Beagle, you were aware of the feedback as I circulated it to the MWG distribution list. However I paraphrase below:
When is a tax not a tax?
When it is hidden behind an AIP with the excuse of using pricing as a tool to reduce excess demand for spectrum in a sector of the spectrum that is protected by international treaty and it's use is mandated under international treaty in controlled airspace. Where there is no alternative and no choice.
On behalf of AOPA and PPLIR I gave an overview of the issues that would be caused by spectrum charging to GA and asked what I hoped were some very direct and robust questions.
The key point that we made during the workshop was if the AIP was meant to use pricing as a tool for freeing up spectrum, who exactly was after this spectrum and for what purpose. Are OFcom prepared to ignore international treaty and resell spectrum that is protected?
I pushed home the fact that a pricing tool that is enforced in an area of spectrum that is internationally protected and therefore can not be released is a tax. This few left a few red faces and squirming bums.
I then went on to explain the danger to GA in my presentation with introducing these charges, that it would indeed free spectrum in the air band as small A/G airfields would give up the radio station. As the number of stations reduced pilots would no longer bother to use the radio as they had few people to talk to and those that were available would be looking at methods of their own cost recovery and we would be effectively unravel a decades work of driving people to use the radio and improving radio standards.
The other area I talked about was the fee to be charged for use of the SSR band. We have spent years getting people to fit transponders and go mode A then mode C and now mode S. If that part of the spectrum is charged then the ground stations that operate will be looking to cost recovery and that again will deter people from use of SSR kit. The CAA may be able to mandate it but getting people to turn it on and talk to units is a different matter.
I also discussed the issues around pricing and the fact that they have charged three times the price of an 8.33khz slot for a 25khz slot.
It was interesting to note that for one of the few times every single person around the table from the airlines, NAT and even the CAA were strongly against the proposal.
My proposal to OfCom was by all means value the spectrum but observe the Cave report and charge it at zero as no efficiencies can be gained from using IAP in this sector. NATS followed in a similar vein and talked about the cost to UK Plc as did the airlines.