posted above - the WIA has posted a news release to its website, here:
www.wia.org.au/newsevents/news/2022/20221114-40/index.php

Importantly:
". . . the WIA is asking those in the Australian radio amateur community who are non-members to register, join-in and have your say in the WIA’s survey.

You can register by sending an email to this address register@wia.org.au
Putting just your call sign (or full name if you are not licenced) in the Subject field.

Following registration, your email address will be deleted for privacy reasons.

The survey closes on Tuesday 22 November.

This gives the Working Group a week to analyse the survey results and prepare the WIA’s final response to the ACMA’s licensing proposals.

[VK3RX]

To that we need to add some of yesterday's email from the WIA :

I'm yet to receive an email from the WIA. Yes, I'm a current member, and no, nothing in my junk/spam folder.

[VK4SMJ]

Got mine last night fairly late.

[VK5TM]

Got mine last night too. (30 character make up)

[VK2CSW]

I know that this will mostly likely reflect badly on me, and I admit to only doing limited reading on the matter, but I really can't make any real headway in understanding the difference between the two classes.

I mean in terms of practical differences.

If we take the ACMA's insistence that there will be no change to interference management, then what is the real difference.

It all feels like a policy wonk's delight with little coalface change.

[VK3RX]

Still no email, so I have followed the register procedure.

I have received survey emails in the past and they have my address OK in MEMNET.

I recall a couple of local club members (long term WIA members and registered with MEMNET) had this issue with the last survey, and they got no response when they registered. One said he called the head office number and got someone who admitted knowing nothing to help, and he gave up.

I will see what happens -

Edit: received the survey link overnight, and I think it was in response to the "register" email which I sent using my ISP address, because the response wasn't addressed to my vk3rx@wia.org.au address registered in Memnet.

[VK5WRJ]

Morning all, I've been watching this thread and trying to understand exactly what is a "class license" and how it will affect me as a foundation license holder?

Perhaps I'm a bit thick, cant understand exactly what changes will take place, perhaps someone can spell it out.

Thanks,
Jon. VK5WRJ.