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Author Topic: UK letter from ofcom regarding ICNIPR proposed licence changes  (Read 319 times)

G3ZHI

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UK letter from ofcom regarding ICNIPR proposed licence changes

Dear Licence Holder,

We are writing to make you aware of some important changes that we are proposing to make to your Wireless Telegraphy Act licence(s) issued by Ofcom.

In February and October last year, we issued two public consultations on our proposal to formally require licensees to comply with the internationally agreed levels in the International Commission on Non-Ionizing Radiation Protection (ICNIRP) Guidelines for the protection of the general public from electromagnetic fields (EMF). We refer to these levels as the ICNIRP general public limits. In October, we also issued a Statement setting out our decision to formally require licensees to comply with the ICNIRP general public limits and we recently published an update on how we propose to implement that decision. 

We are now writing to you to inform you of our proposal to vary the terms and conditions of your licence(s) to require you to comply with the ICNIRP general public limits. In accordance with the Wireless Telegraphy Act and your licence(s), we are giving you notice of our proposal by publishing a General Notice on our website.

We’ve put all the relevant information about our proposal including the General Notice on a dedicated EMF webpage ofcom.org.uk/emf. Here you will find details of the licence variation process alongside the background to the changes and lots of FAQs to help you understand what our proposal means for you.

If, after reading the above information, you wish to make a representation to Ofcom in relation to our proposal to vary your licence(s), you have up until the 18 April 2021 to do so. However, if you do not wish to make a representation you do not need to take any action at this time. More information on the representation process can be found by visiting the Ofcom EMF webpage.

We will consider all representations before coming to a final decision on the variation of your licence(s). We will publish our final decision on the EMF page of our website by 18 May 2021. We will explain whether we have decided to vary your licence(s) to include the EMF condition. If your licence(s) has been varied we will send you an update of it or information on where a new version can be obtained from.

In future we intend to make greater use of General Notices published on our website and may not individually contact you to inform you that we have published one. We would therefore urge all licensees to regularly check the Ofcom website or subscribe to email spectrum updates by going to the following page on our website ofcom.org.uk/about-ofcom/latest/email-updates.

If you have any questions about this change and what it means for you, further information can be found on the dedicated EMF webpage using the address provided above.

Yours faithfully,

Ofcom
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W9IQ

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Re: UK letter from ofcom regarding ICNIPR proposed licence changes
« Reply #1 on: March 03, 2021, 08:04:19 AM »

Make certain to take advantage of the allowed 6 minute averaging rule when you do your calculations!

- Glenn W9IQ
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- Glenn W9IQ

God runs electromagnetics on Monday, Wednesday and Friday by the wave theory and the devil runs it on Tuesday, Thursday and Saturday by the Quantum theory.

G4AON

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Re: UK letter from ofcom regarding ICNIPR proposed licence changes
« Reply #2 on: March 03, 2021, 11:38:27 AM »

Make certain to take advantage of the allowed 6 minute averaging rule when you do your calculations!

- Glenn W9IQ
The current OFCOM spreadsheet is only for frequencies above 10MHz, below 10MHz the likely requirement is based on peak power.

The problem will be separation distances on lower frequencies with antennas that are close to property boundaries, for example an inverted V antenna for 80m, or an end fed wire close to the ground. These antennas will produce strong near fields that are hard to estimate.

Interesting times.

73 Dave
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KF5LJW

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Re: UK letter from ofcom regarding ICNIPR proposed licence changes
« Reply #3 on: March 03, 2021, 12:41:02 PM »

Make certain to take advantage of the allowed 6 minute averaging rule when you do your calculations!

- Glenn W9IQ
Glen I know you mean well and no disrespect, but that is above most hams pay grade, and for those that understand could care less. Not like any amateur would wear a NARDA RF monitor when operating.     
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VR2AX

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Re: UK letter from ofcom regarding ICNIPR proposed licence changes
« Reply #4 on: March 04, 2021, 09:26:32 AM »

There is a technical article in RadCom for March 2021 about this. It implies this is all being done in 'cooperation' with the ARRL.

The fact the deadline for representations is 18 April 2021, and the stated date for FINAL decision is before 18 May 2021, tells the reader all they wish to know!
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W4MSL

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Re: UK letter from ofcom regarding ICNIPR proposed licence changes
« Reply #5 on: March 05, 2021, 10:43:53 AM »

I got the same notification email from Ofcom, followed the links, and was bewildered by what I read. Although this is unlikely to affect me directly (I'm licensed in the UK, but have not resided there in over a decade, and am unlikely to do so again), I was curious as to the intended and likely impact of the "proposed" changes. They would appear to impose a significant regulatory burden both in terms of testing, compliance and documentation. All in the name of "safety," which can be a means for the restriction of something-- anything--for any reason, related to actual safety concerns or otherwise. Perhaps this is over-reading things, as I really don't know what practical difference the changes will make for UK-based hams. But Ofcom's language, "proposals to vary a wide range of licences to require licensees to comply with the ICNIRP general public limits and keep records to demonstrate how they comply" is not reassuring. I cannot see how this will do anything to encourage ham activity in the UK, and can easily imagine it having the opposite effect.

It would be appreciated if the OP or other UK-based hams might comment on the anticipated effects upon a "Full" license ham in the UK. It's a short hop across the pond, you know, and the inclination of bureacracies to "keep pace" with one another is hardly unknown, so the eventual indirect impact for non-UK hams could be significant.
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G8FXC

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Re: UK letter from ofcom regarding ICNIPR proposed licence changes
« Reply #6 on: March 05, 2021, 11:12:44 AM »

Having played with the evaluation spreadsheet, I think the impact here will be fairly small - due to the fact that we are limited to 400W and, in practice, most actually run 100W. The separation distances seem to come down to a few metres - which most of us should be able to accommodate. I guess that it may discourage vertical antennae - I was on the point of putting one in the corner of my garden, but that would make its separation distance extend well into my neighbour's property and a public highway. I'll have to stick with my undersize dipole instead - the height off the ground will pretty much satisfy the separation distance.

All of this is, of course, dependent on my running 100W - if comparable rules were introduced in the US, I guess a lot of people running 1kW or more
would be hard pressed to comply.

Martin (G8FXC)
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W1VT

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Re: UK letter from ofcom regarding ICNIPR proposed licence changes
« Reply #7 on: March 05, 2021, 11:30:51 AM »

I know someone who got in trouble putting a vertical in front of a neighbor's kitchen window.  There was a complaint made by the neighbor to town hall  and  he had to get an expensive permit to keep it.  The rest of the story is that he had other antennas installed but putting the one in front of the kitchen window "crossed a line."  He complained about having to pay the permit fee.
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W4MSL

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Re: UK letter from ofcom regarding ICNIPR proposed licence changes
« Reply #8 on: March 05, 2021, 01:20:52 PM »

Having played with the evaluation spreadsheet, I think the impact here will be fairly small - due to the fact that we are limited to 400W...
Martin (G8FXC)

Martin,

Thanks for the reply. So, you do not anticipate a heavy documentation requirement? Or little different than already imposed there? I've personally experienced concrete examples of such in other fields where the time required to document a procedure took longer than the procedure itself. A "tax," if you will, which had the effect--inadvertent or otherwise--of suppressing the behavior under scrutiny.
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W9IQ

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Re: UK letter from ofcom regarding ICNIPR proposed licence changes
« Reply #9 on: March 06, 2021, 03:32:59 AM »

The FCC has long had the requirement that hams conduct an RF exposure assessment, the results of which must be part of the station records.

What the OFCOM spreadsheet does not do is assist with the 6 minute averaging calculation. Averaging, combined with the 400 watt limit, will largely mitigate any significant impact on the community.

- Glenn W9IQ
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- Glenn W9IQ

God runs electromagnetics on Monday, Wednesday and Friday by the wave theory and the devil runs it on Tuesday, Thursday and Saturday by the Quantum theory.
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