It has become clear that ACMA intends to progress the WIA's initial actions to partially integrate the qualifications requirement for issue of an amateur radio licence into the Australian Qualifications Framework (AQF).
The AQF is the national policy for regulated qualifications in Australian education and training. It incorporates the qualifications from each education and training sector into a single comprehensive national qualifications framework. The AQF was introduced in 1995 to underpin the national system of qualifications in Australia encompassing higher education, vocational education and training and schools.
That push on integration includes the use of Registered Training Organisations (RTO) for assessments, RTOs are an element of the Vocational Education and Training Sector (VETS).
The definition of Vocational Education and Training can be taken from australia.gov.au:
Vocational education and training
Designed to deliver workplace-specific skills and knowledge, vocational education and training (VET) covers a wide range of careers and industries, including trade and office work, retail, hospitality and technology.
So, the WIA and ACMA have over a couple of decades acted to integrate amateur radio qualifications in the AQF to some extent, and current actions are intended to perform assessments within the VETS (ie by VETS qualified assessors under an RTO).
This move to integrate amateur radio qualification with the AQF started a long time ago when well intentioned people thought that it would encourage young people to study for a amateur licence and at the same time obtain AQF competencies that could be useful in obtaining employment or credit in more advanced courses. These competencies could be obtained within Australian high schools, and in the mind of one proponent, would turn out 6,000 new hams (amateur radio operators) year on year.
It is doubtful if the existing AQF competencies have achieved much for the holders themselves or ham radio generally, and in any event, it appears the ACMA think that new competencies would need to be created going forward.
The cost of creating the new AQF objects and conduct of assessments by RTOs is unlikely to be born by government, so it would be born eventually by charges on the persons seeking assessment.
If competency instruments must be registered and assessments done by RTOs under contracts or deeds of agreement with the Commonwealth, it would seem that the assessors must be qualified under the VETS arrangements, and most current WIA assessors do not hold those qualifications.
The RTOs may or may not wish to use the current assessors who do hold the necessary qualifications, it is a business decision for each RTO.
It is likely that most current assessors would no longer perform volunteer assessments, and unlikely that any current assessors would perform volunteer assessments as RTOs need to recover costs and reasonable profits from their business operations.
There is a mandated requirement for operator qualifications for the issue of an amateur radio licence, ‘mandated' by international treaty (ITU Radio Regulations), though administrations define the competency themselves to a large extent (in many instances in consideration of what is done by other administrations).
Post WRC-03, the recommended competency was given as ITU-R M.1544, the essential part follows.
that administrations take such measures as they judge necessary to verify the operational and technical qualifications of any person wishing to operate an amateur station;
that any person seeking a licence to operate an amateur station should demonstrate theoretical knowledge of:
– Radio regulations
– Methods of radiocommunication – radiotelephony
– data and image
– Radio system theory
– antennas and propagation
– Radio emission safety
– Electromagnetic compatibility
– Avoidance and resolution of radio frequency interference.
It is not very detailed, and there is no mention of different grades, so a lot is left to the administration.
Australia's Advanced grade are aligned with the European CEPT HAREC standard which has benefits of simplified reciprocity. There are also other reciprocity arrangements on a country by country basis.
The last licence reform (2003-4)
The WIA in their submission to the ACA's August 2003 discussion paper, A Review of Amateur Service Regulation recommended migration to a two tier licence structure:
The WIA is in favour of the reducing the current count of 5 licence grades to a much simpler 2 grade model. Under this proposal all existing Australian licences would be folded into the current AOCP (Unrestricted) grade.
The WIA in so doing made no distinction between the competencies of the pre existing five licence grades that would be merged into one under that arrangement.
The ACA responded with:
On balance and after careful consideration of submissions, the ACA has decided to introduce a foundation-style amateur licence, to form part of a three-tier licensing structure.
It was within their remit to determine what qualifications applied (ie the content of the competency or as they call it, the syllabus), but their hands were somewhat tied in needing to require qualifications (the international treaty mentioned).
That was 15 years ago.
The bigger question
The bigger question is “what is the purpose of the qualifications requirement”?
The answer that “it is required by international treaty” is not a very good explanation, it is something you expect to hear on an episode of “Yes Minister!”.
A very long time ago when technologies were much less mature, knowledge scarcer and communications and information resources much poorer, a minimum standard of knowledge was considered ‘necessary' to allow a person to design, build, test and operate their amateur radio station within the law, technical standards, and sociably with other services.
Things have changed over the hundred years or so of Australian amateur radio.
If we were to take inventory of the knowledge and skill set used by most hams in establishment and daily operation of their station, it would be much less than the competencies required to obtain the related qualifications.
Another perspective on the problem is to consider whether most hams would pass a re-assessment with no notice or special preparation, ie the same level of preparedness with which they operate their station from day to day.
If the prescribed competencies are more than necessary, or if most hams were unlikely to pass the re-assesment, the qualifications are merely an entrance hurdle that is not related to the ongoing operational requirement.
It can be argued that the principal effect and purpose of the existing qualifications is to restrict entry to amateur radio.
The method of qualifications assessment
It can be argued that Australia cannot dispense with mandatory qualifications due to treaty obligations, and the standard of the Advanced should remain aligned with the European CEPT HAREC standard for reciprocity. Similar things can be said of bilateral reciprocity arrangements.
Abolition of the mandatory Morse code competency for HF amateur licences demonstrates how resistant ham radio is to change, and how hog tied administrations choose to be, it took decades longer than it should have to dispense with that anachronistic restriction on entry to amateur radio, but it did serve the purpose of restricting entry.
Whilst the ACMA might argue that it cannot act alone on the requirement for qualifications, and it might not want to depart from the CEPT HAREC ‘standard' for content of the competency, it does exercise considerable freedom is setting the assessment regime.
In pursuit of that, it seems intent on integrating assessment for amateur radio qualifications in the Vocational Education and Training Sector industry.
An amateur radio licence (or its qualification certificate) is not an occupational or vocational licence / qualification, indeed it is the very opposite (“amateur” radio), and it is not clear that vocational assessments and governance are necessary, or good, or that the costs of such a scheme are reasonable.
The entry costs are likely to increase significantly under a VETS assessment regime and be a further real barrier to entry to amateur radio.
- ACMA. May 2004. Outcomes of the Review of Amateur Service Regulation.
- Duffy. O et al, Oct 2003. (CQVK) Submission to the ACA in response to its discussion paper: “A Review of Amateur Service Regulation” August 2003
- WIA. Oct 2003. WIA response to the 2003 Australian Communications Authority Discussion paper “A Review of Amateur Service Regulation”