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Ofcom EMF Requirements - further LAA comment

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 licence 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-Ionising Radiation Protection, now you ask) which were initially just guidelines. These were 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 happy to assist 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 will ultimately produce (or amend) an LAA Technical Leaflet for further guidance.

Light Aircraft Association

16th April 2021

Photography (mostly) Neil Wilson

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