21 February 2011

Mr David Robinson

Citizen Band/PRS GUL Review

Radio Spectrum Policy and Planning

Ministry of Economic Development

PO Box 1473

WELLINGTON, 6140

Dear Mr Robinson,

Citizen Band/PRS GUL Review

Thank you for your email of 10 February alerting us to this review. 

As mentioned in my interim reply, we did not think we were affected by this review but have since become aware that it includes a proposal that Citizen Band operators be allowed to use the 26.95 to 27.3 MHz band.  This band is currently shared between Amateurs, Paging, Defence, Industrial Scientific & Medical equipment and Short Range Devices. 

We believe it is, in general, undesirable that CB users and Amateur operators share the same spectrum.  While some CB radio users have technical knowledge and skills (some of whom graduate to Amateur Radio), the general CB radio user does not and is therefore unaware of the techniques required in shared spectrum. 

You will also be aware that there has been, in the past, confusion and conflict over the rights and obligations of these quite different groups which RSM has had to manage.  Having Radio Amateurs and CB radio users sharing the same spectrum is likely to make these considerably worse. 

We note that this frequency range is also occupied by a number of licensed paging and telemetry services.  Most CB radio users are unlikely to be aware of these licensed services or have the skills/knowledge to avoid interference to them.  

In summary, we believe it would be unwise to extend the HF CB allocation to include the band 26.960 MHz – 27.410 MHz.

Yours sincerely,

Don Wallace

NZART Administration Liaison Officer

2011-02-21