Ofcom EMF Consultation: Your response needed by Friday, June 12

Ofcom are proposing to impose onerous new licence conditions and mandatory guidance on all licensees (not just amateurs) who are able to transmit >10W EIRP, prompted by recent but unjustified 5G concerns etc.

The RSGB EMF consultation response guide says:

However RSGB does not agree with Ofcom’s proposals to implement that principle by adding a major new enforceable condition to Amateur licences. We believe this would be:

1. In breach of statutory general duties
The Communications Act 2003 and the Wireless Telegraphy Act 2006 together require that regulations made by Ofcom:
• Must be proportionate, objectively justifiable, and targeted only at cases in which action is needed;
• Must not impose burdens which are unnecessary;
There would also be a danger of double regulation with what is normally a HSE/PHE matter.

2. Not objectively justifiable
• The Amateur licences include a long-standing requirement that safety precautions should be taken against “radio frequency radiation” which is accepted by Public Health England (PHE), and the NRPB before it, as being proportionate to the low levels of risk arising from Amateur Radio activities.

3. Inadequate with respect to the requirement for impact assessments
• The document contains no impact assessment of any kind.

4. Disproportionate and Discriminatory
We emphasise that all impacts upon Amateur Radio will be disproportionate to the related risks of harm.
• They will be extremely disruptive to the Amateur Service and Amateur Satellite Service
• They fall most heavily upon the very large numbers of non-commercial licensed spectrum users many of whom lack the resources to make the assessments demanded.

The RSGB recommends you acknowledge the need for ICNIRP guidelines but to state that the proposals from Ofcom are not proportionate for amateur licensees.

More details on the consultation and the Response Guide to help you with your response along with a copy of the RSGB’s response can be found at

Responses must be submitted to Ofcom before the consultations closes on June 12.

Ofcom Consultation PDF: Proposed measures to require compliance with international guidelines for limiting exposure to electromagnetic fields (EMF)

Ofcom Consultation page

5 GHz – RSGB respond to Ofcom

The RSGB has published its response to the Ofcom statement on increasing the amount of the 5 GHz band that can be used for WiFi. The Amateur Satellite Service has a Space-to-Earth allocation at 5830-5850 MHz.

Annex 6 of the Ofcom 5 GHz statement says regarding Fixed Satellite Service (FSS) operation in 5725-5850 MHz:

“…once it becomes clear that this band will become used for Wi-Fi worldwide it will become less attractive for new satellites.”

“In Table 2 below we show the impact that different regulatory regimes for Wi-Fi might have on the exceedance of the protection criteria of the most sensitive satellites in 5.8 GHz assuming a comprehensive Wi-Fi roll-out across Europe and Africa.”

“As discussed previously, the risk of interference is an aggregate of all Wi-Fi use and so will rise slowly over a number of years rather than appearing suddenly.”

“The UK cannot cause interference to 5.8 GHz satellites on its own but it is fairly likely that Europe and Africa will follow our lead. This is likely to be driven by the potential for 5.8 GHz to become a worldwide Wi-Fi band.”

Response of RSGB to the Ofcom 5 GHz Statement

Ofcom 5 GHz consultation and statement page

Direct link to Ofcom statement PDF

Ofcom 5 GHz Consultation – RSGB and AMSAT-UK responses

Ofcom-logo-col-tIn their response to the Ofcom consultation on Wi-Fi in the 5 GHz Amateur Radio allocation the RSGB said “We are deeply disappointed in respect of Ofcom’s compliance with its duties…”

The Radio Society of Great Britain (RSGB) response highlighted that:
a) Ofcom has deliberately not contacted the most innovative incumbents/stakeholders as
stated in Para 3.43 (only Wi-Fi) prior to the formal consultation period
b) As an incumbent we have been blocked from contact during the consultation
c) Ofcom has ignored their duty with respect to CEPT ECA allocation footnotes ECA17/23
d) We expect Ofcom to makes amends and engage, or we will consider escalating this

The Society pointed out that “Ofcom’s research is badly flawed and belittles incumbents…” and “Ofcom strategy for Consumers is also flawed…”

The RSGB describes how “Ofcom’s preference risks causing harmful interference at home and internationally” and “Ofcom continues to unfairly suppress the most innovative stakeholder in the band, and undermine technology for innovation and emergency communications…”

Read both the RSGB and the AMSAT-UK responses at

Ofcom propose using Amateur Radio band for Wi-Fi

CEPT European Common Allocation Table

Ofcom propose using Ham Radio band for Wi-Fi

AMSAT members with the amateur radio 5 GHz and 10 GHz Phase 4B transponder MSS geosynchronous satellite

AMSAT members with the amateur radio 5 GHz and 10 GHz Phase 4B transponder MSS geosynchronous satellite

Ofcom is consulting on plans to put Wi-Fi across Amateur and Amateur Satellite spectrum in the 5 GHz band.

The Ofcom consultation document implies that amateur satellites in 5 GHz only operate in very Low Earth Orbits – This is false.

UNITEC-1 Venus spacecraft with amateur radio 5840 MHz payload

UNITEC-1 Venus spacecraft with amateur radio 5840 MHz payload

A5.28 Amateurs can access 5650-5850 MHz with amateur satellite Earth-to-space links in 5650-5670 MHz and space-to-Earth links in 5830-5850 MHz. Most current amateur satellites are typically nano or picosats (also called ‘cubesats’) that occupy slightly elliptical sun-synchronous low earth orbits at 60-800 km altitude. These smaller satellites have relatively low power and antenna gain.

Radio amateurs have sent 5 GHz payloads into far higher orbits. Examples are the Venus orbiter Unitec-1 which operated on 5.840 MHz and AO-40 which is in a 58,836 km High Earth Orbit (HEO). The 5 GHz band will also be used by the Geosynchronous Phase-4B payload and the HEO Phase-3E satellite both of which are currently under construction.

The use of 5725-5850 MHz for Wi-Fi would adversely affect reception of the network of amateur weak-signal propagation beacons.

Ofcom-logo-col-tThe Ofcom press release says:

As broadband delivered to the home gets faster, people increasingly expect their Wi-Fi to provide several services at once – such as video streaming, video calls, gaming and remote working. This demand puts pressure on the spectrum which carries Wi-Fi signals.

Most Wi-Fi routers in the UK currently use a part of the spectrum called the 2.4 GHz band, but this is becoming increasingly congested and can impair broadband delivery of high data rate applications such as streaming video or live TV.

Many people now have newer broadband routers, which use not only the 2.4 GHz band, but also the 5 GHz band – which offers much more spectrum and can accommodate wide channels suitable for high data rate uses.

To make connections faster, Ofcom is proposing to open up an additional ‘sub-band’ within the 5 GHz frequency range for Wi-Fi – while ensuring protection for other users, such as satellite services.

The extra sub-band would increase the number of 80 MHz channels available for Wi-Fi from four to six, to accommodate data-hungry applications. These extra channels – which are already being used in the United States – could be opened up in around two to three years.

The consultation closes on July 22, 2016.

Ofcom 5 GHz consultation http://stakeholders.ofcom.org.uk/consultations/5-GHz-Wi-Fi/

You can respond online at

The UK Microwave Group (UKuG) point out that Ofcom’s plans for 5725-5850 MHz would unilaterally raise the noise floor for little benefit to consumers. They say 5760 terrestrial & EME and 5840 satellite reception need maximum protection. A Word Doc response form is available on the UKuG site at http://www.microwavers.org/

The UK Microwave Group loans equipment to get amateurs started on 5.7 GHz

Network of amateur weak-signal 5.7 GHz propagation beacons

Unitec-1 amateur radio Venus spacecraft

Ofcom clarifies position on SES call signs

Ofcom-logo-col-tOfcom had said NO to Special Event Station (GB) callsigns being used in the bands above 440 MHz for Amateur Satellite or Terrestrial operation.

The RSGB intervened and Ofcom have now issued revised clarification – Operation above 440 MHz with SES (GB) calls is permitted, so is operation in the 5 MHz segments.

It appears the SES call sign application form OfW287 is rather old and doesn’t list all the available bands. Fortunately that doesn’t matter since the NoV issued for the SES call sign is not band specific.

Well done RSGB !

September 22 – Special Event Callsigns and Microwave Bands

UK Microwave Group Yahoo Reflector http://groups.yahoo.com/group/ukmicrowaves

The Radio Society of Great Britain is inviting all radio amateurs in the UK and Crown Dependencies to complete an online questionnaire. You can find the survey at http://www.rsgb.org/ar-survey

Essex Ham interviewed RSGB President John Gould G3WKL about the 2015 Amateur Radio Survey. Listen to the interview at http://www.essexham.co.uk/news/rsgb-survey-2015.html

UK Spectrum Strategy

RSGB Amateur Radio SlideOn June 30, 2015, Graham Murchie, G4FSG, RSGB Chairman and Murray Niman, G6JYB, Chairman of the RSGB Spectrum Forum presented the case for amateur radio to the UK Spectrum Policy Forum (UKSPF). The Amateur-Satellite Service featured in this presentation.

The Forum has been established as a sounding board to UK Government and Ofcom on future approaches on spectrum with a view to maximising the social and economic value from the spectrum.

The UK Prime Minister David Cameron has stated the ambition to double “the economic benefits of spectrum to UK companies and consumers from roughly £50 billion today, to £100 billion in 2025″.

The UK Spectrum Policy Forum, open to all users of spectrum, is the main vehicle for harnessing user insights and informing these policy decisions.

Read the RSGB story at http://rsgb.org/main/blog/news/gb2rs/headlines/2015/07/06/uk-spectrum-strategy/

Download the presentation slides http://thersgb.org/archives/events/ukspf/150703-RSGB-UKSPF-presentation.pptx

UK Spectrum Policy Forum (UKSPF) https://www.techuk.org/about/uk-spectrum-policy-forum