Radio Spectrum Pricing - more costs to GA?

[astir 8]

OFCOM has a "consultation" document running

Applying spectrum pricing to the Maritime and Aeronautical sectors | Ofcom (http://www.ofcom.org.uk/consult/condocs/aip/)

concerning the possibility of (as best I can understand it) charging for the use of specific radio frequencies. There has been some discussion of it on PPRUNE in the "Tech Log" section but no-one has yet tried to explain it in language which I can follow.

Not unusually it appears to represent (eventually) "us" paying for something which has been previously free.

It seems to be saying that each ground station would have to pay £4950 per year for each frequency used. Mobiles (i.e. aircraft mounted) sets seem to escape, but if every ATC/FIS etc etc ground radio is going to get hit with that money, guess who'll be charged?

Come to that , does it mean that every gliding club with a ground station with the 4 gliding frequencies on it would be expected to cough up 20 grand per year?

Can anybody translate OFCOMspeak into English please?

[danieloakworth]

It also includes charging airports 125k per year per Meg of useage for radar.

[A and C]

The whole thing stinks of goverment money grabbing and I have spent the last hour telling them exactly what I think of it all.......... next is a letter to my MP.

Please use the link that astir 8 has posted and give them both barrels !

[Sir George Cayley]

Will they charge for 121.5? Shirley not:mad:

Sir George Cayley

[robin]

Its not clear how the charge will work for aircraft operators, except, I'd guess, it would increase landing fees.

I've already responded myself pointing out that for me, radio is a nice to have and is a means of communicating information for safety reasons.

I have expressed my horror and disgust at the prospect of filthy lucre getting in the way of my personal safety.....:ugh:

[Whopity]

The RA looked into this back in 1998 and came to the conclusion that there were no merits in applying the policy of Spectrum Pricing to aviation as they cannot sell the frequencies to anyone else!

Spectrum pricing study: Final report (http://www.ofcom.org.uk/static/archive/ra/topics/spectrum-price/spec-pric/1999/smithner.htm)

Quite how they would apply this pricing is not clear as they say in the latest report that it is not a charge for individual licences.

The current report shows a fundamental lack of knowledge of what the aviation use of the frequency spectrum is all about. The quoted fee for a 25KHz spaced comm allocation is 3 times that for a 8.33 KHz spaced allocation; It appears they don't understand the difference between bandwidth and channel spacing!

[A and C]

Just kicking this to the top because it is clear that a lot of you have not understood how important this is!

Do something or pay and pay and pay later!!!!!!!!!!!!!!!!!!!!!!!!

[S-Works]

I will be attending a workshop at OfCom on Monday to make a presentation regarding the impact of these proposals on aviation and GA in particular.

Please feel free to let me have any comments I can use in the presentation that will highlight the issue in a clear and non emotional manner.

[robin]

Bose

Very simply

1) Selling off the spectrum could result in one or two results

a) a single organisation (Virgin or NATS, say) will bid for the lot and then sell it back (with a significant profit)
b) a series of large organisations will divvy up the spectrum for their own purposes.

In both cases small airfields, like Old Sarum or Eaglescott will have a choice of bidding for a dedicated frequency against these large players or retreating to Safetycom - assuming it is still available.

We know of one airfield who has just lost its home frequency to be given to a large regional airport. We have lost the dedicated frequency in favour of a system whereby a pilot may announce his intentions but (according to the CAA) cannot ask for and receive airfield information.

THis means that the element of safety obtained by being able to have a conversation with A/G operators or FISOs or even traffic in the circuit is lost.

In my case I may have flown home after a two-hour trip and the situation on the ground will have changed whilst I was in the air - who will tell me that if the dedicated frequency is no longer available, and what happens if I line up on the wrong runway - right for the wind, but wrong because of local circumstances. At the moment, our A/G operator keeps us all informed, but, unless the use Safetycom is expanded we cannot legitimately pass information to each other.

Finally, and more importantly, we are consulting on the use of unlicenced airfields for flight training. I assume this is so as to reduce the financial and regulatory burden for initial training. These fields are unlikely to be able to afford the price hike of a dedicated frequency. Do we really want student pilots operating without the back-up of radio information?

No, this is an extremely bad idea and takes no note of the use of radio in aviation as a means of conveying essential information between pilots and the ground. We can (once sufficiently experienced) fly non-radio, but the risks of this are multiplied massively.

If Ofcom really do go ahead with this stupid and short-sighted proposal, then we, as GA, need to flag up our intention to register that any incidents due to lack of radio coverage are down to them, and that our lawyers will see them in court.

I really hope that, for once, the CAA will stand up for GA and put their foot down. Given the income they receive from our small licenced airfields, they should be backing us and not making us do their work for them.

[omcaree]

As these chargers filter down to aerodromes I'd imagine an increase in landing fees will be needed to offset the cost.
But how will this charging affect the en-route services such as LARS? The military fields that provide these services would have to pay to keep VHF frequencies (which no doubt they can do without); so this bill would be passed onto the end user? They don't see a great number of GA movements so an increase in landing fees won't make much difference.
I can just imagine receiving an invoice to the tune of "Our records show you were on our frequency for 23 minutes, that'll cost you £230"!.
Or, far more likely, services such as LARS will disappear. Yet another way to reduce safety in GA which will no doubt be overlooked by the money grabbing types who are proposing these charges!

[Whopity]

I attended a RA presentation in 1998 on the very same topic and they had come to the conclusion then that it was not feasible to sell spectrum space for aviation use as it is allocated Internationally and they can't sell it to anyone else! That rather removes the competitive element! this is all documented on the Offcom website.

The primary purpose of aeronautical spectrum is Flight Safety, be it communication, navigation or Radar.

What price Safety under the current administration?

[robin]

.... but their lords and masters need more shekels so common sense doesn't come into it. They want cash and this is another stealth tax.:ugh:

[GWYN]

Suggested reading from the other two recent threads on this subject:

http://www.pprune.org/jet-blast/343462-yet-another-stealth-tax.html

http://www.pprune.org/tech-log/341207-radio-spectrum-pricing.html

[astir 8]

Step 1 - try to understand what Ofcom are saying - that's my problem.

Step 2 - RESPOND! - whichever way you think.

[Whopity]

In 1998 when they announced that they would NOT be applying Spectrum Pricing to aviation they said that they would have a one price radio licence for aircraft. Large aircraft were charged several hundred pounds and light aircraft £35 at that time. They were going to even the price to around £250 per aircraft.

I believe I was the only person who responded, and recommended reducing the light aircraft radio licence to the minimum admin cost; they subsequently reduced it to £25. That was what responding can achieve. AOPA were not interested in responding on behalf of GA when I made them aware of the issue.

The more response, the more likely they are to think again; remember response is public consultation and they have to listen. Typically, the level of response in the GA world is between 1 and 2%, so that's the proportion who decide what happens!

[S-Works]

All good input, thank you. Please keep it coming.

[BackPacker]

Taxation of a common good (land use, water use, frequency use, air pollution) is normally done because somebody makes money by using that common good, and the government want to have its share of the profits. That's why commercial vehicles pay road tax and so forth.

If a commercial operator (a cellphone provider, say), gets exclusive use of a certain frequency range, and uses that to make money, it's very logical that the government wants a share of this.

Aviation doesn't make money from using the aviation frequencies. Instead, it's a safety tool. Putting a tax on it would be like applying taxes when somebody dials the emergency number.

[trevs99uk]

Who gets the money for the Radio License fee for aircraft.

trevor.

[BEagle]

I gather that the Ofcom meeting a day or so ago was........interesting?
http://i14.photobucket.com/albums/a341/nw969/Internet/zxzxz.jpg

Any feedback yet?

[S-Works]

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.

[BEagle]

No, bose-x, I'm sorry but I didn't get anything via the MWG e-mail list. Have the IC and MWG mail lists been merged?

The information came via another PPRuNer whilst we were writing about other matters.

Thanks anyway for the paraphrase!

[S-Works]

No, bose-x, I'm sorry but I didn't get anything via the MWG e-mail list. Have the IC and MWG mail lists been merged?

The information came via another PPRuNer whilst we were writing about other matters.

Thanks anyway for the paraphrase!

In which case I will ensure that you are added back in!! It is important that you see the discussion.

No the 2 lists are separate with overlap for people like me and Chris.

[BEagle]

Ofcom have just released an 'update':

Ofcom consultation on introducing Administered Incentive Pricing (AIP) for the maritime and aeronautical sectors: December 2008 update | Ofcom (http://www.ofcom.org.uk/consult/condocs/aip/update171208/)

Weasel words indeed to describe the reception their daft idea of spectrum pricing for nothing more than government greed has received!

[IO540]

To me, this sounds like a face saving way of saying they have decided to drop it. That's the way I would write it if I didn't want to look like a total d1ck. Must read Alan Clark's diary (the 1st part) :)

[goatface]

The suggestion that a small airfield had "it's" frequency taken away from it and "given" to a large airport is frankly ridiculous and just demonstrates the lack of understanding by a few within the GA community.

Airports throughout the UK have to share frequencies because of the lack of space within the VHF spectrum, for the most part, those experiencing interference do so because they are using them outwith the published DOC within the UKAIP, sometimes if the pressure is exceptionally high, nature interferes and nothing can be done about that.

If and when digital radio frequencies replace MW and VHF frequencies for commercial radio stations, then more space will become available for the use of others but, as always has been the case, they won't be free.

Commercial organisations (airports) pay a lot of money for the use of VHF, MW and UHF frequencies, not only for RT channels, but for ILS,MLS, VOR and NDBs.
GA already pay a very small amount towards this through landing fees, but as with everything GA when it comes to airports, you get a lot and contribute very little in terms of commercial income.

[IO540]

Come on goatface, it's not just GA - this would have affected the whole of aviation and caused mayhem.

The pricing of frequencies which are operated under ICAO obligations is just a tax. It has about as much meaning or logic as charging people for wearing underpants.

It would have massively distorted the use of navaids. GA airfields would have dumped all navaids and gone big-time for GPS approaches, which hilariously would be a good thing because we do need GPS approaches (except that the vast majority of light planes don't have the - approved - equipment to fly them, so this would be a huge detriment to safety) but the UK Govt would have paid dearly for the DMEs which will always be used by airlines, to correct their INS nav systems. Current Eurocontrol plans are to dismantle VORs past 2015 and plant hundreds of DMEs around Europe for the airlines' usage. The UK would have paid dearly for its share of this DME population.

There are loads of VHF frequencies available - it has been proven by IAOPA that the whole 25/8.33 problem would go away if allocation was done centrally for Europe. The usual aviation-political (national CAA job protection, basically) interests prevent this happening. The USA does not need 8.33 because they have exactly this - completely trivial - system.

[xrayalpha]

Look at history.

When 3G phone licences went up for auction, the UK telcos paid so much that Spain cancelled all the licences they had given away a few months earlier and auctioned theirs, earning billions.

But when Scottish Television had to rebid for their licence about 10-15 years ago, they worked out that no-one else was interested and bid just £1. Yes, 100p.

So, let's have an auction, starting at £1.

Then if small airfields don't bid, the floor price will be £1.

Then small airfields can apply and say: we'll pay the commerical rate, here's a quid.

Then the govt loses money - as it tends to do on all its projects (see the one about the computer system merger that would save 60m and has now cost 80m the other day!)

[BackPacker]

XA, the difference is that telco's make money by using those frequencies. Directly.

In aviation, we don't make money from our radio communications or navaids. Instead, we use them to enhance safety, situational awareness and so forth.

Because of this, it's extremely hard to put a value on a frequency. While for the telco's it's easy - you can basically look at your balance sheet.

It would be possible to make money from aeronautical frequencies though, by using the same mechanism that TV and radio uses: advertising.

"G-ABCD, this is London Center, sponsored today by XYZ company"
"This is Heathrow information Zulu, brought to you by XYZ company"
"G-ABCD, you are cleared to land and once you're down, XYZ company is running a special in the cafeteria on the ground floor which we'd like to recommend."

And we can get rid of those pesky morse code identifiers too:

"This is the XYZ NDB. Check out our website at www dot xyz dot com. This is the XYZ NDB..."

[xrayalpha]

Backpacker,

Scottish Television is a commercial TV station, which makes money from advertising.

Yet it "commercially" valued its frequency at just £1.

So my point is, that even if valued commercially, our airband may not even be worth the trouble of selling it off.

After all, the price someone is willing to pay is affected by the demand.

So if all the small operators boycott the deal, the big boys - like Heathrow - can then just tender a single pound knowing they will get their frequencies.

Then the govt will get even less than it does now!

And the small operators will then be able to apply afterwards at just a quid a go for the unused spectrum.

[BackPacker]

XA, that sets a precedent for the rest of the world, and is a big gamble.

First, it sets a precedent because the UK would be the only country that assumes that the aeronautical frequencies have a business value and can be sold and taxed. But aviation doesn't make money from these frequencies. It makes money by hauling freight (sometimes self-loading) about. Our business would technically be possible without radio communications, although the capacity of the system would be greatly reduced, and safety would be severely compromised. But mobile phones or (non-cable) TV and radio, without a radio frequency is simply impossible.

Furthermore, it's a big gamble. Right now these frequencies are set aside, worldwide, for aviation. But what if a non-aviation company makes a bid for a few frequencies and starts using them for non-aviation purposes? The only law that they've got to abide with is the ANO and they can make a convincing case that since they bought the frequency, they're allowed to use it any way they please, rest of the world be damned. Particularly if their DOC is limited to the UK.

Oh, and what would happen if I make a bid of, let's say, 2 quid for 121.5 and decide that what aviation needs is a 24-hour music station? In fact, I can bid 2 quid on all of the 760 or so available frequencies and just wait and see who outbids me, and put my 24-hour aviation news network on any frequency that I get.

The fact that Scottish TV was lucky and was the only bidder on a frequency was an exception. Even more so that they knew about it and had the guts to bid one quid. Any old Scotsman could have made a higher bid and then lease the frequency to Scottish TV for a much larger amount. I predict they can only pull this stunt only once and need to bid a much, much higher amount next time the license comes up for auction.