Return-Path: Received: from mtain-dj04.r1000.mx.aol.com (mtain-dj04.r1000.mail.aol.com [172.19.187.140]) by air-dc08.mail.aol.com (v129.4) with ESMTP id MAILINDC082-862c4d35ae1111a; Tue, 18 Jan 2011 10:13:21 -0500 Received: from post.thorcom.com (post.thorcom.com [195.171.43.25]) by mtain-dj04.r1000.mx.aol.com (Internet Inbound) with ESMTP id 86E52380000B3; Tue, 18 Jan 2011 10:13:19 -0500 (EST) Received: from majordom by post.thorcom.com with local (Exim 4.14) id 1PfDDy-0001ba-Qq for rs_out_1@blacksheep.org; Tue, 18 Jan 2011 15:11:58 +0000 Received: from [195.171.43.32] (helo=relay1.thorcom.net) by post.thorcom.com with esmtp (Exim 4.14) id 1PfDDy-0001bR-6y for rsgb_lf_group@blacksheep.org; Tue, 18 Jan 2011 15:11:58 +0000 Received: from mail-iw0-f171.google.com ([209.85.214.171]) by relay1.thorcom.net with esmtp (Exim 4.63) (envelope-from ) id 1PfDDv-0003WN-HG for rsgb_lf_group@blacksheep.org; Tue, 18 Jan 2011 15:11:58 +0000 Received: by iwn2 with SMTP id 2so6008093iwn.16 for ; Tue, 18 Jan 2011 07:11:54 -0800 (PST) DKIM-Signature: v=1; a=rsa-sha256; c=relaxed/relaxed; d=gmail.com; s=gamma; h=domainkey-signature:mime-version:date:message-id:subject:from:to :content-type; bh=zU6iu8YhBCZmdY6NAoRkECWAogX0VNAjWT9C2PuBRNY=; b=k+Bn+hVV0sjvSXME4WZRXqw5ZgNXbZhPDOo9eiwvuPaOPi+mbRVjf5uWUsJj6xKGLC gLXLjpMOzmUGhFP1/Wj/Pr0C5X5c58vPscC3Wnphh7Jz4kTwdRq2EnO3sZfMtc3DXK5g DZ1glW2NFKJ+2dioZX1dTIXfNdLFiX6uzm4yk= DomainKey-Signature: a=rsa-sha1; c=nofws; d=gmail.com; s=gamma; h=mime-version:date:message-id:subject:from:to:content-type; b=r2v4LuRAu8+KqUT6/RsB/Bawvgj6h1OOmc8W4dgvo0LgQvOOS6N/QhG4nHLnFh57mA RZj9o13f4H0zuQ5yI8kHDXN0UKrBGUhAkSyd8vJoDZ2UKGP0gP3+XDkKuEDBhh2Je6fw 5QzSQ4rygttAQatX4ktVb+YYVAlu6QoFS4vTU= MIME-Version: 1.0 Received: by 10.42.165.5 with SMTP id i5mr6407356icy.501.1295363514515; Tue, 18 Jan 2011 07:11:54 -0800 (PST) Received: by 10.42.241.133 with HTTP; Tue, 18 Jan 2011 07:11:54 -0800 (PST) Date: Tue, 18 Jan 2011 15:11:54 +0000 Message-ID: From: Roger Lapthorn To: rsgb_lf_group@blacksheep.org, G6ALB , sub9khz@yahoogroups.com DomainKey-Status: good (testing) X-Spam-Score: 0.3 (/) X-Spam-Report: autolearn=disabled,HTML_IMAGE_RATIO_02=0.192,HTML_MESSAGE=0.001,HTML_TAG_EXIST_TBODY=0.126 Subject: LF: VLF Earth Mode does NOT need an NoV - official at last Content-Type: multipart/alternative; boundary=90e6ba6e8652233f53049a20527c X-Spam-Checker-Version: SpamAssassin 2.63 (2004-01-11) on post.thorcom.com X-Spam-Level: X-Spam-Status: No, hits=0.3 required=5.0 tests=HTML_50_60,HTML_MESSAGE, HTML_TAG_EXISTS_TBODY autolearn=no version=2.63 X-SA-Exim-Scanned: Yes Sender: owner-rsgb_lf_group@blacksheep.org Precedence: bulk Reply-To: rsgb_lf_group@blacksheep.org X-Listname: rsgb_lf_group X-SA-Exim-Rcpt-To: rs_out_1@blacksheep.org X-SA-Exim-Scanned: No; SAEximRunCond expanded to false x-aol-global-disposition: G X-AOL-SCOLL-AUTHENTICATION: mail_rly_antispam_dkim-m245.1 ; domain : gmail.com DKIM : fail x-aol-sid: 3039cdbc9d084d35ae0f6466 X-AOL-IP: 195.171.43.25 X-Mailer: Unknown (No Version) --90e6ba6e8652233f53049a20527c Content-Type: text/plain; charset=windows-1252 Content-Transfer-Encoding: quoted-printable Today I received this letter from OFCOM, which clarifies the legality of operating so called "earth mode" (conduction/induction via the ground) experiments at frequencies below 9kHz in the UK. Note the sentence in Paul= 's letter saying, "*We would not normally issue NoVs for communications using non-wireless telegraphy apparatus/stations i.e. where you rely only on conducted emissions and where there are no intentional radiated emissions.= ** "**. * Wanting to check earth mode propagation behaviour at a series of frequenci= es *below* 9kHz to see how results compared (earlier tests at 0.838kHz seemed around 10dB better than at 8.76kHz), I asked OFCOM if I needed an NoV extension to be legal. One could also argue that such tests at frequencies= * above* 9kHz would also be legal as long as it does not cause any "Undue Interference to any wireless telegraphy" and one was not intending to radiate. This sounds a wholly pragmatic answer from a government body. Roger, > > > > Rod Wilkinson has now left Ofcom , so I=92m responding to your query. > > > > You should seek you own legal advice as Ofcom is unable to give legal > advice, however, we would issue NoVs, where appropriate, for wireless > telegraphy apparatus/stations. > > > > In the case of the 9 kHz band NoV we currently stipulate the frequency= band > only around 9 kHz as discussed with the Met Office and we do not intend= to > issue NoVs for lower frequencies in the band. We would not normally issu= e > NoVs for communications using non-wireless telegraphy apparatus/stations > i.e. where you rely only on conducted emissions and where there are no > intentional radiated emissions. * > * > > > > I would also draw your attention to other relevant legislation (e.g. > Wireless Telegraphy Act 2006) and the Terms of the Amateur Licence and= in > particular to clause 7(3); *=93Notwithstanding any other terms of this > Licence, the Licensee shall ensure that the Radio Equipment is designed, > constructed, maintained and used so that its use does not cause any Undu= e > Interference to any wireless telegraphy=94.* > > * * > > I am also copying in Ash Gohil in the Ofcom Licensing Centre who is in= the > team that Rod worked in. Please address any further queries to him in th= e > first instance. > > * * > > I hope this helps. > > * * > > Kind regards, > > > > Paul > > > > *:: Paul Fonseka** > *Spectrum Policy Group-Business Radio > +44 (0) 20 7981 3116 > *paul.fonseka@ofcom.org.uk* > Hope this is of interest. 73s Roger G3XBM --=20 g3xbm-qrp.blogspot.com/ www.g3xbm.co.uk www.youtube.com/user/g3xbm G3XBM GQRP 1678 ISWL G11088 <#> <#> <#> <#> --90e6ba6e8652233f53049a20527c Content-Type: text/html; charset=windows-1252 Content-Transfer-Encoding: quoted-printable Today I received this letter from OFCOM, which clarifies= the legality of operating so called "earth mode" (conduction/in= duction via the ground) experiments at frequencies below 9kHz in the UK.= Note the sentence in Paul's letter saying, "We would not normally issue NoVs for communications= using non-wireless=20 telegraphy apparatus/stations i.e. =A0where you rely only on conducted=20 emissions and where there are no intentional radiated emissions.".

Wanting to check earth mode propagation= behaviour at a series of frequencies below 9kHz to see how results= compared (earlier tests at 0.838kHz seemed around 10dB better than at 8.7= 6kHz), I asked OFCOM if I needed an NoV extension to be legal. One could= also argue that such tests at frequencies above 9kHz would also be= legal as long as it does not cause any "Undue Inter= ference to any wireless telegraphy" and one was not intending to radi= ate.

This sounds a wholly pragmatic answer from a government body.

Roger,

=A0

Rod Wilkinson has now left Ofcom , so I=92m responding to your query.

=A0

You should seek you own legal advice as Of= com is unable to give legal advice, however, we would issue NoVs, where ap= propriate, for wireless telegraphy apparatus/stations.

=A0

In the case of the 9 kHz band NoV we currently stipulate the frequency=20 band only around 9 kHz as discussed with the Met Office and we do not intend to issue NoVs for lower frequencies in the band.=20 We would not normally issue NoVs for communications using non-wireless=20 telegraphy apparatus/stations i.e. =A0where you rely only on conducted=20 emissions and where there are no intentional radiated emissions.

= =A0

I would also draw yo= ur attention to other relevant legislation (e.g. Wireless Telegraphy Act= 2006) and the Terms of the Amateur Licence and in particular to clause 7(3); =93Notwithstanding any other terms of this Licence, the Licensee shall ensure that the=20 Radio Equipment is designed, constructed, maintained and used so that=20 its use does not cause any Undue Interference to any wireless telegraphy=94.

=A0

I am also copying in Ash Gohil in the Ofco= m Licensing Centre who is in the team that Rod worked in. Please address= any further queries to him in the first instance.

=A0

I hope this helps.

= =A0

Kind regards,

=A0

Paul

=A0

:: Paul Fonseka
Spectrum Policy Group-Business Radio
+44 (0) 20 7981 3116
paul.fonseka@ofc= om.org.uk


Hope this is of interest.

73s
Roger G3XBM
--
g3xbm-qrp.blogspot.c= om/
www.g3xbm.= co.uk
www.youtub= e.com/user/g3xbm
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