W I A Federal
The Wireless Institute of Australia
A.C.N. 004 920 745
National Society of Radio Amateurs
(A Company Limited by Guarantee)
PO Box 2175, Caulfield Junction, VIC, 3161
(10/229 Balaclava Rd., North Caulfield 3161)
Phone (03) 9528 5962 Fax (03) 9523 8191
Submission for the Reallocation of 45 - 52 MHz
The WIA notes that Band 1 television services will cease operation on 9 September 2008, and that the spectrum presently occupied by TV channels 0, 1 and 2 will be withdrawn from the Broadcasting Service and reallocated to other services.
We assume that planning of the new allocations will begin in the reasonably near future. Therefore we wish to place on record our formal submission for the return of the band 50 - 52 MHz to the Amateur Service, under the same licence conditions that apply at present to the 52 - 54 MHz band.
In support of this request, we offer the following comments:
1 . With the exception of the current Australian footnote, the entire 50 - 54 MHz band is listed as exclusive amateur spectrum in the ITU frequency allocation tables for Regions 11 and Ill. In Region 1, Band 1 television is also being phased out and most countries now have a 50 MHz amateur band. This amateur band has therefore become an internationally standard allocation, and the interests of international harmonisation would be best served by restoring the full 50 - 54 MHz amateur allocation in Australia.
2. The 50 MHz band is important to the Amateur Service because it provides unique opportunities for propagation experiments. During the last solar cycle, Australian amateurs have been able to communicate with their counterparts throughout the world. All long distance communication in this band takes place in the low end just above 50 MHz, and it is important for Australian amateurs to have full access to the same frequencies that are used for this purpose in other countries.
3. We assume that when the 50 - 52 MHz band is reallocated, the new allocation will apply throughout Australia. For some years the full 50 - 54 MHz band has been available without restriction to amateurs in SA, WA, the NT and in overseas territories. It is logical to extend this allocation to the eastern states when the channel 0 allocation is withdrawn. To do otherwise would mean a significant loss of privileges for amateurs living outside the eastern states.
4. Considering that the closure of analog TV transmissions will free up 21 MHz of spectrum (45 - 52 and 56 - 70 MHz), the WIA feels that reallocation of 50 - 52 MHz to exclusive amateur use would not lead to any problems of spectrum scarcity for other services.
5. We are aware of proposals some years ago from ethnic organisations for the reallocation of channel 0 as an ethnic narrowcasting band. We do not know whether this is still a live issue, but we would like to comment on it.
First we would reiterate our request that the 50 - 52 MHz band not be allocated to any user other than the Amateur Service.
We would also suggest the likelihood of problems with receiver desensing and mutual interference if narrowest stations were operating just below 50 MHz, where amateur stations would be using powers up to 400 watts and trying to receive weak signals.
If it is decided to allocate a portion of Band 1 spectrum for ethnic narrowcasting, we feel that frequencies above 56 MHz would serve the purpose much better.
6. Related to the above, the WIA would also ask that spectrum close to 50 MHz should not be allocated to other high power services. An example of the problems that can occur is receiver desensing and direct interference to weak signal reception caused by a weather radar operating on 49 MHz in the Darwin area.
7 In conclusion, the WIA formally requests the following:
(a) That when the revised Australian Spectrum Plan takes effect in 2008, the band 50 - 54 MHz be allocated to the exclusive use of the Amateur Service;
(b) That the band 45 - 50 MHz not be allocated for any other kind of broadcasting or narroweasting service; and
(c) That if possible, at least several MHz below
50 MHz be kept clear of any high power services.
WIA Federal President
March 20, 2000