Foundations of Amateur Radio

From the 19th of February 2024, the ACMA, the Australian Communications and Media Authority, the regulator, is modifying the rules for amateur radio in Australia by moving to an amateur class license where all amateurs will operate under the same license instead of under an individual one.

You must be qualified to operate under the new class license and all currently licensed radio amateurs should now have been issued with a recognition certificate for their current qualification level.

Keep this certificate safe, it authorises you to operate as an amateur and shows which callsigns you currently hold. I've just received a revision that now correctly identifies my callsign VK6FLAB as a four-letter callsign, rather than three-letters which caused concern over the longevity of my call.

There's no annual charge to operate as an amateur, no charge to keep a callsign, and no charge to do an exam, however, if you operate a repeater or beacon, you'll continue to require a transmitter license. There are once-off charges for applications to consider and issue recognition certificates and callsigns but those are not new.

The document that legally defines amateur radio in Australia, colloquially the LCD, is replaced by the Radiocommunications (Amateur Stations) Class Licence 2023. The regulator carefully states that: "To operate an amateur station under the amateur class licence, you must comply with the conditions within it", but doesn't clarify if those conditions have changed or not. External commentary claims they haven't, but it was completely re-written and it's difficult to compare the precise actual wording side-by-side.

This has happened before, for example, when the regulator introduced the Limited license in 1954, the Novice license in 1975, abolished Morse in 2004, and introduced the Foundation, Standard and Advanced licenses in 2005. It was replaced again in 2015 and has been revised since, most recently on the 17th of November 2021.

I suspect lawyers will find potentially unintended but material differences between documents, but to my knowledge, that investigation has not yet occurred. I think this is a perfect example of where the peak bodies claiming to represent amateur radio in Australia have a responsibility.

There are many rules around the who, how and where to conduct a qualification exam. For example, the regulator has decided that online or residential exams are not permitted, leaving venues, printed exams and postal delivery as an ongoing cost and concern.

There are plenty of questions left.

An amateur at Advanced level can hold a club station callsign but it appears that at a Foundation or Standard level you can no longer hold a club station license like VK6BSG and VK7HSD. You still need to log usage of a remote club station. Describing the requirements the regulator uses both "revise their arrangements" and "current arrangements will be retained" in the same paragraph, apparently contradicting itself.

The regulator will ask you every five years if you want to keep your callsign. This infers a system to contact you. What does that look like, how will it be maintained, are there requirements for keeping it current, does it need to have the location of your station, an email address, or just any means of contacting you, and is it public? The official register of radio communication licenses will no longer hold amateur licenses so it's unclear how you'll be able to contact another amateur, or how we'll be able to know who holds which callsigns at what level in which location and when a reminder is due. The details around the new callsign register are incomplete to say the least.

What does breaking the rules look like? With individual amateur licenses your ability to operate is directly linked to you and if found in breach, your license can be cancelled. Under a class license, your ability to operate hinges on knowledge that cannot be taken away.

The regulator publishes the relationship between some international amateur licenses and qualification levels in Australia and as an international visitor you can apparently operate in Australia for 365 days if your current license is recognised. After that, unless you hold a Harmonised Amateur Radio Examination Certificate or HAREC, you need to apply for a recognition certificate after either paying for recognised prior learning or passing an exam, even though you were already automatically recognised as having the appropriate qualifications when you entered the country. Does the list of recognised licenses get longer as more international amateurs pay for prior learning and if you leave the country and return, will the clock reset?

There's more. For example, the date that you got your US Technician license determines your recognition. Before 23 September 2016 you're recognised at an Australian Advanced level, after that at a Foundation level.

And finally, if I were an accredited unpaid volunteer assessor, authorised to administer an amateur exam on behalf of the regulator, would I be permitted to comment like I am here, or would I be expected to speak directly with the regulator about my concerns? What happens if speaking directly to the regulator breaks down? What's the penalty for speaking out? Is the regulator going to stop you from being an unpaid volunteer?

Before you ask why I didn't put these concerns to the regulator, I'll point out that it's not up to me to fix these issues, nor is it my place to make recommendations. I don't represent anyone and in my opinion this should be a community wide public conversation, not held in secret talks behind closed doors.

As an amateur outside Australia I'd recommend that you pay attention, because I'm sure that bean counters will be taking notes to see if there's money to be saved at your regulator.

I'm Onno VK6FLAB