Submission on Changes to CBRS Standard
- 1st Submission to ACA on CBRS Standard (213 downloads)
- 2nd Submission to ACA and Standards Australia (205 downloads)
- Submission goes before Standards Australia
- Draft Amendment of Standard Released
- Amendment 1 : 2007
History of the Submissions
In January 2005 ACREM sent to the Australian Communications Authority (ACA) a submission proposing changes to the CBRS Standards that would force manufacturers to include certain minimum information with all equipment operating on the Australian CB bands. This was brought about following some incidents that highlighted the worsening problems on the CB bands regarding misuse of the legally allocated emergency channels, especially on the UHF band, and the lack of information in some user guides.
In the early days of CB each station required an individual licence, and with this licence came information detailing the various legal channel allocations on the CB bands such as emergency channels and call channels. Even those that operated unlicensed were fully aware of these channels because the licensed operators ensured these channels were kept clear for the intended use. However, in 1994 the Federal Government introduced the Citizens Band Radio Station Class Licence, removing the need for operators to hold an individual licence and pay an annual licence fee. But despite some beliefs CB was not ‘de-regulated’ – conditions governing the use of the CB bands remained in force and all stations were automatically covered by the Class Licence.
Unfortunately, in the absence of a licence and information on channel uses, it wasn’t long before new users started operating on emergency channels and call channels, totally unaware that channel allocations even existed! This was compounded by the fact that many manufacturers provided little, if any, information regarding the Class Licence and channel uses with the equipment. As the UHF CB band grew more popular, especially amongst the business operators who now had access to totally free radio communications, the problems grew steadily worse.
With the introduction into Australia of cheap UHF hand-held radio’s the problems exploded beyond belief! Cheap units could now be purchased for as little as $20 each and were often marketed simply as “40 Channel UHF Radio” or “UHF Personal Radio”. Most often the fact that these were indeed CB Radio was not mentioned, and many parents started buying these units for their children to use as ‘play toys’. Although they were low power, they were still capable of causing extreme interference, especially when used within range of a repeater. Often these units were imported from the USA where they operate on the US “Family Radio Service”, and then re-programmed to operate on the Australian CB band, which meant that information in the user guide regarding Australian CB allocations was extremely rare.
In late 2004 an emergency call following a serious motor vehicle accident in Queensland was blocked for some 40 minutes while emergency Monitors tried to clear the emergency repeater. In the end this accident resulted in a fatality, and pushed home the severity of the problems and just how easily lives could be lost because of interference on the emergency channels. Action was needed and ACREM prepared their first submission to the Australian Communications Authority (ACA) seeking changes that would force manufacturers to include information on the CB channels in all manuals, and also the affixing of labels to all equipment to draw the attention of the user to the existence of the emergency channels. The submission also sought to have ACA increase compliance enforcement activities, blaming much of the current problems on the lack of action by the Government against illegal operations.
Then in May 2005 ACREM was contacted by the ACA regarding the submission, and asked to prepare a second submission dealing solely with the matters affecting manufacturers, for consideration by the Standards Australia industry group and, hopefully, agreement by the manufacturers to voluntarily implement the proposals presented. In order to compile this submission ACREM contacted a number of other groups and asked for their comments, suggestions and support so the submission could be presented as a combined effort backed by several groups. ACREM contacted ACBRO, ACRM-SA, ACRM-WA, CARES, CREST-NSW, CREST-Vic, CREST-Qld, TASVEC, VKS737 network, Goulburn Emergency Repeater Group and Gympie Emergency Monitors. Of these groups the following chose to support the submission and also provide input into its preparation, where possible. We acknowledge and thank these groups for taking the time to support a submission that affects ALL CB operators:
- ACBRO – (now closed)
In addition to these groups, several private individuals also provided information to help prepare the submission.
Submission considered by Standards Australia
On 23rd June 2005 the submission was discussed by the Standards Australia Radiocommunications group committee, with the points highlighted by the ACA for consideration and report back to ACA receiving the most discussion. The combined groups were represented by ACREM Director, Martin Howells, who participated in the meeting by telephone conference.
The submission was forwarded to the committee by the ACA who had provided their general support behind the submission and highlighted three questions that required consideration by the industry group for recommendations back to ACA. These three questions were:
- Page 8 and 9 ACRM-SA and TASVEC comment. The supply of equipment having channel 35 as the default. It would appear that, at the least, unless the user is aware of the intended purpose of channel 35 then they cannot avoid causing interference. It would also appear that users would benefit from not being provided incorrect advice at the point of supply.
- Page 9 “Private CB operators” and page 10 item 1(a) comment. What are the practicalities of reducing the incidence of the CTCSS problems presented by equipment configuration?
- Page 10 item 1(b). What are industry comments on the practicalities of configuring the cheaper units to avoid the use of repeater frequencies?
- The committee agreed that equipment should NOT have the emergency channels as the default power-on channel. It was agreed to amend the standard so that channels 31 to 38, and channel 5, would not be used as default power-on channels on any CB equipment.
- Whilst the use of CTCSS on channels 5 and 35 is not prohibited in the Class Licence, it is covered in the actual standard. However it was agreed that the Class Licence should be amended so that it reflects the same restrictions as the standard, especially as most operators would not have access to the standard but do have access to the Class Licence.
- It was generally agreed that removing repeater channels from equipment is impractical and may prove extremely difficult. It was believed that the changes in (1) above would help to alleviate the problems being experienced when new users turn on their equipment and it is already set to a repeater input channel.
The committee also agreed to look at any equipment that is currently available with CTCSS tones functional on 5/35. This change in the standard only occurred in 2001 so it is possible that some equipment still available was manufactured prior to the changes, a fact supported by reports that some very popular and cheap UHF hand held units currently available do indeed allow full CTCSS functions on channels 5 and 35. If necessary the committee will audit any such equipment and recommend that the manufacturer make the relevant changes.
All up it seems that the ACA and Standards Australia have responded well to our concerns and are now aware of the problems that have been experienced by a number of operators all across Australia. We can only hope that this submission will prompt some changes to help remedy the growing problems, and ACREM will continue to work with other groups to petition for changes where and when necessary.
Draft Amendment to Standard
In August 2006 the Draft Amendment for postal ballot and public comment was released. Basically it proposes the following changes to the Standard for UHF CB equipment:
- the requirement for information regarding the Class Licence and the emergency channels be included in all user manuals; and
- the requirement that the design must prevent channels 5 or 35 being used as a default factory power-on channel.
Although there were more suggestions in the submission, ACREM feels that this is still a victory for the CB groups as it shows that Standards Australia and the Committee are willing to listen to submissions put forward and adopt suggestions where we can make a case for those changes.
One other matter than came out of the submission, that of CTCSS on the emergency channels, was passed back to the ACA (now ACMA) for consideration during the next review and amendment of the Class Licence.
You can download the Draft Amendment paper from here: DR06492 - Amendment 1 to AS/NZS 4365 (184 downloads) .
On 22 January 2007 Amendment 1 to AS:NZS 4365:2002 (Radiocommunications equipment used in the UHF citizen band radio service) was published. In brief, this amendment made the following changes to the standard:
- Delete clause 5.2 and replace with:
5.2 Equipment user manual
An equipment user manual shall be provided with the equipment and include:
- Advice that use of the citizen band radio service is licensed in Australia by ACMA Radiocommunications (Citizens Band Radio Stations) Class Licence and in New Zealand by MED General User Radio Licence for Citizens Band Radio and operation is subject to conditions contained in those licences.
- Advice that, in Australia except in an emergency, a CB transmitter must not be operated on UHF emergency channels 5 and 35 and no voice transmissions are permitted on data channels 22 and 23. Note that equipment meeting this Standard will inhibit voice operation on channels 22 and 23.
- An instruction to always listen on a channel (or observe a channel busy indicator) to ensure it is not already being used before transmitting.
- A brief description of UHF CB repeater operation and the need to avoid operation on locally used repeater input channels (which will be in the range channels 31 to 38) or locally used repeater receiving channels (which will be in the range channels 1 to 8), unless long distance communication via the repeater facility is specifically required.
- Delete clause 6.1.2 and replace with:
6.1.2 Start up channel
The equipment design shall prevent emergency channels 5 or 35 being the factory default start up channel.
This was a major win for the groups that chose to support our original submission with the combined submission that went before the Radiocommunications Consultative Committee.
You can download a copy of this amendment here: Amendment No.1 to AS/NZS 4365:2002 (222 downloads) .
A second amendment to the standard was published on 12 December 2008. Although this amendment was primarily concerning the use of data and automatic locators, it did make changes to Clause 6.1.2 which was amended in amendment 1 to prohibit the emergency channels being factory default start up channels. However, this provision was retained as presented in amendment 1 in Clause 6.1.4.
You can download a copy of this amendment here: Amendment No.2 to AS/NZS 4365:2002 (196 downloads) .