LoRa APRS From a Balloon - Legality

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John Laidler

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Nov 13, 2025, 3:30:27 PM (4 days ago) Nov 13
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There was a long thread a few months ago about the RSGB project to launch a LoRa iGate below a balloon. A lot of the discussion was about the legal situation but I'm still unclear if this was concluded one way or another. Specifically, if instead of launching an iGate the balloon carried a tracker, broadcasting signals to be picked up by iGates on the ground, is this allowed? The default frequency for these trackers in the UK is 439.9125 MHz. Outside ISM bands but allowed for licensed operators. 

John
M0WIV 

David Brooke

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Nov 13, 2025, 4:45:17 PM (4 days ago) Nov 13
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On Thu, Nov 13, 2025 at 12:30:27PM -0800, John Laidler wrote:
> Specifically, if instead of launching an iGate the balloon carried a
> tracker, broadcasting signals to be picked up by iGates on the ground, is
> this allowed? The default frequency for these trackers in the UK is
> 439.9125 MHz. Outside ISM bands but allowed for licensed operators.

The UK amateur licence does not permit airborne operation in the 70cm
band.

Whilst you could transmit LoRa APRS under the ISM rules you'd have to
arrange for receiving stations so in my view there would be no point in
doing so rather than using the established UKHAS format LoRa.

David G6GZH

Steve

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Nov 13, 2025, 5:21:41 PM (4 days ago) Nov 13
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I remember the discussion.  In effect Amateurs up-linked messages to the balloon on 439.9125 MHz and these amateur radio messages were then down-linked on 433.850MHz in the ISM portion of the band.

Airborne use of 433.850MHz would not be allowed under the amateur radio license - but is allowed for airborne use of License Exempt devices.

There is no issue with the uplink on 439.9125 MHz as its inside the Amateur 70cms allocation and the amateurs were ground based.

My point was that Radio Amateurs are only allowed to communicate with other amateurs** - but clearly the down-link is outside the amateur radio service (since amateur airborne operation on 70cms is not permitted).

Other folk had a different perspective - seeing the LE down-link as no different than using say bluetooth to relay amateur audio between rooms (I see that as different as the amateur transmission has already received by an amateur radio station before being relayed).

I gave an example of similar system:  a hill top amateur 70cms repeater with PMR446 output (amateur band up, license exempt band down, repeating amateur radio messages).

There wasn't a definitive outcome to the discussion (we agreed to disagree).  I wasn't going to push the point as there had been a lot of work done and it seemed too late in the day to change.

You might ask Ofcom for a view (the RSGB has skin in the game) - it would be worth putting both examples to them and seeing if they think both are allowed (and why).  A further question would be if balloon based APRS tracking could be used on LE 70cms frequencies and power levels. 

    Steve G8KHW


**The UK license says:   

    "Making transmissions  19. Unless the Radio Equipment is being used for the purposes of clause 5 (disaster situations), the Licensee must ensure that

        a) Transmissions are only addressed to one or more amateur radio station(s);"

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Steve

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Nov 13, 2025, 5:32:43 PM (4 days ago) Nov 13
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My view would be, this would not be allowed as:

    If the signals are being picked up by amateur radio iGates (but set
up to a 70cms LE RX frequency)  then the transmission from the balloon
are clearly amateur radio in nature and amateur radio is not allowed
airborne on 70cms.

    Steve G8KHW
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John Laidler

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Nov 13, 2025, 5:39:28 PM (4 days ago) Nov 13
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Steve,

Many thanks and especially for supporting my memory that there wasn't a conclusive end to the discussion. 

My instincts are just to do it and put the RSGB project forward as an example where it was allowed. 

John
M0WIV 

Steve

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Nov 13, 2025, 5:50:37 PM (4 days ago) Nov 13
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My view would be no - to me this seems 1 step further than the RSGB LoRa APRS example - where in that case you might argue that the downlink is merely a LE copy of amateur radio traffic.  In this case it seems to be the origin of the amateur radio traffic. 

Are the iGates going to repeat packets locally too?  if so this could bee seen as relaying a non amateur radio message to amateur radio. 

If OFCOM want folk to use the LE portion of 70cms for amateur radio they should put it in the licence with a frequency and power limitation to match.

    Steve G8KHW

David Brooke

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Nov 13, 2025, 6:00:38 PM (4 days ago) Nov 13
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On Thu, Nov 13, 2025 at 10:39:11PM +0000, John Laidler wrote:
>
> My instincts are just to do it and put the RSGB project forward as an
> example where it was allowed.

Their downlink was ISM, not amateur.

David

Steve

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Nov 14, 2025, 3:54:47 AM (4 days ago) Nov 14
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Agreed - I don't see you can draw any other conclusion.

I guess you can argue a case for Johns proposal in that it is license
exempt traffic that just happens to carry an amateur radio callsign -
and no problem if that is iGated to APRS.fi ('cos no part is going over
amateur radio).  But if the traffic was Digipeated (which also seems
part of LoRa APRS) then that would be relaying non amateur traffic over
amateur radio.  There would be nothing to stop a non amateur putting up
a balloon at the same time with an amateur looking callsign that was
then digipeated over amateur radio.

The whole thing is a can of worms that I wish the RSGB had not
initiated.  If UK amateurs want to do amateur radio from a balloon then
they now have some perfectly good other bands to do it on (2m etc.)

    Steve G8KHW

Ross G6GVI

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Nov 14, 2025, 6:02:44 AM (3 days ago) Nov 14
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Hi John, 
As the other correspondents have said, Amateur airborne operation is not permitted on 70cm - but if you'd like to try APRS, why not use FM-AFSK on 144.8? Several of the Polish pico flights have used this and been widely received while flying over the UK.
73 de Ross.

M5AKA

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Nov 14, 2025, 7:53:51 AM (3 days ago) Nov 14
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Steve, we did have a different of view on this last time.

You say “ A further question would be if balloon based APRS tracking could be used on LE 70cms frequencies and power levels.” 

The answer seems to me to be a clear yes, what aspect did you think might be problematic?

APRS is a classic example of one-way communications. 

Trevor




Steve

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Nov 14, 2025, 10:29:29 AM (3 days ago) Nov 14
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I covered this in my earlier email today.

The way I see it the downlink is either amateur radio traffic or its LE/ISM (it cant be both at the same time).  

If its Amateur its a contravention of the license conditions. If the traffic is LE/ISM the most obvious issue is if the traffic is APRS digipeated - as digipeating would be an amateur transmission repeating non-amateur traffic.  

In my mind the RSGB flight has set an example where amateurs now feel its all OK to use the LE portion of 70cms as if they were licensed to use it, as long as they stick within the LE frequency/duty cycle and power levels. 

Lets not beat about the bush - the real purpose here is to do amateur radio on 70cms airborne,  using LE in order to circumvent the UK amateur 70cms license conditions.  

    Steve  G8KHW

M5AKA

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Nov 14, 2025, 2:58:35 PM (3 days ago) Nov 14
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Yes I saw your subsequent email sometime after I posted my comment.

You say "The way I see it the downlink is either amateur radio traffic or its LE/ISM (it cant be both at the same time)."

I would say the Content of either transmission is irrelevant as long as it does not breach the Communications Act 2003 Section 127 and other language related legislation.  Amateur transmissions of course also have one additional restriction, the transmission is "not for commercial purposes of any kind".

Beaconing APRS transmissions are permitted in both LE and amateur transmissions

A transmission by a licence-exempt device can carry amateur radio traffic as there are No Content Restrictions on licence-exempt transmissions other than those stated above

I appreciate we have different views on this.

Trevor




Steve

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Nov 14, 2025, 4:57:06 PM (3 days ago) Nov 14
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I contend that an amateur radio station may only transmit/re-transmit amateur radio traffic - the stand out clauses in the amateur radio license in this respect are:


    "Making transmissions  19. Unless the Radio Equipment is being used for the purposes of clause 5 (disaster situations), the Licensee must ensure that

        a) Transmissions are only addressed to one or more amateur radio station(s);"


Gateway (“Gateway” means radio equipment for the purpose of connecting to other non-amateur networks.)

    14. The Radio Equipment may be used as a Gateway and may be operated (but not controlled) by other radio amateurs without supervision, providing that the Licensee

    d) takes all reasonable steps to ensure that the Gateway is only used by an Amateur;

Since a gateway is the bridge between amateur radio and non-amateur networks this clause seems to go further than simply ensuring transmissions are carrying amateur radio traffic, its ensuring that traffic received by the amateur station may only be forwarded to the non-amateur network (e.g. APRS-IS) if its from an amateur source.


Data station operation

    17. The Radio Equipment may be used as a Data Station and may be operated (but not controlled) by other radio amateurs without supervision, providing that the Licensee:

    e) takes all reasonable steps to ensure that the Data Station is only used by an Amateur;


Asking Chat GPT (what about UK amateurs re-transmitting non amateur radio traffic?):

Summary Answer to Your Question

  • No, UK amateurs can’t legally retransmit non-amateur radio traffic under their normal amateur licence.

  • The licence allows retransmission only of amateur-originated messages.

  • Running a system (repeater / gateway) that regularly repeats non-amateur content would violate the licence terms, and the station keeper could face licence revocation if they don’t control misuse.


    Steve G8KHW

Rick Hewett

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Nov 15, 2025, 6:26:58 AM (2 days ago) Nov 15
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On Fri 14 Nov Steve wrote:
> The whole thing is a can of worms that I wish the RSGB had not
> initiated. If UK amateurs want to do amateur radio from a balloon then
> they now have some perfectly good other bands to do it on (2m etc.)

Yeah, with the new licence conditions, the obvious amateur radio
approach would be to have the down-link on the 2-metre band using the
standard APRS transmission mode rather than LoRa for that down-link, and
making use of the higher power permitted by the amateur radio licence
for that down-link.

Of course that might make the payload a bit heavier, and since the
RSGB's flight there's been the UA1093 incident which has probably helped
underline the importance of the payload weight and density limits...

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73, Rick, M0LEP (aka lazyleopard on #highaltitude IRC)

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