LF: VLF Earth Mode does NOT need an NoV - official at last

[Roger Lapthorn <rogerlapthorn@gmail.com>]

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 frequencies 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’m 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 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.

 

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); “Notwithstanding 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 Undue Interference to any wireless telegraphy”.

 

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 the 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
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