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Catriona Lawrence
Internal Reviewer
FOI Ref: 01296704
Internal Review ref: 01296704
Email:
xxxxxxxxxxx.xxxxxxxx@xxxxx.xxx.xx
Ian Hope
xxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxx.xxx
2 August 2021
Dear Mr Hope,
Internal Review: Call Sign Policy
Thank you for your email dated 17 July 2021, where you asked for an internal review of Ofcom’s
response to your Freedom of Information Act (‘the FOI Act’) request (ref: 01296704) dated 30 June
2021.
Background
Your FOI request
In your original request, dated 2 June 2021, you wrote the following:
Please list the Date when Ofcom changed published policy on re-issuing Amateur radio call
signs.
Previously the RA, then Ofcom would only permit a previously issued call sign to be given to
another amateur or a club, with written permission from the previous holder or the Previous
holders Family. This was Policy for a number of years
Now anyone can apply for a call sign that was previously held or issued, which means we
have recent licencees, Holding G3 call signs
When did Policy change, who agreed and why were us Amateurs not consulted on the
Change, it is a insult to Silent Keys and almost like Graverobbing that you hear Old call signs
on the Air and I urge Ofcom to reconsider Policy
Ofcom’s Information Request Team (‘the IR Team’) responded to your request on 30 June 2021. In
the letter it advised that it was unaware of Ofcom having ever applied a policy whereby a radio
station call sign may be assigned only with the consent of another party. It provided a link to
Ofcom’
s online guidance for licensees1, noting that paragraphs 1.16 to 1.18 describe the approach
taken in reusing old call signs.
1
https://www.ofcom.org.uk/__data/assets/pdf_file/0026/82637/amateur_radio_licence_guidance_for_license
es.pdf
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Your further request for clarification
On 30 June you responded to the IR Team from your personal email address, rather than your
‘whatdotheyknow.com’ email address. You suggested that they “look through the Old GPO and RA
records, before saying Ofcom has never had a Policy of asking for Permission to reuse call signs”. You
also advised that the process of requesting written permission from the previous holder, or their
family should they be deceased, had existed and been taught in Amateur Radio exams.
You received a further response from the Team on 14 July which was sent to your personal email
address. In this response it again advised that Ofcom held no record of such a policy. It did, however,
note that:
in 2006 a document was published indicating that, in some circumstances, Ofcom might seek
others’ agreement before al owing a call sign to be transferred from one licensee to another
but this was for the transfer of call signs, not their assignment. That document was
withdrawn some five years ago.
Internal review
Your request
Following this response of 14 July, you sent five further emails to the IR Team from your
‘whatdotheyknow.com’ email address. In the first of these emails, sent on 17 July, you submitted the
following request:
Would Like a Review as you have not replied to my request for you to go through the archives
and actually refresh your memory, As many amateurs have said it was policy and formed
part of the licence documents under the RA/GPO.
Go back read history, and realise what a huge mistake you have made.
In the second email, also of 17 July, you again suggested that the IR Team look in Ofcom’s own
archives where you claimed to have found a statement on the topic, published on 31 May 2006. This
statement, which you included in the body of the email, included the fol owing two points:
•
Ofcom wil transfer a call sign from one radio amateur to another radio amateur providing
that the call sign holder consents to the transfer. Ofcom wil require a letter of instruction
from the call sign holder as evidence of consent.
•
Ofcom wil also transfer a call sign from a deceased radio amateur to another radio amateur.
Ofcom wil require a letter of instruction from the call sign holder’s executor (or
administrator) as evidence of consent.
In the third, sent on 26 July, you provided a link to Ofcom’
s transfer of amateur radio call signs
policy2, published in 2006, which had been archived on the WayBack Machine, an internet archive
2 https://web.archive.org/web/20120713191813/https:/licensing.ofcom.org.uk/binaries/spectrum/amateur-
radio/guidance-for-licensees/amateur-radio-cal -signs/transfercal signs.pdf
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service. You then requested for your request to be answered, alongside a formal apology, by Friday
30 July as you considered that the IR Team had “had enough time to deal with this”.
Your final two emails of 29 and 30 July concerned your wish to receive a response to your request by
30 July and 6 August respectively.
My assessment
I can confirm that Ofcom does not hold the information you have requested. As advised by the IR
Team, this is because Ofcom has never applied a policy whereby a radio station call sign may be
assigned only with the consent of another party. In addition, we are unaware of any such policy
being applied by Ofcom’s immediate predecessor.
Having searched Ofcom’s website, I cannot find the information you provided in your second email
of 17 July. However, it does appear on an
amateur radio website3, which provides a link to an Ofcom
document that is no longer available on the Ofcom website. The relevant Ofcom colleagues have
advised that the missing policy is the same policy referred to in the IR Team’s email of 14 July, which
was published in 2006 and removed from the Ofcom website five years ago upon its retirement. This
is also the same policy (the transfer of amateur radio call signs policy) that you provided a link to in
your email of 26 July, which has been archived on the WayBack Machine.
As advised by the IR Team on 14 July, this policy indicated that “in some circumstances, Ofcom might
seek others’ agreement before allowing a call sign to be transferred from one licensee to another
but this was for the
transfer of call signs, not their
assignment”. I believe it would be helpful to
explain the difference between transfer and assignment in this context.
First, Ofcom’s approach to the assignment of call signs can be found in paragraphs 1.16 to 1.18 of
our
online guidance4. Following this approach, if an amateur radio licence is surrendered (including
cases where the previous holder has died), the call sign is retired and remains unavailable for two
years. Thereafter, a subsequent applicant for a licence may expressly request the call sign. If an
applicant does not request a particular call sign, they will be assigned the first available call sign in
the sequence for that class of licence.
Second, before its retirement, the transfer of amateur radio call signs policy allowed for a call sign to
be transferred between licensees without needing to be retired for two years, as set out above. This
was only allowed in exceptional circumstances and required a letter of instruction from the call sign
holder or, if deceased, their executor, as evidence of consent.
I appreciate you feel strongly about the recycling of call signs. However, call signs are a finite
resource and Ofcom must adopt policies that optimise the availability of this resource. I hope that
my above explanation assures you that, while Ofcom no longer allows call signs to be transferred,
3 http://www.amateurradio.eu/gm/licencing/transferring-cal signs.htm
4
https://www.ofcom.org.uk/__data/assets/pdf_file/0026/82637/amateur_radio_licence_guidance_for_license
es.pdf
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even with written consent, we do not reassign a call sign to a new licensee until a reasonable period
of time has elapsed.
Further considerations
If you have any queries, then please contact
xxxxxxxxxxx.xxxxxxxx@xxxxx.xxx.xx. Please remember
to quote the reference number above in any future communications.
Yours sincerely,
Catriona Lawrence
If you are not content with the outcome of the internal review, you have the right to apply directly to the Information Commissioner for a
decision. The Information Commissioner can be contacted at:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Your complaint should be raised within three months of your internal review.
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Document Outline