RSGB statement concerning 40MHz in the UK

In a previous post, I outlined how several radio amateurs in the UK were in the process of applying for Innovation and Trial licences from OFCOM to carry out tests on the 40 MHz band. 

The RSGB have now outlined the position of OFCOM on the issue...

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RSGB statement concerning 40MHz in the UK

There have been recently a number of reports of individual holders of UK Amateur licenses gaining Innovation and Trial licences from Ofcom to conduct experimental transmissions on 40MHz (8m).

Ofcom has made it very clear for several years that there was no likelihood of UK radio amateurs gaining any access to 40MHz which included NoV (Notice of Variation) to a UK amateur licence or an amateur SRP (Special Research Permit). 

The RSGB has consulted Ofcom as to the exact status of these Innovation and Trial licences. Ofcom’s reply was as follows:

“We have been approached by a couple of individuals wanting to conduct experiments in the band. Like all other research and innovation requests Ofcom receives we have put these through our Innovation and Trial licensing regime. If the coordination checks are passed, they are being issued with an Innovation and Trial licence. These are issued for up to 12 months on a non-interference, no protection and non-operational basis. 

These are not Amateur Radio Special Research Permits and licensees do not fall under the Amateur Radio licence terms and conditions. Therefore, applicants are not required to have passed an amateur exam or hold a callsign. Although we are allowing this experimentation, we would like to make it clear that we have no proposals to allow wider amateur radio access to the 40 MHz band.

Clause 9(6) of the UK amateur terms states “The Licensee may receive Messages from an overseas amateur or from an Amateur duly authorised by Ofcom on a frequency band not specified in Schedule 1 but the Licensee may only transmit on a band specified in Schedule 1 which is authorised under Clause 9(2).”

Users of 40 MHz under an Innovation and Trial (I&T) licence are not authorised under the Amateur Radio licensing regime and there is no requirement to have passed an amateur radio exam to obtain such a licence. Clause 9(6) of the Amateur licence is designed to cover additional frequencies, such as 70 MHz and 146 MHz, which are not contained in Schedule 1 of the Amateur Radio licence but Ofcom has authorised via a Notice of Variation (NoV). 

We would like to make clear that we have not duly authorised any amateur to use a frequency band not specified in Schedule 1 through this process. Reception of transmissions authorised under an I&T Licence should therefore be treated the same as those authorised under other licences that Ofcom issues such as business radio or maritime.

We would also like to make clear that I&T licences do not permit operational or commercial use. These licences are designed to support individuals and companies in carrying out research, development, testing and demonstrations of equipment. 

Therefore, the use of the 40 MHz band under this licence should be for these purposes only. The licences are granted on the basis that the user will be carrying out such research and not operating on the band in a similar way to the frequencies listed in Schedule 1 of the licence.”

Ofcom’s view is very clear. Any operation on 40MHz in the UK is not Amateur radio and therefore cross-band contacts to such stations by UK radio Amateurs operating on the bands licenced for amateur radio are not permitted.

*** RSGB Statement Ends

Just to highlight that the RSGB are just outlining the position of OFCOM so there is no point in bashing the RSGB over this.

Several radio amateurs in the UK obtain special 40 MHz permits

In a previous post in February of 2022, I reported on how the UK licensing authority OFCOM had refused to give NOV's (Notice of Variation) to radio amateurs to carry out tests on the 40 MHz band.

The good news is the OFCOM are allocating temporary Innovation and Research licenses.

Roger, G3XBM in the east of England can operate from the 2nd of April for 1-year with 5-watts. Roger writes... "After a very long wait OFCOM has approved my 8m TX permit that runs from April 2nd for a year.

It permits me to use 40-42MHz with digital modes (including CW) at 5W ERP max. I expect to erect a wire dipole which is directed towards Europe.

I expect to be mostly on FT8 around 40.676MHz with precise frequency done in liaison with others. What I hope is all 8m FT8 stations can be monitored with one USB dial setting, but spaced out. 5W should certainly cover Europe with Es. I shall try some local CW crossband QSOs, but hope to be on FT8 24/7."

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John, G0JJL in the north-west of England can operate from the 1st of May 2022. John writes... "I am one of the UK Amateurs that have recently obtained a temporary 12 month licence to transmit on 40MHz. 

These licences are not Amateur Radio special permits, they are Innovation and Research licences which have nothing to do with Amateur Radio at all. In fact, anyone in the UK can apply for this type of licence whether they are a licensed Amateur or not. 

The UK regulator, Ofcom, do not issue callsigns with Innovation and Research licences, it is up to the licence holder if they wish to use one and the licence holder can use any callsign of their choice. Some UK Amateurs who obtain an Innovation and Research licence might decide to use their Amateur Radio callsigns on 40MHz and this is perfectly legal so far as Ofcom are concerned. However, using their Amateur Radio callsign on 40MHz does not mean their station is then an Amateur Radio station operating on 40MHz, it is not, it remains an Innovation and Research licence station only and this as been confirmed by Ofcom. 

My Innovation and Research licence was granted to allow research of propagation in the 8m band and my licence permits use of 40.680MHz and 40.690MHz using narrow band digital modes and CW from 1st May 2022 from two locations. The callsign to be used is GR9A." 

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Neil, G0JHC in the north-west of England has also applied for a permit and will be using the callsign GR9B. Neil is located in the same area as G0JJL.

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Paul, G7PUV in the south-east of England is currently applying for a permit. Others are likely to follow.

Analysis... This is indeed welcome news as it allows more signals on the band which is great for experimentation. There's only so many times you can report a beacon on 40 MHz.

At the end of April, the Sporadic-E season will have started and it should be quite easy for the UK stations to be heard in countries with permits like Slovenia (S5) and Croatia (9A) which are around the 1200km mark.

By late May and all of June, there should be plenty of short skip Sporadic-E with distances in the region of 500-1000kms possible.

There are plenty of opportunities for radio amateurs in the UK to participate in these experiments by listening for the permit holders and working them cross band from 40 MHz to either 28 MHz or 50 MHz.

40 MHz is an excellent band for meteor scatter tests. Tropo contacts up to 200kms may be possible and aircraft scatter propagation can also be explored.

Trans-Atlantic contacts to the permit holders in the USA should be possible in May and June by multi-hop Sporadic-E. There is also the possibility of very long paths to South Africa.

Maybe in time, radio amateurs in the UK will get an allocation at 40 MHz but for now, this is a 'foot in the door'. The results of these Innovation & Research permits can be used to show a real need for a formal amateur radio allocation for this band.

Can EI stations work these special permits? ...Not to be pedantic but the answer is no. In Ireland (EI), the amateur radio license states quite clearly that we can only make contact with other radio amateurs. Making contact with a special experimental license in the USA, Canada or the UK is not the same as say Slovenia, Croatia or South Africa.

It's up to EI stations what they do formally or otherwise but I'm just clarifying the current situation.

Links...
a) Plenty of information as always on my 40 MHz page.

Update on UK amateur radio stations getting permission to experiment on the 40 MHz band

As of February 2022, a number of amateur stations in the UK are trying to get permission from OFCOM, the UK licensing authority to carry out experiments on the 40 MHz band.

NOV... Roger, G3XBM reports that he applied for a Amateur Radio Special Research Permit and getting a Notice Of Variation (NOV) as shown in A above. His application for this was recently turned down.

At present, some UK radio amateurs are using these NOV's to experiment with compressed digital video techniques at 146 MHz and 71 MHz.

I know there is at least one more person waiting for a reply on their application for a 40 MHz NOV although it doesn't look good at this stage.

Innovation & Trial License... The second route is to apply for a Innovation and Trial License as shown as B above. This costs at least £50 and G3XBM is currently applying for one of these.

This would seem to be similar to how the FCC in the United States recently allocated special experimental permits to seven individuals.

OFCOM... A few years ago, the RSGB (Radio Society of Great Britain) held discussions with OFCOM about new frequencies and allocations. OFCOM were of the view that they would not allocate anything for 'more of the same'. 

In other words, they're not going to allocate new frequencies for DX-ing, contesting or just talking to someone else down the road. Their view was that radio amateurs in the UK have more than enough frequencies for this and they're probably right.

Any new permit or allocation will have to show there is a genuine need for it. Radio amateurs experimenting with modern compressed digital video techniques and getting the signal to fit inside a limited band is a good example of this.

Looking forward... It's not looking great at the moment but it would be very useful if some UK stations were allowed to use the weak signal mode WSPR on low power on the 40 MHz band on an experimental basis. They would be unlikely to cause any interference to other users if they were just given say the ISM band of 40.670 to 40.700 MHz to experiment with. 

This could be used to carry out propagation experiments as we approach the peak of the next sunspot cycle. As the solar flux increases, it's not always obvious where the maximum usable frequency is for the F2 layer of the ionosphere.

We know it's in the low VHF region but where? It's well above 28 MHz but below 50 MHz. Being able to do propagation research is where the real value of having an allocation at 40 MHz lies.

It seems likely that if an application is going to be successful then it will have to go into some detail as to how the experiments will be carried out and how any potential interference to other users can be mitigated.

Radio amateurs in the UK unlikely to get 40 MHz allocation

 

Ofcom is the licensing authority for the radio spectrum in the UK and in a response to an informal query, they indicated to the Royal Society of Great Britain (RSGB) that an allocation at 40 MHz for radio amateurs in the near future was unlikely.

In an editorial comment in the VHF/UHF column of the November 2020 issue of RadCom from the RSGB, the VHF Manager John Regnault, G4SWX wrote... "In recent years, the RSGB has informally asked Ofcom about amateur access to 40 MHz. Ofcom responded that this was not amateur radio spectrum, whilst they would agree to the continuation of the GB3RAL propagation beacon on 40 MHz, they would not agree to further beacons or general access to 40 MHz by UK amateurs."

"Readers should also note that NoV access to unused spectrum at 71 and 146MHz was granted for innovative experimentation and not more of the same (CW/SSB/FM)."

"The view expressed by Ofcom is that UK radio amateurs have adequate VHF/UHF spectrum for these traditional activities." 

The GB3RAL 40MHz beacon first went on air back in 2007 and it was only operational for a short period. The RSGB are now looking to find a new home for this 8-metre beacon and getting it operational again.

As of November 2020, just Ireland, Slovenia, Lithuania and South Africa have some sort of access to the 40MHz band.

For more information on the new 40MHz band, visit this page... https://ei7gl.blogspot.com/p/40-mhz.html

UK Radio Spectrum Review Shows Increased Noise on VHF Bands

Ofcom is the organisation that is responsible for radio regulation in the UK and they have just released a document for a review of the UHF spectrum from 410 to 470 MHz. While most of the report covers the UHF spectrum as expected, they do make a reference to the increase noise levels on the lower VHF bands.

In the chart below, 'Band 1' covers 55 to 68 MHz while 'VHF Low' covers 68 to 87.5 MHz.

In the past, the assumed noise floor for radios was -116dBm and the planned coverage area of a radio system was -104dBm, i.e. 12 dB over the noise floor.

What Ofcom have found is that the actual noise floor is currently 12dB higher than previously thought. As a result, the planned service signal level must now be -92dBm.

This higher noise level is likely due to a variety of sources. Just think of the extra electrical power lines, increased use of switch mode power supplies in electrical equipment and the vast multitude of computer and IT systems. Taken all together, they result in a large increase in electrical noise especially in urban areas.

What this means for amateur radio is that bands like 4 metres (70 MHz) and 6 metres (50 MHz) are likely to be much noisier than they used to be in the past. Higher VHF and UHF bands are not effected as badly. It's likely that the extra noise levels also extend down to the higher HF frequencies like 14 to 28 MHz as well.

This higher noise floor as announced by Ofcom is in contrast to what was said by Comreg, the Irish licensing authority. In response to a submission by the Irish Radio Transmitters Society, they said the following in a report published in mid-2016....

2:17 ComReg notes that no evidence was provided by the IRTS to support its assertion that the noise floor is increasing and, further, ComReg observes that its monitoring activities do not indicate a significant increase in the noise floor on the whole;

Perhaps the noise levels in the Ofcom report are based on the very large urban areas in the UK but it's hard to imagine that the noise levels haven't increased substantially in the various Irish cities and towns in the last 20 years.

Links...
1) Ofcom Strategic Reeview of UHF Band 1 and 2 410 to 470 MHz
2) Comreg Radio Spectrum Management Strategy 2016 to 2018