Appendix 3 - Amateurs and Citizens’ Band (CB)

Your views on the proposals set out in this document are sought by 31 December 1999. Comments should be sent to the address below. It would be helpful if lengthy written documents could be sent via email of on disk in Word 7:

 Contact Details:

Karen Scott
Radiocommunications Agency,
Wyndham House,
189 Marsh Wall,
London,
E14 9SX.

Email: amcb@ra.gsi.gov.uk

Fax: 020 7211 0228

APPENDIX 3 Amateur and Citizens’ Band (CB)

Amateur Radio

Scope for Spectrum Pricing

1 As well as international allocation agreements which could affect the possibility of re-assignment of some bands currently used by amateur radio, there are other policy constraints operating in this area. The RA's priority in allocating spectrum to amateur radio is to encourage its wider use for educational, leisure and amateur research purposes. It is felt that the service represents a valuable resource for 'engineers of the future' and should not be undervalued as such.

2 Spectrum pricing could play a role in relieving congestion in the amateur bands, and parts of the spectrum could be used by fixed and mobile services. There are, however, perceived to be strong positive externalities from the encouragement of amateur use which would suggest there is a case for preferential treatment relative to other users. Given the nature of the individual licences, and the recommendations of the Smith NERA study, the Agency has decided not to use spectrum pricing in this sector.

Nature of Sector

3 The Amateur Radio Service is a long running service, of a significantly international nature. The purpose of the Service is self-training, intercommunication, and experimentation by those interested in radio techniques for solely personal and non-pecuniary reasons. There are currently 60,000 amateur radio licences on issue in the UK.

Spectrum Strategy

4 The Amateur Service has a significant number of allocations throughout the spectrum, ranging from 0.1357 MHz to 250 GHz, many of which are of relatively small bands, or are allocated to the Amateur Service on a Secondary basis. In comparison to certain commercial services, the Amateur service has a large allocation of spectrum for a relatively low population, and does not suffer congestion to the same extent, although there are greater pressures on the use of certain bands where the Amateur licensees report difficulties due to congestion. There are also pressures on the Amateur use of the spectrum from other services in need of new allocations, requiring the Amateur service and requesting to share spectrum with them.

Current licence and Fee Structures

5 Within the Amateur Radio Licence class there are presently a number of licence categories:

Full Class A;
Full Class A/B
Full Class B; Novice Class A, and; Novice Class B.

These licences are pre-packaged, each product providing slightly different spectrum allocations and the use of different power levels. The qualifications required to obtain each licence become more advanced as the number of frequencies and the powers permitted increase. This provides an easier entry level for novices, and a progressive structure of licences for those who wish to demonstrate development. There are no type approval requirements for amateur radio equipment, although international recommendations for good practice in radio characteristics design are increasing. The licence is renewable annually on the anniversary of its commencement. The cost of each licence is £15, except for licensees under 21, for whom they are free.

Proposals

6 In common with other pre-packaged licences, there are several areas of change which could be considered:

(i) Exempt the service from licensing. The variety and number of frequency allocations open to Amateur radio licensees, the number of those allocations shared with other users, the necessity to allocate call-signs to licensees, the diversity of types of operation and the fact that type approved equipment is not required, make it important for the Agency to have a closer association and knowledge of the amateur service than licence exemption would allow. This option will not therefore be considered.

(ii) Single Licence Category. Aspects of the present arrangements indicate that it may be possible to licence all radio Amateurs with the same licence product. The same fee is already payable for each of the present licences, and the same terms and conditions booklet is published for all Full licences and another for both Novice licences. A single Amateur licence would simplify Amateur radio licensing, and be in line with the arrangements in many other countries.

The present reason for providing five different licence products is to provide different frequencies and powers for different levels of Amateur qualification. A licensee's eligibility for holding a particular licence is dependent on the qualifications held. However, the present arrangements demonstrate that it is possible to provide for more than one type of licence within the same terms and conditions, and therefore within the same licence, should it be desirable to retain an element of incentive licensing. The same licence could specify as many levels of licensing as necessary, linking the terms and conditions to be followed in each case to the qualifications held by the licence.

A single Amateur radio licence would of course only use one call sign series. The present system of four distinct call sign series causes additional administrative work. The supply of call signs is a finite resource, and a single call sign series would not suffer from any wastage. Different levels of licensing could be indicated in the call sign by use of a suffix added by the licensee to the unique call sign issued with the licence.

(iii) Long Term Licences. Also for consideration, as in the case of CB radio, is that the period of the licence could be increased from one year to, for example, three years. The Agency is concerned about maintaining up to date details for individuals who would no longer receive an annual prompt but acknowledges that some individuals might prefer this option.

Longer Term Changes

It is an international requirement for individuals operating in the HF bands to have a knowledge of Morse, hence our current Morse test requirement for Class A Licensees. A proposal to remove this requirement from the International Radio Regulations is due to be discussed at the 2001/2002 World Radio Conference and it is likely that this requirement will be dropped. On this assumption, there is scope to move to an incentive based system, whereby operators achieve more privileges by obtaining additional qualifications. The following table represents the type of system that could be considered and the routes for transferring existing licence categories to the new classes.

* Additional examination to focus on interference, EMC, operation at high power levels and related topics.

1 . The cost of enforcing CB is higher than the current income received from licences. This also means that, were the bands currently used by this service to be re-allocated to another spectrum-using service, the large number of small users would make the task of freeing the bands concerned for alternatives users difficult. There is, moreover, little scope for persuading current users to buy more spectrally-efficient equipment, especially whilst such equipment is still relatively expensive and many CB users are unwilling even to buy a licence. Thus, for the case of CB, there is little scope for using spectrum pricing to encourage the use of less spectrum in this area.

2. There are major practical and policy obstacles to the introduction of spectrum pricing for CB. There is a perception of congestion in the CB band by users but this has not been borne out by monitoring exercises. There is at least a theoretical possibility of alternative uses of the spectrum. In practice, however unless a practical solution is found to enforcing spectrum changes and protecting legitimate users from interference, the introduction of such charging would appear self-defeating. The Agency therefore proposes not to introduce spectrum pricing for CB, but will consider maintaining fees at a low level subject to views on the proposals outlined below.

3. CB is designed as a short range radio service and it is available not only for individual hobby use but for business use, for example, by Haulage and Taxi firms. It is designed to be used (unlike amateur radio) without the need for any technical knowledge or qualifications. There is therefore, a requirement for the equipment to be type approved. Currently, there are approximately 36,500 licensees who have access to two sets of frequencies within the UK:

The European harmonised frequencies (CEPT) 26.965MHz - 27.405MHz (40 Channels); the specification for which is ETS 300 135

The UK only frequencies 27.60125MHz - 27.99125MHz (40 Channels); the specification for which is MPT1382/MPT 1320

4. In terms of dealing with cases of interference and enforcement work in general, RA gives priority to the protection of Business and Commercial radio. Where resources permit, enforcement work is carried out but the emphasis is on tackling non approved

equipment use and non-licensed use. It must be emphasised that generally only the most serious cases result in prosecution. Usually the minimum required level of enforcement action is carried out.

5. The spectrum available for CB outlined earlier, is not attractive for general fixed/mobile usage unlike the VHF/UHF frequencies where over recent years the Agency has witnessed a enormous demand for telecommunication purposes. There is

currently, no actual or foreseen future demand for this part of the spectrum. One exception, however was the 934MHz allocation which CBers were sharing on a secondary basis up until December 1998 (when the service was withdrawn). CB uses simple pre-packaged technology i.e. the specific channels are agreed thus requiring no further processing by the Agency. Users are not required to pass technical examinations thus there is no scope for increasing pressure to improve efficiency. The amount of spectrum available for CB use is quite small in comparison with other services.

6. There is a limited amount of business use of the CB service, its usage is confined most commonly to Haulage companies and Taxi firms. Unlike the case of PBR or other 'protected' services for example, no special dispensation has been made for such users - they are all subject to the same terms and conditions and no separate frequency is allocated to them. CBers are not protected from in-band interference. There is also no special international co-ordination required for the spectrum.

7. The cost of the licence fee is currently £ 15 pa for which the licensee receives a licence document. The administrative process is handled by an outside contractor. The licence fee was originally set purely on a cost recovery basis (although for some time the Agency has made a loss in this area). The licence fee covered areas such as enforcement work and research and development. In addition, the licence fee also funded any necessary international negotiation and the production of specifications or other technical work, for example our current work on the feasibility of an AM/SSB CB service. The Agency recently announced that it plans to make the licence free for those under 21, to bring the CB service into line with the amateur service.

8. From a peak of 300,000 licensees (in 1981) numbers have been falling considerably annually. To date, there are approximately 37,500 licensees. It is suspected that there are a large number of unlicensed users. The Agency has also been making a significant

financial loss in this sector for a number of years.

9. In common with other pre-packaged licences, there are several areas of change which could be considered:

(i) Exempt the service from licensing. There are both advantages and disadvantages involved in adopting this option. In all the countries which allow the use of CB equipment, there is no demand for individuals to pass a technical examination before they are eligible to apply for a licence to transmit. Therefore, the equipment used has to be type approved to a National or European harmonised standard.

In addition, there is general agreement within Europe that when efficient use of the spectrum is not at risk and harmful interference is unlikely, given that legal CB Radio equipment requires type approval, the possession, installation and use of radio equipment can and perhaps, should be exempted from individual licensing requirements. Should this occur and providing that all CEPT administration exempt the same categories of radio equipment, it will greatly assist the free movement of radio equipment throughout Europe. Any individual will then of course be able to use equipment without any prior permission from the administration. Conditions currently contained in the licence could be transferred to the exemption regulations and thus would still apply. It is however unlikely that additional facilities would be made available to users, for example the one to one data facilities which are currently under discussion.

The Agency's Local Customer Services currently carry out a number of activities with regard to CB enforcement work. If the CB service became licence exempt, it is likely that certain activities such as licence campaigns, roadside vehicle checks, enforcement action against unlicensed use and in-band problems such as abuse, would no longer be carried out. It is also recognised that licence exemption may cause problems for enforcement officers dealing with interference cases.

The issue of deregulation has been previously raised with CB representative groups who have indicated that they wish to see the licence retained for CB. For this and the other reasons outlined above, the Agency currently supports the retention of a licence.

Registration Scheme. Alternatively, the Agency may consider establishing a 'registration scheme' for the use of CB. The individual user would notify the Agency of any changes to personal details. However, there is no incentive for the licensee to comply and the Agency would need to consider the benefits of such an approach.

Simplification of the Service. Also for consideration, as in the case of amateur radio, is that the period of the licence could be increased from one year to for example, three years. The Agency is concerned about maintaining up to date details for individuals who would no longer receive an annual prompt but acknowledges that some individuals might prefer this option.

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Appendix 4