EME/EMR/EMF Compliant or just confused?

Precis

  • The EME requirements which are a formal part of the Radio Licence Conditions are “half baked” and quite simply a “dogs breakfast”.
  • The WIA Website tries to make it simple, but actually makes it worse with an out of date article as they appear confused themselves, including referencing the wrong document.
  • The LCD lays out some conditions that lack definition (inaccessible to the public is one), yet has its technical basis (if you want to clarify) from a commercial document (Standards).
  • ACMA’s Website offers no further clarification (unlike the ARRL site and RSGB sites which provide very clear documents that use common sense)
  • ACMA’s calculator is woefully inadequate in terms of variables and explanations and results differ widely with the U.S. & Great Britain versions. (I assume we are also meeting international standards?)
  • We are now being asked (told) that we are to move to an Apparatus licence as part of a consultation paper that also is proposing that all Amateurs comply with Level 2 compliance Methodology, which requires operating Level 2 stations are required to take measurements and keep records demonstrating compliance with the EME limits in accordance with the ARPANSA Standard.

What Started this trip down the rabbit hole?

After a recent licence upgrade, Transceiver updates, as well as a few new antenna’s installed, I thought it was an appropriate time to revisit the electromagnetic energy requirements which are part of the regulations that apply to amateur radio operators.

Wow, what a mistake that was!!

The first thing you need to do is stop getting EME (Earth-Moon-Earth) and EME (Electro-Magnetic Energy) terms confused.Well it wasn’t me that was getting the terms confused. You search on Google and it the majority of articles being returned are Earth-Moon-Earth articles (a subject that has been using the EME acronym a lot longer). You need to filter out moon and moonbounce on the end of the search terms to minimise the “noise” in your searches. Earth-Moon-Earth (EME) transmissions have been around since the late 1940’s and the term was coined as such. Why they needed to confuse things with using the same acronym, no one knows.

EMR (Electro-magnetic Radiation) would have made more sense – In physics, radiation is the emission or transmission of energy.

Next, we come down to the old chestnut, which are websites that are either out of date and/or making statements without referencing the material that it came from. In this case (but is not limited to), I am being critical of the WIA website with an article was last updated on Dec 2018 (almost 4 years ago at the time of writing). Whilst they have made a reasonable attempt of summarising the “rules”, there are several statements contained in the conditions which need clarification. Like any thorough and analytical Amateur, you would normally access the source documents referenced by the webpage, except there are no original documents referenced, and the only link on the page is to a “unofficial EMR Calc” and the “Amateur LCD of 2015”, which does not contain any of the following words electro-magnetic, EMR, EME or even ARPANSA.

Why is the document linked at bottom of the article?? I have no idea. As a licenced Amateur, I know this document reasonably well, and know exactly where to find the latest copy. I should do, it’s part of the Regulations test. Even though I know the documents, the issue is that the WIA website does not, so it becomes confusing right at the start.

First we need to wade through the confusion of the WIA Website on EMR/EME

Whilst the title in their article is Radiocommunications Licence Conditions (Apparatus Licence) Determination 2015, the document that is linked is Radiocommunications_Licence Conditions_Amateur_Licence_Determination_2015.pdf. Two different documents!!

The actual document I needed was this…..Radiocommunications Licence Conditions (Apparatus Licence) Determination 2015 – F2021C01209 https://www.legislation.gov.au/Details/F2021C01209 – Compilation Date 17th November 2021 (at the time of writing)

This document appears to be where the WIA’s website article has obtained the basis for its document. It’s a shame it wasn’t linked correctly.

Now we have the source document that the WIA website obtained the Level 1 Compliance and Level 2 Compliance details from, which is the Level 1 Criteria and the Level 2 Criteria


So now we have confirmed where the WIA Website has sourced their criteria

I am not trying to make a mountain out of a mole hill, and for the most part, the average VK Amateur Operator will fit into the first part of the Level 1 Criteria (from the ACMA document) which are

Level 1 means

  • The average total power supplied by the transmitter to all antennas fed by the transmitter is not more than 100 W; and
    each antenna fed by the transmitter is installed so that it is inaccessible to a member of the general public; or
  • The bottom of the lowest antenna fed by the transmitter is at least 10 m above ground level; and
    the average total equivalent isotropically radiated power of all antennas fed by the transmitter is not more than 3200 W in any direction; or
  • Is a point-to-point link operating at more than 1 GHz.

The WIA website leaves the 1Ghz criteria out of their webpage summary, but this is an issue with not clearly referencing the documents that the “summary” was taken from and I have to assume and at sometime the document they originally referenced and, extracted details from has changed.

So for the purpose now, whilst not ideal on several fronts, let’s take the ACMA Apparatus document as the criteria that the Amateur Operator needs to measure themselves against to confirm whether they are compliant….

Now we can determine whether we are compliant – possibly not!

Clarification Issue 1 : What is defined as “inaccessible to a member of the general public”?

ACMA’s documentation at least provides an example :

For subparagraph (a)(ii), the following are examples of a type of place that is inaccessible to a member of the general public:

·         the area around an antenna that is fenced and where entry is through a locked gate;

·         the area around a tower where the tower cannot be climbed except by the use of an external aid.

Now the issue comes under Part 3, section 8 with the following statement

8              Power flux density and field strengths

(1)   The RF field produced by a transmitter operated under the licence must not exceed the reference levels for general public exposure at a place accessible to a member of the general public.

They again provide an example

      For subsection (1), the following are examples of a type of place that is accessible to a member of the general public:

·         a private residence;

·         a public park;

·         a building roof‑top with a transmitter antenna located on the roof‑top, where access is not restricted by the site manager or operator.

So the issue that comes up is that a Private Residence (my house as an example) is regarded as an area that is accessible to a member of the general public per the last section quoted, yet it states that “the area around an antenna that is fenced and where entry is through a locked gate: is regarded as a “type of place that is inaccessible to a member of the public”. My yard (in which my multiple antennas are fully enclosed within), has a locked gate to limiting who is able to get into the back yard. The issue I have is that anyone can jump the fence, far easier than climbing a 10m tower, and the next issue is that I or my family may have visitors enter the house, are my antenna’s now regarded as accessible to members of the general public.

This needs to be certainty on what is regarded as accessible and in-accessible to the public

Clarification Issue 2 : The term “average total power supplied by the transmitter to all antennas”

Interesting term, I decided to google it, and only when I added RF on the end of it, did I come up with a search match and it appears to be a term bandied around relating to EMF and standards, but no real world explanation. ACMA already use the terms Px (Peak) Py (MeanPz (Carrier) as part of their legislation documents, why add another term that is not widely used or described?

Furthermore, if I try and translate this back to the EME Calculator, I am left wondering whether I take into account, loss in the feed cable, work on a tranmission/receive duty cycle (which is what other countries appear to do), taking into consideration whether I am using digital modes, CW, SSB…..there is no real information on the ACMA calculator.

The Battle of the EMR Calculators

I have located the EMR Calculator provided by ACMA, and to their credit, they refer to it as a “simple calculator” and needless to say it is simple. Three “broad” variables to be entered, and it will supposedly spit out the minimum distance (or exclusion area from the Antenna in metres).

The issues I immediately came across were the following

  • Only specifies between 10Mhz and 300Ghz – no explanation of why 0-10mhz is not included
  • No clear indication of what the power measurement relates to…is it average power
  • It’s so simple it assumes the transmitter runs at 100 per cent power
  • It is simple, and missing information, the confidence level it provides that you meet the legislative requirements of the Electromagnetic radiation requirements that pertains to the conditions under which the licence was issued, is not there.
  • If I just go ahead and assume, this is not something I can take into a legal argument, let alone a courtroom.
  • Now what’s worse, I want to delve further and work out what rules the ACMA calculator are based on and to provide that confidence, I find the document I need to reference is an Australian Standards document which I either a) have to pay a reasonable sum to obtain a copy or b) go to the ACMA’s office to review a copy in their office. I have never come across Legislation that has it’s workings in a commercial/technical document that I need to pay for (possibly only to look at for a couple of lines).

As you can see above, the ACMA calculator is very simple spreadsheet

I will admit, some of my concerns and questions have arisen after I looked at ARRL’s (U.S.) and OFCOM’s (Great Britain) calculators as they made sense, they explained the figures you were entering. The ARRL’s is a lot simpler than the RSGB, but at least both appeared to have enough information to base an answer on.

ARRL’s calculator

RSGB’s Calculator

As you can imagine, each one gives out a different result. However the RSGB and the ARRL give answers that appear reasonable, where as the ACMA calculator gives out an answer that is 3 times the distance.

I appreciate that each country has its own agency, however my understanding is that they are using international standards (unless Australians are more susceptible to radiation than the US or GB)

With the result from the ACMA Calculator, it gets worse as you go up in power, e.g. 400W and should it ever be granted, 1KW, it is highly likely that many will not comply, not without having large back yards allowing for. large distances between the fence and the Antenna. Especially in the modern world, having a clear 14m behind the house, and 14m from side to side is not that common if you are running 400w.

Finally, the WIA points you to a calculator created by VK3UM (SK) which is a nice calculator, and some real time and effort went into it, but whether the calculations I take from it will stand up in a legal argument, especially as I cannot confirm what “Standards” it was based on, and even his own disclaimer states that his tool is only as accurate as the methods prescribed in the respective standards.ACMA make no reference except to their calculator, but fail to clarify other meanings such as publicly inaccessible.

From what I can see, ACMA’s calculator even it admits its shortfalls, which includes not taking into account the antenna pattern, and other environmental factors and assumes that you are running at 100% power 100% of the time. Yep, that sounds like a typical Amateur (tongue in cheek if you haven’t worked out that comment). It appears that they are working on absolute worst case, but that could make the difference between being able to take part in the hobby, or tossing it all in, especially if you need to downsize as you no longer have the excessive clearances that the ACMA calculator requires.

The move (push) to an Class licence

Personally I don’t have any concerns with moving to a class licence (and your view may differ, which is appreciated, and mine could change), but as part of this move ACMA is drafting a class licence with EME requirements for Amateurs to be consistent with other class licences. I am not saying that this is a bad idea as everyone has to play their part in the enviroment, safety, personal health, and the health of others, so no aversion there, however where it requires reasonable additional costs (just to obtain the standards), a large amount of time to work out whether I am compliant or not (my end of year tax returns take less time and I have much more confidence in them), and legally (as we are dealing with Legislation) I don’t know where I stand.

This is a perfect time to get some clarification on several items, and should be used before this document becomes legislation

HOWEVER to confuse matters even more the following statement was taken from their published consultation paper “In practical terms, our proposed EME condition would require ALL amateur stations to comply with the Level 2 stations compliance methodology”

That last line is a doozy….this requires you as a level 2 compliant station (as per the current Appartus Licence Determination) to

General requirement to measure or calculate RF fields

The licensee must measure or calculate the RF fields produced by the transmitter in accordance with one of:

  • if AS/NZS 2772.2 applies in relation to the transmitter – AS/NZS 2772.2;
  • if C95.3 applies in relation to the transmitter – C95.3;
  • if IEC 62232 applies in relation to the transmitter – IEC 62232;
  • if IEC 62577 applies in relation to the transmitter – IEC 62577.

 The licensee must keep a record of measurements or calculations made under this subsection (see paragraph 15(1)(e)).

You are going to need deep pockets to obtain the Standards quoted above (at least the ones that pertain to your transmitter).

If there is no decent calculator available, you are going to need to obtain or borrow the equipment to measure your RF Fields.

And this apply to any time you make a change to your transmitter, transmitter specifications, antenna specifications, feedline specifications

So that simple statement of “In practical terms, our proposed EME condition would require ALL amateur stations to comply with the Level 2 stations compliance methodology” is going to cost unless it is simplified by ACMA with the use of a more comprehensive, accurate calculator, that can be used for official station records. I have no issue when making a change to recalculate with new variables, confirm that I am still compliant or make the changes (usually distance) to make myself compliant. I would then print off a report and file it or hang it in a frame for each configuration.

If you take a look at the RSGB Calculator, it is comprehensive, it allows you to create reports for each of your configurations, allows you to save electronic copies and save to PDF. This meets the Level 2 requirements which are to measure or calculate RF Fields

Whether it meets or calculates in accordance with AS/NZS 2772.2 or C95.3 or IEC 62232 or IEC 62577, no one knows as the ACMA Calculator provides no supporting documentation, and as mentioned the fact that it only says 10Mhz and upwards leaves doubt.

Clarifying Documents

One thing that ARRL and RSGB have done well to support their Amateurs is by providing (on their respective websites, documents providing further clarification), and they have done it well.

In fact in the couple of months whilst writing this article, RSGB have created a further document which is very readable

http://rsgb.org/main/files/2022/10/RSGB-EMF-Guidance-EMF-2-v2-.pdf

And the ARRL just does it well with their clear explanation

http://arrl.org/fcc-rf-exposure-regulations-the-station-evaluation

Including this little gem (which explains how their calculations come about)

http://arrl.org/files/file/Technology/RFsafetyCommittee/OET65B.pdf

Someone needs to own this, whether it is ACMA or the WIA and produce a document that makes it much clearer than what it is now. I am not stupid, I don’t have an OCD, I read technical documents all day, I regularly read business contracts, and I read local emergency legislation (not knowing an understanding it will leave me in hot water). Now if I am having troubles reading, translating, and making sure I am compliant, I would say that 50% of the hams out there are in a simlar boat (or maybe I made the mistake of looking too deeply)

Summary

These standards are being reinforced (and changed) as a condition of holding an Amateur licence as we move to a Class Licence. Furthermore these apply to visiting operators as well. Many will not bother if they do not have a clear/quick way to confirm their compliance.

If you believe this is just “a storm in a tea cup”, just take a look at this blog https://rsgb.org/main/blog/publications/the-last-word/2021/05/19/the-last-word-emf/. I actually only found it whilst writing this summary paragraph and final review, but it clearly shows many of the same concerns with EMF conditions (and I suspect it led to the RSGB clarification document mentioned previously)

These standards have been in place for many years now, (FCC first introduced regulations in 1996) but Australia’s legislation looks like a dog’s breakfast. I enjoy the amateur radio hobby, I enjoy the privileges and want to remain compliant, but I am concerned that this is still half baked and being forced on the Amateur Operator in the guise of a Consultation paper for the Apparatus Licence migration.

So finally to close of this article, the recommendations are as such

What we need is:

It’s not asking that much, but it will allow VK Amateur operators to meet their legislative requirements, without undue costs and stress, and could make the difference in Amateur operators embracing the process and taking a real interest in it. Amateur operators are already to a large part, self policing, provided they have the rules in black and white and there are not undue costs in meeting those rules.

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