From the WIA, original post here.

Date : 26 / 10 / 2016 
Author : Roger Harrison – VK2ZRH

The Wireless Institute of Australia (WIA) has submitted a comprehensive response to the proposed update of the Australian Radiofrequency Spectrum Plan (ARSP), prepared by the Australian Communications and Media Authority (ACMA) and released for stakeholder comment in September, with a four-week deadline for submissions.

Following up on previous submissions on amateur licence conditions to the ACMA in 2014 and in April this year, the WIA’s response to the proposed Spectrum Plan update seeks access to new bands at 70 MHz and 920 MHz, in addition to the new global amateur band at 5.3 MHz – 60 metres – agreed at the World Radiocommunication Conference, WRC-15, last November.  In addition, the WIA is seeking primary status for 50-52 MHz and extensions to the 160 metre band and the 80 metre DX Window.

The Australian Radiofrequency Spectrum Plan includes a Table of Frequency Allocations from 8.3 kHz to 420 terahertz (THz) that divides-up the spectrum to show the general purpose of each band, to which services the bands are allocated, and associated footnotes relevant to particular allocations. It was last reviewed in 2013.

In the submission, the WIA notes – with evident relief – that there are few changes that impact the 25 amateur bands spread throughout the Table of Frequency Allocations.  However, the Institute highlights the issue that the secondary Amateur allocations, where amateurs share bands with primary users, face pressures of spectrum demand – and loss of band access – from telecommunications services and applications for the Internet of Things.  This is particularly so for amateur bands across the microwave spectrum.

Accordingly, the WIA submission advocates that, while the position and expectations of primary users is understood, that the Amateur Service should retain some access in all current bands – anywhere in the spectrum – where amateurs presently have secondary status, to uphold the fundamental principles embodied in the definition of the Amateur Service – of self-training, experimentation and intercommunications for personal aims and without pecuniary interest.  This signals the Institute’s long-held position that some band access is retained where spectrum demand whittles away parts of a secondary amateur band.

The ACMA introduced two additions to its “catch-all” clause – Clause 10 – that enables it to allocate or permit use of a frequency band for a purpose different from that specified in the Table of Frequency Allocations.  Clause 10 had eight sub-clauses in the 2013 Spectrum Plan and the ACMA introduced a ninth regarding satellite Space-to-Earth services, and a 10th sub-clause to allow use of a frequency band by an “unspecified” service by written agreement with an incumbent service, provided that harmful interference is unlikely.

The WIA signalled its support for the new Clause 10 (10) as the Institute’s view is that it enables a more dynamic response to changing circumstances in demand for and use of spectrum, “ . . particularly in response to changing circumstances and new developments, which in the past has been difficult to accommodate in a timely manner, if at all.”

A drafting error in the Table of Frequency Allocations affecting the 40 metre amateur band was picked up by the eagle eyes of the WIA’s Spectrum Strategy Committee.  The proposed update to the Spectrum Plan lists Broadcasting as a primary service in the Australian allocation of the 7100-7300 kHz band when, in fact, this was removed back in 2009.  The WIA has requested that the Table of Frequency Allocations be corrected, along with the related Footnote.

The updated Spectrum Plan is expected to begin on 1 January 2017.  Once it is amended, affected subordinate legislation, such as licence conditions, will also be amended subsequently.  The ACMA has advised previously that, due to various factors, all foreshadowed changes may not occur by the end of 2016.

The ACMA will publish on its website stakeholder responses to the proposed updates to the ARSP in due course.

The WIA’s submission can be downloaded here.