2009 Access to 500 kHz Letter to MED

24 June 2009
Mr Brian Miller
Manager, Radio Spectrum Policy and Planning
Radio Spectrum Management
Ministry of Economic Development
P O Box 1473
WELLINGTON 6015

Dear Brian,

Access by New Zealand's Radio Amateurs to a Band and Spot Frequencies at 500 kHz

As you may recall, access to a band at 500 kHz for New Zealand's radio amateurs has been previously sought, in a letter from NZART of 2 October 2005. Your reply declined our request (File No. POL/1/24/16, 17 October 2006 refers) however, the Ministry was to seek further information at that time.

We now have a two part request as follows:

(1) General Access by NZ Amateurs to a Band at 505 - 510 kHz on a Temporary Basis

(2) Access to Spot Frequencies at 487.5 kHz and 512 kHz for a Memorial Station ZLD

There are a few common elements to both requests.

(1) General Access by NZ Amateurs to a Band at 505 - 510 kHz on a Temporary Basis As you will be aware, significant changes have occurred since the original request. The major change is that at WRC-07 a new Agenda Item 1.23 was approved for WRC-11; that is "to consider an allocation of about 15 kHz in parts of the band 415 - 526.5 kHz to the amateur service on a secondary basis, taking into account the need to protect existing services".

In support of this Agenda Item, NZART is seeking early access on a temporary and "non interference basis" (NIB) to a small band at 505 - 510 kHz (or such other allocation that is acceptable to the Ministry), until further notice. We expect that Notes 2 and 4 to the Allocation Table of our General User Radio Licence will apply.

The first and most specific objective is to ensure that we can operate without causing any interference to existing services. We are aware of the NAVTEX service (on 490 kHz and 518 kHz), NDBs and DGPS systems operating in adjacent sub-bands. It is also that understood that there are still prohibitions on operating in the 495 - 505 kHz range.

It is intended that those amateurs participating in operations at "505 -510 kHz" (the "600 meter band") collect data and information on, and have as general objectives:

* Investigations into ultra reliable communications via ground wave (valuable for emergency use)

* Study of a unique propagation and noise environment (especially NZ conditions)

* Experiments with antennas, modulation methods, digital signal processing, weak and long distance signals (to determine optimum parameters and systems) NZART is optimistic that the frequencies at about 500 kHz will be useful for regional communications between all stations in a "party line" network (out to about a 100 - 300 km range), with the potential for use for emergency communications. This frequency is near the geometric mean of our existing bands at 135 kHz and 1.8 MHz. Little application of "modern technology" has been applied to this frequency, so we will look to use DSP and computer processing of weak signals and data modes.

It is noted that access to parts of this spectrum, under various conditions and experimental licences have now been granted by the administrations of a number of countries - most recently by Canada in November 2008. The USA, Great Britain, Germany, Sweden, the Czech Republic, the Netherlands and Romania are also participating in 500 kHz experiments.

It is proposed that access to this 600 meter band be managed by a set of "Rules" similar to those developed for AREC access to the two spot frequencies at 5 MHz. A copy of our proposed draft "Rules" is attached. NZART sees this as a part of our "self regulatory" functions.

It is also proposed that project and band management be carried out by the Suburban Amateur Radio Club (SARC), Branch 86 of NZART. They have a special interest in this, with their club access to the Musick Memorial Radio Station at Bucklands Beach, Auckland.

This request for access to a small band at 500 kHz has the unanimous support of the NZART Executive Council.

Request: That NZ radio amateurs be allowed access to 505 - 510 kHz (or other suitable allocation), on a temporary and "non interference basis" (NIB), until further notice. It is expected that Notes 2 and 4 to the Allocation Table of our General User Radio Licence will apply. Only "narrow band" modes will be used, with CW (Morse code) or other modes with less than 1 kHz bandwidth.

No e.i.r.p. limits on radiated power are requested. It is suggested that the amateur radio power limit shown in paragraph (5) of the GURL is sufficient and understandable. In practice it is difficult enough to get energy radiated at 500 kHz with the short, loaded antennas that will typically be used. Measuring e.i.r.p. is difficult. It is not expected that large numbers of amateurs will use the 600 meter band due to the difficulty of radiating a sufficient signal - it will become a specialised but important part of our activities.

(2) Access to Spot Frequencies at 487.5 kHz and 512 kHz for a Memorial Station ZLD The second request is for occasional use of the two spot frequencies of 487.5 kHz and 512 kHz originally used by ZLD, the Auckland Coast Radio station. A "Memorial Station" will be restored at the Musick Point site in Auckland for this purpose using the original NZPO transmitters (separate transmitters were used on each frequency) and receivers, to make it as authentic as possible. These transmitters are crystal locked and cathode keyed, and will be used for A1A (Morse code) transmissions only. Occasional special transmissions will be made only on these frequencies, listening for replies from other historic and museum stations on 500 kHz and other adjacent frequencies. Some cross frequency communications may be possible.

To enable cross frequency communications with stations in the amateur service (hopefully in NZ in the allocation 505 - 510 kHz as requested in (1) above; and other licensed bands) it is also requested that the amateur call sign ZL1ZLD be allowed to be used from time to time on the spot frequencies. This call sign is already held by the Suburban Amateur Radio Club.

Other general operating procedures will be in accord with the set of "Rules" proposed for (1) above, where applicable.

It is clearly understood that these spot frequency operations must be on a "non interference basis" (NIB), especially with the NAVTEX service on nearby frequencies, and comply with any other conditions set as the Ministry may require.

Request: That the Suburban Amateur Radio Club (SARC) of Auckland be given access to transmit on the original spot frequencies of 487.5 kHz and 512 kHz used by ZLD, with the use of the call sign ZLD for special memorial occasions; and the call sign ZL1ZLD for cross frequency communications with stations in the amateur service.

This request for spot frequencies also has the unanimous support of the NZART Executive Council.

For your valued consideration and timely approval.

Thank you.

Yours sincerely,
Don Wallace
NZART Administration Liaison Officer
NZART 3 June 2009