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BEagle · 31st August 2008, 08:37

Well, here's what I sent to Ofcom:

Question 1: How should Ofcom manage the process of taking advice from users, regulators and government on efficient apportionment of AIP fees in the maritime and aeronautical sectors? Are any new institutional arrangements needed?:

You must prove that there would be no effect on safety as a result of your proposals. Thus a safety review shall first be conducted by the responsible authority and you shall be obliged to abide by its findings.

Question 2: If you consider that our proposals for pricing ground station users for any spectrum would be likely to have a detrimental impact on safety, please let us know. In order for us to understand your assessment fully, it would be helpful if you could outline the mechanisms whereby this might happen.?:

If elements of the aeronautical and maritime frequencies are auctioned, there is every likelihood that the costs will be passed on to those who have no option but to use radio communications for flight or maritime safety.

Your proposal puts an unacceptable price on safety; it is quite unacceptable to compare aeronautical and martime radio to business radio.

Question 3: Do you have any evidence which indicates that AIP charged to ground stations could have a material detrimental impact on UK competitiveness?:

If airlines are obliged to pay more to use VHF communications within UK airspace, it will be inevitable that they may move their operations to more reasonable EU Member States.

Question 4: Taking into account the information available in this document, including that set out in Annex 5, our initial views on VHF radiocommunications licence fees and on the reference rates for bands in other uses, and any information you have about the organisations to whom we are proposing to charge fees, please provide any evidence that you think is relevant to us in considering the financial impact of the fees we intend to propose for VHF radiocommunications, or for other uses:

You cannot expect to charge for safety!

Question 5: Do you agree that there is little to be gained, in terms of economic efficiency, from charging AIP to WT Act licences for aircraft:

Economic efficiency is utterly irrelevant in this context.

Question 6: Do you consider that we should discount fees for any particular user or type of user? Specifically, do you consider that there should be a discount for charities whose object is the safety of human life in an emergency:

There should be no AIP or any other charges beyond those exisiting today, 11 Aug 2008.

Question 7: Do you agree that Ofcom should apply AIP to ground stations? use of maritime and aeronautical VHF radiocommunications channels, to help manage growing congestion in current use and to ensure that the cost of denying access to this spectrum by potential alternative applications is faced by current users?:

NO

Question 8: Do you agree with our initial view that it would be appropriate to apply a pricing system similar to that already existing for Business Radio licences to maritime and aeronautical VHF communications? If not, what are your reasons for proposing that we should develop a fee structure for maritime and aeronautical VHF channels which is distinct from that already established for Business Radio?:

NO

Business Radio is for convenience and efficiency, whereas aeronautical and maritime radio is entirely for safety.

You CANNOT make this comparison - it is totally nihil ad rem.

Question 9: Are there any short term reasons specific to the sector(s) why it would be inappropriate to apply fees from April 2009?:

This absurdly short timescale would give insufficient time to conduct a proper Safety Review and Imapct Assessment.

Question 10: Ofcom would welcome stakeholders? views on the factors which should be taken into account when apportioning fees between individual users of radars and racons:

This is a statement, not a question.

Question 11: Do you agree with our initial view that a reference rate of £126k per 1 MHz of national spectrum for L band and S band radar spectrum would achieve an appropriate balance between providing incentives to ensure efficient use of spectrum while guarding against the risks of regulatory failure in setting the reference rate too high? If you consider a different rate would be more appropriate, please provide any evidence that you think we should take into account.:

NO

Question 12: Do you agree with our initial view that a reference rate of £25k per single MHz of national spectrum would be appropriate for deriving fees for licences to use X band radar?:

NO

Question 13: Do you agree that, generally, spectrum used by aeronautical radionavigation aids is currently uncongested? Do you believe that this may change during the next few years and, if so, approximately when?:

Certain frequencies are often congested, others relatively quiet. The use of data links may reduce voice RT requirements, but more efficient frequency planning (as has been proved in Germany) would improve congestion levels and negate the need to extend 8.33 KHz channelling requirements.

Question 14: Do you agree with the basis on which Ofcom has arrived at its initial view on reference rates for aeronautical radionavigation aids?:

Absolutely not.

Comments:

I am frankly appalled that Ofcom should even consider selling off safety to the highest bidder. Aeronautical and maritime frequencies are necessary for the safety of life - in no way whatsoever are they comparable with Business Radio or PMR.

Aeronautical and maritime VHF and radionavigation frequencies are essential for safety and must be removed from the spectrum pricing policy.

31st August 2008, 08:37	#6 (permalink)
BEagle Join Date: May 1999 Location: Quite near 'An aerodrome somewhere in England' Posts: 14,371	Well, here's what I sent to Ofcom: Question 1: How should Ofcom manage the process of taking advice from users, regulators and government on efficient apportionment of AIP fees in the maritime and aeronautical sectors? Are any new institutional arrangements needed?: You must prove that there would be no effect on safety as a result of your proposals. Thus a safety review shall first be conducted by the responsible authority and you shall be obliged to abide by its findings. Question 2: If you consider that our proposals for pricing ground station users for any spectrum would be likely to have a detrimental impact on safety, please let us know. In order for us to understand your assessment fully, it would be helpful if you could outline the mechanisms whereby this might happen.?: If elements of the aeronautical and maritime frequencies are auctioned, there is every likelihood that the costs will be passed on to those who have no option but to use radio communications for flight or maritime safety. Your proposal puts an unacceptable price on safety; it is quite unacceptable to compare aeronautical and martime radio to business radio. Question 3: Do you have any evidence which indicates that AIP charged to ground stations could have a material detrimental impact on UK competitiveness?: If airlines are obliged to pay more to use VHF communications within UK airspace, it will be inevitable that they may move their operations to more reasonable EU Member States. Question 4: Taking into account the information available in this document, including that set out in Annex 5, our initial views on VHF radiocommunications licence fees and on the reference rates for bands in other uses, and any information you have about the organisations to whom we are proposing to charge fees, please provide any evidence that you think is relevant to us in considering the financial impact of the fees we intend to propose for VHF radiocommunications, or for other uses: You cannot expect to charge for safety! Question 5: Do you agree that there is little to be gained, in terms of economic efficiency, from charging AIP to WT Act licences for aircraft: Economic efficiency is utterly irrelevant in this context. Question 6: Do you consider that we should discount fees for any particular user or type of user? Specifically, do you consider that there should be a discount for charities whose object is the safety of human life in an emergency: There should be no AIP or any other charges beyond those exisiting today, 11 Aug 2008. Question 7: Do you agree that Ofcom should apply AIP to ground stations? use of maritime and aeronautical VHF radiocommunications channels, to help manage growing congestion in current use and to ensure that the cost of denying access to this spectrum by potential alternative applications is faced by current users?: NO Question 8: Do you agree with our initial view that it would be appropriate to apply a pricing system similar to that already existing for Business Radio licences to maritime and aeronautical VHF communications? If not, what are your reasons for proposing that we should develop a fee structure for maritime and aeronautical VHF channels which is distinct from that already established for Business Radio?: NO Business Radio is for convenience and efficiency, whereas aeronautical and maritime radio is entirely for safety. You CANNOT make this comparison - it is totally nihil ad rem. Question 9: Are there any short term reasons specific to the sector(s) why it would be inappropriate to apply fees from April 2009?: This absurdly short timescale would give insufficient time to conduct a proper Safety Review and Imapct Assessment. Question 10: Ofcom would welcome stakeholders? views on the factors which should be taken into account when apportioning fees between individual users of radars and racons: This is a statement, not a question. Question 11: Do you agree with our initial view that a reference rate of £126k per 1 MHz of national spectrum for L band and S band radar spectrum would achieve an appropriate balance between providing incentives to ensure efficient use of spectrum while guarding against the risks of regulatory failure in setting the reference rate too high? If you consider a different rate would be more appropriate, please provide any evidence that you think we should take into account.: NO Question 12: Do you agree with our initial view that a reference rate of £25k per single MHz of national spectrum would be appropriate for deriving fees for licences to use X band radar?: NO Question 13: Do you agree that, generally, spectrum used by aeronautical radionavigation aids is currently uncongested? Do you believe that this may change during the next few years and, if so, approximately when?: Certain frequencies are often congested, others relatively quiet. The use of data links may reduce voice RT requirements, but more efficient frequency planning (as has been proved in Germany) would improve congestion levels and negate the need to extend 8.33 KHz channelling requirements. Question 14: Do you agree with the basis on which Ofcom has arrived at its initial view on reference rates for aeronautical radionavigation aids?: Absolutely not. Comments: I am frankly appalled that Ofcom should even consider selling off safety to the highest bidder. Aeronautical and maritime frequencies are necessary for the safety of life - in no way whatsoever are they comparable with Business Radio or PMR. Aeronautical and maritime VHF and radionavigation frequencies are essential for safety and must be removed from the spectrum pricing policy.