ACMA consultation regarding Amateur Radio qualification processes

[VK4ADC]

The ACMA have released a consultation paper titled 'new approaches to Amateur Radio qualification arrangements"  detailing three possible approaches - or a combination of them. 

The background information document can be found via this link: 
https://www.acma.gov.au/theACMA/new-appr...rangements

The main consulation reference document is at https://www.acma.gov.au/theACMA/-/media/...6F419.ashx

Note that the closing date is 2nd July 2018 so have a close read of all of the materials and make your submissions well before the due date.

[VK2CSW]

I have had a read of the document. A couple of times.

Maybe this reflects poorly on me, but if I am honest I simply can't generate an opinion for or against any of the options.

I am not knowledgeable enough about the WIA's structure and financial arrangements to understand what impact moving examination and callsigns to other RTO's might have.

[VK4ADC]

There are pros and cons for each option.  

As an assessor, one of the things I often hear from candidates for assessment (at any grade) is about the cost of attempting the various sections:  Theory, Regs, Prac or a combination of all three (eg for a FL). 
 
We heard at the recent WIA AGM that the WIA is not covering costs even at the current rates and that there may be a fee adjustment but that they saw the cost was something that should be borne as it allows new people into the hobby.  In the case of a stand-alone RTO which is in it purely for profit, I would expect the fees might skyrocket since the whole process is time consuming, and their people who act as assessors would probably be due an hourly pay rate at the very least – while the WIA has assessors do it for free.

The possibility of online assessments for Theory and Regs might be ok but would still need invigilators physically present to ensure that the person being assessed was actually who they were purporting to be and that the actual answering of the questions was conducted above board. Then comes the Practical: is a for-profit RTO going to have facilities Australia-wide with persons who can conduct a practical assessment ? My experience is that the knowledge that candidates possess varies so widely that only a person knowledgeable in procedures and practical aspects of an AR station can successfully undertake the process. 
 
All three options proposed in the ACMA document are viable – obviously – but the outcomes of the assessment process is not going to be the same.  Option 1 provides for a Certificate of Proficiency while 2 and 3 don’t . Essentially 2 & 3 provide an Attainment. 

The issue of a licence is the final outcome but is that going to be regarded equally for VK’s travelling overseas and wanting to gain a reciprocal licence or use CEPT equivalency.

These are just my initial thoughts – with probably more to come when I re-read the documents yet again, but I hope it gives a push to thinking about what the outcome will mean. Yes, we mostly might already have our licences but any changes will affect how new people enter the hobby, upgrade from a lower level  - or maybe even get turned away because of prohibitive costs. 

I might currently be a WIA Assessor but that isn't limiting my thoughts to Option 1 as a keep-on-going approach. I am open to relevant ideas that might help me form a better submission.

Your submission to the ACMA might just make that slight difference in the consultation outcome provided it is well thought out and well presented.

Doug,  VK4ADC
WIA Assessor 4-040

[VK3QI]

Doug,

Regarding the costs associated with the various proposals, it is enlightening to look at the OMC costs for the Maritime Operator Licence (especially the LRCOP which is the closest to the Amateur Licence).

http://www.amc.edu.au/industry/omc/omc-fees-and-payment

The AMC is required to only charge on a cost recovery basis (like the WIA) and now that the LRCOP has a practical assessment element to it,  the costs are considerable.  

Examination $89  or  Unit of Competency $49 from an RTO (but the RTO may have already charged a considerable amount for the Unit)

The WIA currently charges $70 (and $35 for under 18).

What needs to be considered in any of the options, is that the initial licence fee and renewal fee may be under a separate organisation, unlike what happens now where the WIA issues licence/callsign recommendations.

One wonders what the ultimate cost would be if Option 1 was adopted and the preferred tenderer was only prepared to do the examinations.    What would the ACMA  charge then for the callsign issuance?


Cheers

Peter  VK3QI

[VK3QI]

Doug, 

I should have added; "[i]Examination $89  or  Unit of Competency $49 from an RTO (but the RTO may have already charged a considerable amount for the Unit)"[/i]

Typically that RTO Competency Training can cost $250 or $300  for the unit MARC020 or MARO003 required for the LROCP.

Of course one could do the study individually and just take the examination (just like what can happen with the Amateur licence exams).

********************

I just hope that anyone who makes a submission to ACMA understands that the whole issue of initial and on-going licence costs is an entirely separate issue that brings into focus the difference between a class and apparatus licence and the implications to the Amateur Service. 

Cheers

Peter  VK3QI

[VK2ZRH]

Peter VK3QI said > . . . the difference between a class and apparatus licence and the implications to the Amateur Service.

Under the new radiocommunications act, there will only be one type of licence (parameters-based licence) - the three licences of the past - Spectrum, Apparatus and Class licences - will be no more. Hence, it's not an issue for this consultation.

[VK3QI]

Roger, Roger.

I understand that, but I don't believe that this decision has been promulgated to the vast majority yet  (both Amateur and other services)  and the consequent effects this may have on future licences.

I am not aware that the second consultation stage has occurred yet and that there has been any discussion about subsequent subordinate legislation.

Perhaps you are privy to further information?

Cheers

Peter  VK3QI

[VK2ZRH]

I am unsure what you mean here, Peter.

Can you expand on your first paragraph? Are your referring to whether the ACMA/DoCA has/has not chosen to adopt parameters-based licensing (or, will retain Apparatus-Class-Spectrum licensing)? See: www.communications.gov.au/what-we-do/spectrum/spectrum-reform

There has only been one consultation stage for the Exposure Draft of the new Radiocommunications Bill; from the DoCA website: "There will be a second round of consultation before the Bill is finalised for introduction into parliament." It is clear from submissions to the first Exposure Draft that there is little question that parameters-based licensing will be introduced in the new radcomm Act. The government's intention was first advised in 2014 and publicised by the WIA (web, broadcast, AR mag) at regular intervals every year since then. 

Consultation is launched by the govt in the public domain - keep an eye on the ACMA and DoCA websites. 

I am not privy to any more information than is already in the public domain.

[VK3QI]

Hi Roger,

The Draft FYSO 2018-2022 mentions the ED2 (page 62 and table 4, page 4) but no specific time is mentioned as to when ED2 might be released and over what time frame.

The rest of the FYSO still refers to the different types of licence.

I see mention that the sunset date has been changed to April 1 2023, with a clear indication that DoCA and ACMA will have achieved the required changes prior to that date.

My first paragraph refers to my understanding that many services are still of the belief that changes to the RadCom act (1992) are still not a fait accompli, when in fact, as you quote from the DoCA Website, "parameter- based licensing will be introduced".

Another item that I picked up in reading the FYSO was this little gem.

Table 9, page 20    3.3 - 3.4GHz

"Noting incumbent use of the band, the ACMA is of the view that this band may be a candidate for consideration of dynamic spectrum-access type arrangements, to promote sharing and increase the utility of the band. If the ACMA pursues this idea, it will engage further with relevant stakeholders".

It will be interesting to read any discussion papers released with the ED2 and how they will affect Amateur licensing arrangements.

Cheers

Peter  VK3QI

---

Hi Roger,

The Draft FYSO 2018-2022 mentions the ED2 (page 62 and table 4, page 4) but no specific time is mentioned as to when ED2 might be released and over what time frame.

The rest of the FYSO still refers to the different types of licence.

I see mention that the sunset date has been changed to April 1 2023, with a clear indication that DoCA and ACMA will have achieved the required changes prior to that date.

My first paragraph refers to my understanding that many services are still of the belief that changes to the RadCom act (1992) are still not a fait accompli, when in fact, as you quote from the DoCA Website, "parameter- based licensing will be introduced".

Another item that I picked up in reading the FYSO was this little gem.

Table 9, page 20    3.3 - 3.4GHz

"Noting incumbent use of the band, the ACMA is of the view that this band may be a candidate for consideration of dynamic spectrum-access type arrangements, to promote sharing and increase the utility of the band. If the ACMA pursues this idea, it will engage further with relevant stakeholders".

It will be interesting to read any discussion papers released with the ED2 and how they will affect Amateur licensing arrangements.

Cheers

Peter  VK3QI

[VK4ADC]

RASA has also posted an info request on this topic :

http://vkradioamateurs.org/rasa-calls-fo...cma-paper/

See also http://vkradioamateurs.org/acma-consulta...licencing/

It is good to see the muck being stirred up a little through the previous posts - once it settles the best approach (i.e. options 1,2,3 - or a combo) may be a little easier to identify for my own submission.
 
P.S. 
Am I a RASA supporter? 
No, but it might pay to keep an eye on what they say/do to stay informed.

[VK4ADC]

From text edition for JUNE 10 2018 - VK NATIONAL NEWS BROADCAST ON VK1WIA : http://www.wia.org.au/members/broadcast/wianews/

Also in MP3 edition of news available at: http://www.wia-files.com/podcast/wianews-2018-06-10.mp3

" 
As many of you are aware the Australian Communications and Media Authority recently released a discussion paper seeking feedback on three methods being contemplated for licencing of Amateur Operators when the current arrangement expires in 2019.

 We request your assistance in providing feedback to be included in our submission that will be aligned with the "Beyond 2020" strategy outlined at the recent conference.

 If you have any feedback on the discussion paper that you would like us to consider in the WIA submission, please email beyond2020@wia.org.au.

 We also encourage you to have your say by directly responding to the ACMAs discussion paper. A link to the discussion paper can be found on the WIA website.

 https://www.wia.org.au/newsevents/news/2.../index.php

 Thats all from me
 73
 vk4apm
"

[VK4ADC]

BUMP .. to the top again..

Regardless of the WIA submission, you are able to put your independent submission into the ACMA melting pot.  

Remember that the WIA may put in a WIA-justified submission where yours can truly be independent.

There is a little time left until the 2nd July closing date so best put your ideas & comments down in black and white and get your submission in.

How and where details are on the ACMA document available from an earlier link.

[VK4ADC]

Have just uploaded my independent submission document, with a few days to spare before the closing date of 2nd July.

Have you done yours yet ????

[VK4ADC]

In June the ACMA issued a consultation paper regarding alternate qualification frameworks for Amateur Radio in advance of issuing a tender in late August.   The regulator has released the results of this consultation process to which 45 responses were received. 

For those who have been following this process the ACMA has announced that they will be tendering for "Approach 1" (which is a similar approach to that which is currently in place). The WIA will respond to the tender when it is released at the end of August.  

Further information will be made available on the WIA website as it becomes available.

From text edition for AUG 26  2018 - VK NATIONAL NEWS BROADCAST ON VK1WIA : http://www.wia.org.au/members/broadcast/wianews/

Also in MP3 edition of news available at: http://www.wia-files.com/podcast/wianews-2018-08-26.mp3