A dialogue with OFCOM

At last, and only 3 months late, OFCOM have renewed my NoV for 8.7-9.1kHz VLF operation.

Currently I am "in negotiation" with OFCOM on another matter mentioned a few days ago.

In the next few months I want to do some QRPp radiated tests with the earth-electrode antennas at some frequencies between 9kHz and 137kHz. Ideally this would be around 35-45kHz and 70-80kHz, where I can find a quiet spot without any activity from primary users like the Ministry of Defence.  With QRSS, continuous carrier or WSPR and with an EIRP of around 10uW it should be interesting. Tests on 137kHz suggest this power is enough to see a radiated signal out to at least 25km locally with an E-field probe on the car, which would allow me to check coverage and polar plot. On the lower frequencies this may be limited to just 5-10km, but that would be OK.

But, OFCOM say they will not grant me licence-exempt permission to operate in this part of the spectrum, even at the miniscule powers and bandwidth (uWs and a few Hz).

They say they would HAVE to consult with the primary users and this would take months. They suggest instead I apply for a Non Operational (Test and Development) Licence, but does that not need primary user approval too?  Problem is this licence costs £50 a year, which sounds like total overkill when the risk of me interfering with anyone is about as likely as me winning the lottery or landing on the moon when I jump.

Now, I could just go ahead and do the tests anyway knowing I will not cause anyone a problem.  Really this is not the way it should be and anyway I'd like to publish the results later. Hardly possible if I don't do things with OFCOM's approval.  I am hoping that the good people at OFCOM will see that this is worthwhile amateur research, it won't cause ANY issues and they will soon say, "go ahead on the strict understanding that if you cause any harmful interference to primary users you close down immediately, but at that power, no licence needed."   I have written back to OFCOM again this evening making this case and we'll what transpires. I also suggested issuing me a one-off NoV, but they say they won't!

Many of you will be saying, "why not just do it". If the powers that be really cannot see sense, then maybe I may have no other option.

OFCOM licence exemption

Martin G8JNJ has brought to my attention a little known, to me at least, OFCOM concession that appears to allow licence exempt operation under certain conditions in many, if not all, parts of the radio spectrum for research and development purposes.

Although OFCOM will grant Non Operational Licences (these were once known as Test and Development Licences) and charge you £50 a year for the privilege (!)  to test new equipment or carry out specific research, they do NOT require a licence if emissions measured at a specified distance are below certain levels (supressed radiation conditions). See http://licensing.ofcom.org.uk/binaries/spectrum/non-operational-tech-licence/ofw357nonopguide.pdf for some guidance notes on this.

My own interest is to research earth-electrode antennas in the frequency range between 8.97kHz (where I already have done some tests) and 137kHz (where I have also tested this antenna structure). Using WSPR and other weak signal techniques, quite a lot of useful work can be done with low uW EIRP levels. It would be interesting to see how such an antenna structure behaves at say, ~40kHz and 73kHz. It may just be possible to do tests at moderate ranges (in the far field) without a licence. Now wouldn't that be interesting?