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
https://www.rsgb.org/emf

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)
https://www.ofcom.org.uk/__data/assets/pdf_file/0013/190003/emf-condoc.pdf

Ofcom Consultation page
https://www.ofcom.org.uk/consultations-and-statements/category-1/limiting-exposure-to-emf