South African Radio League response to Government Gazette 38301 of8 December 2014

Section 21 Amateur Radio Communication

(2) (b) insert after HAREC (Harmonised Amateur Radio Certificate), insert after issued “by the South African Radio League after having successfully passed the amateur radio class A examination”

Motivation: To clarify who issues HAREC in South Africa

(4) While the South African Radio League is in agreement with the concept that a class B license is a novice license, after consultation with the amateur radio community, we recommend that clause 4 be deleted.

Motivation:While the SARL understands that after passing the Class B Amateur Radio Examination, the license is issue by ICASA at their discretion, the SARL is of the opinion that once a person is granted a licence it should not be revoked unless the person transgresses a regulation.

(9) The South African Radio League recommends that clause (9) is deleted as it serves no practical purpose. Also see our comments on clause (33)

(16) The South African Radio League proposes that the following is added after a log book “or an electronic record,”

Motivation: Most amateurs keep electronic records and are nolonger using physical paper logbooks.

Clauses (18) add the word amateur after national i.enational amateur radio frequency plan etc……..

27 Allocation and display of callsign

The South African Radio League recommends that after “said radio set by the licensee” the following be inserted, “except in the case of an amateur radio licensee when the callsign need only be displayed once in the area where the equipment is situated, and the callsign must be transmitted etc,………”

29 The South African Radio League recommends that the following be deleted: “and local municipality”

(2) Delete clause

Motivation: The South African Radio League is of the opinion that this is not a matter that ICASA should be involved in as the said clause refers to the height of the antenna tower or mast and not the design of the actual antenna. ICASA has no jurisdiction over antenna structures

(33) The South African Radio League recommends that this clause is deleted in its entirety

Motivation: While the proposed clause does not affect members of the South African Radio League, it does affect non-members.

Internationally the possession of radio receiving equipment with continuous tuning is not regulated as with modern technology most receivers are capable of continuous tuning. The issue is dealt with by regulations that specify that transmissions may only occur on frequencies for which the person is licensed.

Annexure I

Amateur radio frequency bands

The SARL proposes the title be changed to National amateur radio frequency plan.

Motivation: To align with references to section I as the national amateur radio frequency plan

Additional allocation

In discussion with ICASA over the past few years the South African Radio League requested that the 160 metre band allocation be increased to fall in line with region 1 allocations namely 1.810 – 2.000 MHz. Propagation on these frequencies is being studied, and for South Africa to make a meaningful contribution, amateurs should be able to communicate with other amateurs who operate on various frequencies above 1.810 MHz. There was agreement and a recommendation would be prepared for consideration by the ICASA Council. It would be opportune to make the change in the revised regulations.

Increase in output power

In line with other HF bands, where appropriate, it is recommended by the South African Radio League that power for Class A Licensee be standardised to 30 dBW

3.500 – 3.800 MHz A = 30dBW

Increase in Output power on VHF and UHF Frequencies. The South African Radio League recommends the following changes

50- 54 MHz 50-52 MHz = 30 dBW

53 – 54 MHz = 26 dBw

144 – 146 MHzA = 30 dBW

1240 – 1300 MHzA= 30 dBW

1260 – 1270 MHzA= 30 dBw This subsection could be deleted as it is a part-duplication of the above 1240 - 1300 assignment

2300- 2450 MHzA= 30 dBW

5650 – 5850 MHzA= 30dBW

Motivation

Radio Amateurs, by nature of their license are experimenters and are engaged in experimental transmissions using, amongst others, transequatorial propagation, sporadic E propagation and EME ( Earth Moon Earth communication bouncing signals off the moon) which require higher power and large antenna structures. By increasing the allowable output power to 33 dBW would enable South Africans to compete with the world.

(see additional technical motivation)