First Report Following Release of Discussion Paper
The Basis of this Report
1. Introduction
2. The definition of the "amateur service"
3. The banned country list
4. The amateur service as a resource for emergency communications
5. Messages on behalf of a third party
6. The technical and operational qualifications to be an amateur
7. Morse code
8. The international recognition of amateur licenses
9. The amateur satellite service
10. Other matters
11. General approach
12. Conclusion
13. Further comments
| THE BASIS OF THIS REPORT: |
The background to these issues, our terms of reference, the constitution of the Committee and our detailed discussion of the issues are all set out in our Discussion Paper April 1996. This Report is written on the basis that it will be read with our Discussion Paper and we do not repeat what is there set out or what we then said except to the extent necessary to put what we now say in context. Please refer to our Discussion Paper as you consider this Report.
We have received many hundreds of pages of comments from societies, organisations and individuals. We summarise, as best we can, issues, knowing that in many cases we do not properly reflect all the points or the careful arguments that have been put to us, nor do we attribute all of the views or arguments put to us. To do so would make this Report too long.
| 1. Introduction |
We said in our Discussion Paper April 1996 that after the receipt of comments and submissions by the end of June 1996 we would prepare a Report which we hoped would be considered by the Region 1 Conference in October 1996.
We proposed that we would then prepare a further Report, for consideration by the Region 3 Conference in 1997, and then repeat the process for the Region 2 Conference in 1998. We would, throughout this process, seek comments and submissions from individuals, groups and societies.
We recommended that each Region should express their view, but at the same time delegate the task of formulating a global policy to the Administrative Council after the Region 2 Conference in 1998.
Neither the Discussion Paper or this Report has been considered by the Administrative Council. Our suggested time table and general approach will be considered by the Administrative Council at its meeting immediately after the Region 1 Conference in Tel Aviv.
We would like to thank all those societies, organisations and individuals who have taken the trouble to set out their views for us.
We would also like to reinforce what we described as the purpose of our discussion Paper. We quote from the Paper:
"The purpose of this Discussion Paper is to provide a basis for informed debate by the amateur community on the issues that are raised. It attempts to identify the relevant issues, provide the background, and offer some possible solutions. It is a discussion paper; and should not be interpreted as expressing any final view of the Committee, or the view of any region or the Administrative Council."
We stress that the Discussion Paper "should not be interpreted as expressing any final view of the Committee, or the view of any region or the Administrative Council." That is true of every tentative conclusion we advanced, even though we may have expressed some of our preliminary views less tentatively than others.
The members of the Committee will not, at this stage of the process we propose, seek to defend or attack any of the tentative conclusions set out in the Discussion Paper. We see our task as facilitating, as best we can, discussion by ensuring that the various issues as we see them or as others see them are considered.
We see our primary role in the next period as listening to others and understanding their views and understanding the reasons for their views.
We now discuss what we see as the most important of the issues raised in the responses to date.
| 2. The definition of the "amateur service": |
We pointed out that the definition has not been significantly changed since the first international regulation of radio, and expressed the view that it remains entirely appropriate today.
We asked:
JM1UXU, SSA (Sweden), RSGB (Great Britain), O.V.S.V. (Austria), WIA (Australia) agreed with our conclusion. However, AMSAT-NA suggest the deletion of the words "interested in radio technique", pointing out that the interests of radio amateurs are far broader than those words suggest.
AMSAT-NA's proposal would amend the definition as follows:
S1.56 Amateur Service: A radiocommunication service for the purpose of self-training, intercommunication and technical investigations carried out by amateurs, that is, by duly authorised personsinterested in radio techniquesolely with a personal aim and without pecuniary interest.
We believe that this proposal deserves further discussion. We ask do those words, in fact or potentially, limit legitimate amateur activities? Or, do they reinforce the reason that the services exist?
| 3. The banned country list: |
We asked:
SSA feel that no change is necessary, O.V.S.V. believe there is no need for the present restriction. One correspondent illustrated the problem presented by the provision by telling of his experience some years ago in Thailand. Overall, more supported our suggestion than opposed it.
| 4. The amateur service as a resource for emergency communications: |
In the Discussion Paper we examined the many international declarations that recognise the value of the amateur service as a resource for emergency communications.
We asked:
JM1UXU, advocates caution in this area, arguing that such activities are not "proper", but rather incidental activities for the service. SSA and JM1UXU both look to Resolution 640 rather than a change to S25.
However, most see the ability to provide emergency communication as important, and a number saw the desirability of a provision facilitating such activity.
Many accepted the different needs in different countries, some lacking the infrastructure of others. This is a matter that does require ongoing consideration.
| 5. Messages on behalf of a third party: |
We do not question the right of an administration to prohibit its amateurs from carrying messages on behalf of a third party. We do believe that any messages so carried must be non commercial and not carried for reward. We question whether or not the attitudes that existed when the international prohibition was included in the Regulations have changed. We also raise the question whether the prohibition is really consistent with the international use of store and forward techniques.
We discussed S25.2 in the context of carrying messages on behalf of a third party. JM1UXU suggests that the prohibition could be removed, or at least special provision inserted to deal with emergency communications, while others took a different view. O.V.S.V. agreed that it should be left to each administration to limit or not limit "third party traffic", so long as it was in accordance with the "main" definition of the amateur service.
Several submissions addressed the phrase "in plain language. The provision reads:
S25.2 (1) When transmissions between amateur stations of different countries are permitted, they shall be made in plain language and shall be limited to messages of a technical nature relating to tests and to remarks of a personal character for which, by reason of their unimportance, recourse to the public telecommunications service is not justified.
A number supported the concept of "plain language". RSGB points out that "plain language" should mean that the details of any coding used must be publicly available, and transmissions that are deliberately encoded to conceal meaning should be the subject of the ban. AMSAT-NA interpret the phrase the same way. RSGB suggest that the restriction should remain, and trying to remove it may cause adverse reaction.
We agree that plain language encompasses any code that is available generally, and that what is prohibited is any encryption intended to conceal meaning.
However, AMSAT-NA point out that the telecommand of amateur space stations must involve the transmission of enciphered messages. They point out that, so far as they are aware, this has never been a problem, but are concerned that it could become a problem in the future, particularly because telecommand stations are located in different countries.
The US regulations make provision for this as follows:
"A telecommand station may transmit special codes intended to obscure the meaning of telecommand messages to the station in space operation."
We ask, is a special exception for the telecommand of space stations in the amateur service necessary? Is that a matter for S25? Or, can the problem be addressed another way?
| 6. The technical and operational qualifications to be an amateur: |
In our Discussion Paper we suggested that the technical and operational qualifications to be an amateur are fundamental to the privileges that are given to the amateur service. We said that the appropriate qualification is essential to distinguish the amateur service from other use of the spectrum. We pointed out that the present Regulations do not set a "standard," but leave that to each administration. If it was considered desirable that some standard be set, we said that we would not suggest an elaborate curriculum, rather the identification of basic topics on which knowledge should be demonstrated.
We asked:
Our concern that the present provisions may not be meaningful was reinforced by the example given to us of the question "What is 'a'?" with response "di-dah" being sufficient to qualify the morse test. SSA prefers the present position which provides flexibility. On the other hand, a number of submissions supported the concept of a minimum identification of topics, not an elaborate syllabus, incorporated by reference.
On the other hand, we did receive suggestions of a quite elaborate and multi level licence structure. We question whether that is the proper role of the international regulations - how can the international regulations define a licensing structure that can meet the different needs of all administrations?
We would like more comment from the developing countries on this issue.
| 7. Morse code: |
We did not question the value of morse code as a means of communication, nor did we question the right of an administration to require its amateurs to demonstrate a skill in morse code. At present, morse code as a qualification is a treaty obligation. We said that we had regard to the fact that we were concerned with obligations that will govern the amateur service in the next century.
We asked:
This issue attracted by far the greatest response, particularly from US amateurs. Very many addressed this issue alone, seeing it as more important, we assume, than what we saw as the prior question of qualification in general terms.
Many opposed our suggestion that the requirement should cease to be treaty obligation, though many did not address the issue in the context of a treaty obligation.
On the other hand, we received some careful arguments in favour of taking the requirement out of the international regulations and leaving it to administrations to determine whether the morse is a licensing requirement for their country.
A number of societies are still considering the matter, and we do not feel that we can take the discussion further at this stage.
We would find it unfortunate if this single issue was allowed to overshadow the many other and we think equally important issues that are raised.
| 8. The international recognition of amateur licences: |
We pointed out that many countries accept a home country driving licence to allow visitors to drive in their country. We asked whether an amateur should be able to visit another country and during that visit be able to use his home country licence? We examined the CEPT arrangements for Europe, and the CITEL arrangements for the Americas. We suggested that Article S25 could include provisions facilitating such use.
We asked:
This suggestion, while supported by some, did not receive the support we expected. For example, SSA sees the difficulties as probably being too great to meet a need that they see as desirable, and others questioned whether it is the role of the ITU to facilitate such matters.
Perhaps it is an issue that particularly concerns Region 3, and, as yet, we have had little input from that part of the world.
| 9. The amateur satellite service: |
We examined the definition of the amateur satellite service, and had a concern that the service is restricted to space stations on "earth satellites". We said that we did not know whether that restriction could present a problem in the future. We also looked at the measures to ensure that amateur satellites do not cause harmful interference.
We asked:
AMSAT-NA supported our concern in respect "earth satellites". The separate definition of the service is supported. Other issues affecting the amateur satellite service are addressed elsewhere in this Report.
| 10. Other matters: |
We asked whether there are other matters that are not included in Article S25 and should be addressed in the Article, or other changes to Article S25 that should be sought?
The issues that have been raised that we did not consider have been included in their appropriate context in this Report.
| 11. General approach: |
It is obvious, we think, that proposals for change should be approached with caution, despite the opportunity that is identified in our terms of reference to examine the international regulations " with a view to formulating the changes, if any, that are desirable to properly reflect the objects, needs, obligations and privileges of the services for the next century, so that the services remain viable and valuable, meaningful and relevant to both the community and to those licensed in the services ... "
Some warn that the revision of Article S25 should be limited to the minimum absolutely necessary, avoiding any attempt to impose obligations on countries. Change for change's sake should be avoided.
An issue has been raised with us in relation to improving the language of S25. There is no doubt that the language could be improved. On the other hand, proposals to change the language of provisions that say, albeit badly, what we want carries its own risk. That is, the risk in an ITU environment, of other and unacceptable change arising from further revision of such a proposal.
We welcome such suggestions, but only on the basis that whether or not such proposals are pursued will depend on a judgement made much closer to the WRC and balancing the value of such change against the risk of making the proposal.
| 12. Conclusion |
While some have very clear views on a number of matters, it is clear that many others, particularly the member societies are still investigating and considering the issues.
It is also the fact that we have not received what we would regard as sufficient (or any) input on some matters. An example is the lack of views from the smaller societies, particularly from the less developed countries, in relation to the question of the international regulations setting the qualification for amateurs.
A number of those communicating with us have asked for proposals to put to their administrations. We believe that is premature. There are, at this stage, divergent views on many of the issues that are raised. The amateur services will only succeed in achieving their objective if the member societies speak with one voice, all taking a common view. That is not possible at this time. For ourselves, we cannot offer any proposals that we would feel confident either represent a view that would be acceptable to the majority of either societies or amateurs, or, indeed, do we feel we could be confident represents a position that we ourselves can say is the best view.
Accordingly, we find that we are not able to make any recommendations at this time other than to recommend that the evolutionary process we have proposed should be allowed to take its course.
We continue to seek the views of individuals, groups and societies, and will be particularly interested in the discussions at the forthcoming regional conferences.
Finally, we repeat the suggestion we made in our Discussion Paper that the approach of each Region should be to formulate their view, but at the same time delegate the task of formulating a global policy to the Administrative Council after the Region 2 Conference in 1998.
The Future of the Amateur Services Committee
Michael Owen, VK3KI, Chair
John Bazley, G3HCT
Tom Atkins, VE3CDM
Terry Carrell, ZL3QL
Larry Price, W4RA
David Sumner, K1ZZ
IARU President Richard Baldwin, W1RU, is an ex officio member of the Committee.
| 13. Further comments |
We welcome further comments. Please communicate to the Committee as follows:
By mail:
By FAX:
By electronic mail:
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