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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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
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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
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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?):
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
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