Ofcom EMF Requirements – further LAA comment

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Steve Slater
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Joined: Thu Jan 01, 2009 4:57 pm

Ofcom EMF Requirements – further LAA comment

Post by Steve Slater » Fri Apr 16, 2021 5:46 pm

It is unfortunate that none of the sport flying organisations in the UK were made aware of two Ofcom consultations in 2020 on Electro Magnetic Fields from radio equipment until a number of licence holders were contacted in March 2021 telling them they may have to comply with new regulation. The LAA has been in contact with Ofcom’s technical and policy staff and we have formally requested in view of their flawed consultative process, that license amendment activities in association with aviation be deferred until appropriate impact assessment and mitigation reviews are carried out.

It is clear from our research that the risk to third parties from light aircraft radio transmissions is small. It is noteworthy that Ofcom wish to comply with advice from ICNIRP (the International Commission for Non-Iodising Radiation protection, now you ask). This was then interpreted by HSE as ‘appropriate guidance’. Ofcom then have sought to escalate this to a mandate by amending licence conditions. We have queried the basis for this.

At the same time we are now assisting Ofcom in achieving its desired aim of ensuring EMF protection by proportionate guidance based on the ICNIRP guidelines. In its current form, the proposed Ofcom requirements indicate that all equipment that transmits with an output power greater than 10W EIRP must be assessed.

As we discussed at a recent technical meeting between LAA Engineering and members of the Ofcom team, this impact would be mitigated by an amendment to requirements to state that only equipment with an output power greater than 10W EIRP after factoring for the amount of time transmitting within a 6 minute period, need be assessed. For a VHF transmitter this typically results in less than 10%, and 0.5% for a transponder.

Using these criteria virtually none of the installations in the recreational aviation fleet need further technical assessment.

We are now working with Ofcom to produce aviation-specific guidance for licence holders that will include practical, step-by-step instructions for demonstrating compliance, that will help members to achieve the anticipated requirements. We’ll keep all LAA members appraised of this and we'll ultimately produce an LAA Technical Leaflet for further guidance.

Stephen Slater

Ian Melville
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Joined: Mon Feb 11, 2008 7:21 pm

Re: Ofcom EMF Requirements – further LAA comment

Post by Ian Melville » Sun Apr 18, 2021 8:21 am

Good work Steve. Thanks for the update.
Ian Melville

Posts: 8
Joined: Mon Jan 28, 2013 8:41 am

Re: Ofcom EMF Requirements – further LAA comment

Post by alioth » Wed May 26, 2021 3:37 pm

Only the UK civil service could turn a guideline into hard regulation. :evil:

However, it is probably not particularly onerous for us: the transponder is probably the most powerful transmitter on our aircraft but it has a low duty cycle (0.5% or thereabouts). According to Ofcom's calculator, for something like a GTX335 you will need a 22cm separation from the antenna to the general public. With the typical antenna placement (under the fuselage) the general public won't get that close.

Worst case for the COM radio which is unlikely to have an average duty cycle of more than 10% in any 6 minute period, would be a 37cm separation from the antenna.

It's a lot more problematic for those of us who are into amateur radio and like doing things like Summits on the Air - we're now likely going to have to do paperwork every time we operate.

It's also about the "general public" (that's to say random people) who typically aren't allowed airside anyway and the general public aren't ever on our planes.
Dylan Smith

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