ComReg‘s massive allocation of low-band VHF spectrum to radio amateurs in Eire is most welcome and sets an example to other regulators but other aspects of the regulations raise questions especially regarding Amateur-Satellite Service allocations.

Unusually for an official document ComReg seem to use “AMSAT” as an abbreviation for the ITU Amateur-Satellite Service, however, they fail to define exactly what they intend it to means. AMSAT is a registered trademark of a USA Corporation, see https://www.amsat.org/notification-of-trademark-copyright-and-other-proprietary-information/

Frequency Table

The low-band VHF Amateur Service allocations are now:
30.0-49.0 MHz 50 watts
50.0-52.0 MHz 100 watts
54.0-69.9 MHz 50 watts
69.9-70.5 MHz 50 watts

The national amateur radio society, IRTS, are to be congratulated on achieving amateur access to so much spectrum.

The ComReg document as written appears to mean amateur satellite operation is not permitted in these ITU Amateur-Satellite Service allocations:
435-438 MHz
1260-1270 MHz
5650-5670 MHz
5830-5850 MHz

Oddly satellite operation is permitted in 430-432 MHz but there are no amateur satellites there!

Transmitting to amateur satellites operating in 2400-2450 MHz is only allowed with a Special Permit, it’s not included as standard in the licence. Even with the Permit amateurs will be restricted to a transmitter output of just 25 watts.

ComReg limit which modes that can be used in each band by listing three-character ITU Emission Designators. For example X7F is among those permitted for the 54.0-69.9 MHz band and means Digital Amateur TV (e.g. DVB-S) can be used. Unfortunately it appears to be the only band where X7F is permitted, an unnecessary restriction.

The Emission Designators for digital voice modes such as D-STAR and DMR don’t appear to be listed anywhere suggesting they cannot be used.

In 2006 the UK regulator Ofcom adopted a Technology Neutral approach to amateur radio, they scrapped listing of specific Emission Designators and allowed all modes to be used. It is unfortunate ComReg hasn’t taken this opportunity to do the same.

The new ComReg amateur radio document can be downloaded from
http://comreg.ie/publication-download/amateur-station-license-guidelines