The Communicator Digital Edition: Off-Roading

The SARC Communicator [Excerpt]

Back to Basics – Sept/Oct 2020

From The Canadian Amateur Radio Basic Question Bank

There has been a great deal of discussion, confusion, and misinformation surrounding the legality of the off-road community using so-called LADD and RR frequencies while travelling the backcountry. Many of our SARC Basic class students take the course to become certified and are under the impression that having an amateur radio operator certificate gives them legal access to LADD and RR frequencies with amateur equipment. To shed some light on this oft discussed subject, and perhaps avoid forfeiture of equipment or a fine, this Communicator’s Back to Basics column offers an explanation.

The focus in this issue has two questions that apply. One has to do with the equipment, the other with the licencing or certification requirement:

Question B-001-006-006
Some VHF and UHF FM radios purchased for use in the amateur service can also be programmed  to communicate on frequencies used for land mobile service. Under what conditions is this permissible?

A. The equipment has an RF output of 2 watts or less
B. The equipment is used in remote areas north of 60 degrees latitude
C. The radio is certified under the proper Radio Standards Specification for use in Canada and is licenced by Industry Canada on the specified frequencies
D. The radio operator has Restricted Operator’s Certificate

And the second question:

B-001-006-005
Which of the following statements is NOT correct? A person may operate radio apparatus, authorized in the amateur service:

A. only where the person complies with the Standards for the Operation of Radio Stations in the Amateur Radio Service
B. only where the apparatus is maintained within the performance standards set by Industry Canada regulations and policies
C. except for the amplification of the output power of licence-exempt radio apparatus outside authorized amateur radio service allocations
D. on aeronautical, marine or land mobile frequencies

I will be quoting frequently from Innovation, Science and Economic Development Canada regulations and policies and will refer to them hereafter as ‘ISED’.

First some definitions…

Amateur Radio Service

Amateur radio service means a radiocommunication service in which radio apparatus are used for the purpose of self-training, intercommunication or technical investigation by individuals who are interested in radio technique solely with a personal aim and without pecuniary [monetary] interest.

An Applicable Basic Amateur Radio Certificate Restriction

According to Radio Information Circular (RIC) 3

4.4.1 Basic Qualification

The following privileges and restrictions are applicable to the Basic Qualification:

re-programming of radio equipment to operate in the Amateur Bands if this can be done by a computer program

Note: No physical modifications to the circuitry of the radio are permitted.

Land Mobile Service

Radiocommunications Regulations state:

Land mobile service means a radiocommunication service that provides for communications between mobile stations and

(a) fixed stations,
(b) space stations, or
(c) other mobile stations

Mobile Station

A Mobile Station is also defined on the ISED website as: “a radio station intended to be used while in motion and during stops.”

Commercial Licence Radiocommunication Services and Stations

Per the Canada Radiocommunications Regulations:

s.3 It is a term of a radio licence that the holder of the licence may

(a) install, operate or possess radio apparatus to perform any of the following services, as authorized by the radio licence, namely,

(i) aeronautical service,
(ii) amateur radio service,
(iii) public information service,
(iv) developmental service,
(v) fixed service,
(vi) intersatellite service,
(vii) land mobile service,
(viii) maritime service, and
(ix) radiodetermination service; and

(b) install, operate, or possess radio apparatus at a fixed station, mobile station or space station as authorized by the radio licence.

Mobile Stations s.60 (4)

The radio licence fee payable in respect of radio apparatus installed in a mobile station that operates in the land mobile service is the applicable fee set out in item 5 of Part I of Schedule III for all authorized transmit and receive frequencies.

s.63 The fee, for the applicable metropolitan or other area, set out in Part IV of Schedule III for each assigned transmit or receive frequency (Sections 56 and 60) Fee Schedule Applicable for a Mobile Station in any Service other than the Amateur Radio Service

Mobile station in the land mobile service – monthly $3.40 - annually $41.00

Licences, Certificates and Callsigns

The Amateur Radio Service requires the operator to hold an amateur radio operator's certificate. Traditionally, amateur radio operators were issued two separate authorizations: An Amateur Radio Operator Certificate and a radio station licence. The Amateur Radio Operator Certificate was issued for life and had no fee associated with it, while the radio station licence was issued on a yearly basis and a licence renewal fee was charged.

Effective April 1, 2000, ISED combined these documents into one authorization, the Amateur Radio Operator Certificate. This certificate is the sole authorization required to operate amateur radio apparatus in the amateur radio service. (It is no longer called a licence - Amateurs have a certificate to operate)

A callsign is assigned when you receive your amateur certificate. This is required for the purpose of station identification. For a fee, additional callsigns can be requested by contacting the Amateur Radio Service Centre. Your callsign covers all your base, mobile, and portable radios at that location, and allows you to operate within any of the amateur bands (frequency ranges) for your certification class. Fixed stations at separate locations require a separate callsign for station identification.

A radio operator certificate is required only in the aeronautical service, maritime service, and the amateur radio service. (per s.33 of the Radiocommunications Regulations). A radio operator certificate is not required in the Land Mobile Service but each radio requires a separate licence (callsign); this is different than your Amateur certificate. So, if you own a mobile and a portable used on a commercial band, you would require two licences. You pay per radio, not per frequency in the radio, but each frequency in the radio must be listed on that radio's licence.

‘Type-Approved’ Radio Equipment

Contrary to Amateur Radio, commercial radio is pre-programmed to operate on specific frequencies and cannot be user programmable. So, you cannot actually "attempt" to transmit on an amateur frequency if it does not already exist in the radio. Commercial radio equipment must pass testing to ensure it does not create interference and is compliant with both ITU and Canadian regulations. This is referred to as being “type-approved”. Radio equipment is approved according to the bands and purpose for which it is marketed, and a lower standard exists for amateur equipment than commercial. Unlike Amateur Radio, where we can choose our own frequency to operate (if it is within an Amateur band), commercial radios are not permitted to be frequency-agile. For example, a trucker cannot one day decide to set up a talk channel on a frequency that is not already designated and licenced by ISED for trucking. Commercial radios modified to be programmed by the operator in the field are not type-approved and can not legally be used on commercial frequencies.

A commercial VHF radio’s frequency range will typically be capable of covering all or a portion of the amateur VHF band. The amateur VHF band is 144-148 MHz; you will find commercial radios with ranges of 136-174 MHz, 146-174 MHz, 136-152 MHz, or similar. So amateur frequencies CAN exist in a commercial radio, but they would have to be programmed in and the operator licenced to use them in a specific band.

Surplus and new commercial radios are readily available and may be programmed and used by amateur radio operators within the amateur bands for which YOU are certified. If you are an amateur radio operator and have a licence for your commercial radio, you can have your commercial frequencies and your amateur frequencies in the same commercial VHF radio, but they must be professionally programmed to avoid errors.

VHF and UHF commercial gear is better quality because they have more stringent specifications than amateur radios and have minimal operator controls for ease of use, typically only an on/off and volume control, squelch, and a channel selector.

One more caveat. Since 1997 narrow band equipment has been implemented in North America for VHF commercial radio equipment. This means that twice as many channels can be assigned as each channel takes up only half the bandwidth. Channels are now specified narrowband (11 kHz) with a maximum transmitter power of 30 watts, or as otherwise indicated. Amateur radio equipment is not narrow-band and causes interference on narrow-band channels. This is one of the reasons Amateur radio equipment is not permitted on commercial frequencies. If you buy an older commercial radio it may not be narrow band and would no longer be type-approved for certain commercial frequencies.

So, amateur radios cannot be used to transmit on commercial frequencies, in part because they do not necessarily meet the specifications required for use in the commercial (land mobile) radio service, and in part because ISED does not want commercial users to be able to program frequencies on the fly, generally assuming that the commercial users are not radio hobbyists and therefore would not have the knowledge to correctly program a radio.

Lastly, it is not illegal to program an amateur radio to receive outside of the amateur band, or possess such a radio if you have a licence, but it's illegal to use it to transmit outside of the amateur band. Some amateur radios come from the factory able to transmit outside of the amateur bands, but this is not ISED approved.

LADD Frequencies

In Canada, the LADD (or LAD) VHF channels (Logging ADministration Dispatch) were originally intended for commercial trucking, general communications in forestry & logging, heavy mining, and exploration and petroleum. These are also known in Western Canada as the "Opens". Their use is governed by Industry Canada and require a licence and compliant, type-approved radio equipment. Click here for info about ISED licencing.

Due to the wider availability of low cost amateur VHF FM radios and the decline of CB Radio, recreational users have adopted them for back country communications and, for those who do not have reliable cellular service, especially survivalists and preppers, they are marketed as an essential communication resource. Users of LADD channels require commercial type-approved equipment and require a corresponding licence for the radio – NOT AN AMATEUR RADIO LICENCE (or certificate) to comply with the regulations. Also, in keeping with Spectrum Canada regulations, it is important to note that there are geographic restrictions where LADD channels can be used to prevent interference to adjacent users.

ISED has approved four LADD channel frequencies for radio licencing. Companies or individuals with only one or two radios no longer have to wait for a letter of permission from an existing radio channel holder in order to licence their radios. Their radio supplier can apply with ISED on their behalf for the use of 154,100Mhz (Ladd-1), 158.940Mhz (Ladd-2), 154.325Mhz (Ladd-3) and 173.370Mhz (Ladd-4) in their ISED approved commercial VHF radios. Larger companies may apply for a commercial (shared) channel frequency if they have many mobile vehicles needing to be dispatched from an office base station.

For legacy compatibility, LADD1-LADD4 channels use normal FM (FM is +/-5 kHz deviation, bandwidth 16 kHz, max bandwidth 20 kHz), while most of the other channels increasingly use Narrow NFM (NBFM is +/-2.5 kHz deviation, bandwidth 11 kHz, max bandwidth 11.25 kHz). Normal FM has slightly longer range than Narrow FM (see the RadioMaster article FM versus NFM for Best Radio Communications). If you are using NFM and reception is loud and distorted, try FM instead.

Resource Roads

Background

Mobile radio communication on resource roads had been historically highly variable across the Province of British Columbia (BC) for a multitude of reasons:

Road users were required to know unwritten local protocols
Heavy radio traffic caused overlapping calls and interference
Radios had to be reprogrammed to local channels with each location change
Road signage was inconsistent and unclear

A standard mobile radio communications protocol was developed to standardize and simplify, and thus make travel on resource roads safer.

Refer to the ISED page RR — British Columbia Resource Road Channels

ISED RR channels are specified narrowband (11 kHz) with a maximum transmitter power of 30 watts, or as otherwise indicated. These channels must only be used in locations where it is specifically posted for usage. Improper usage, for example "chit chat", will result in harmful interference to other resource road and loading usages or to other priority radio spectrum users. All channels are designated such that they cause no interference to other users and must accept interference from other priority users.

Mobile Radio Station Licence Application

In the Province of British Columbia, Resource Roads are typically one or two-lane gravel roads built for industrial purposes to access natural resources in remote areas. Over 620,000 kilometers of roads on the British Columbia landbase are considered resource roads.

Two-way radios using these channels require a mobile radio licence. The use of amateur, marine or user programmable radios is not permitted.

The BC Forest and Range Practices Act regulates the use of these roads and radio communications. Outside BC check your applicable legislation.

FOREST SERVICE ROAD USE REGULATION [current to 2020-07-28]

Use of 2-way radio

s.5 (1) A driver on a forest service road who uses a 2-way radio to communicate with other drivers on the road must announce, in accordance with any road markers posted at intervals along the road,

(a) his or her position, and
(b) the branch of the road being travelled if the radio's signal can be received on more than one adjacent branch of the road.

(2) Subsection (1) applies to a driver only if

(a) the driver uses a radio frequency provided by the holder of a private commercial radio station licence, or other licence under the Radiocommunication Act (Canada) and the regulations under that Act, to communicate with the other drivers, and
(b) the forest service road is posted with a sign that indicates the radio frequency that is to be used.

[Editor’s note: This legislation says ‘MUST announce, in accordance with any road markers’ and appears to make it illegal for anyone without proper communications – i.e. a licenced commercial type-approved radio with programmed RR channels, to drive on a Forest Service Road if marked with RR signage.]

Liability insurance

s.12 (1) A person must not operate or cause to be operated a motor vehicle or trailer, other than a motor vehicle or trailer described by section 2 (5) of the Motor Vehicle Act, on a forest service road unless

(a) the driver, motor vehicle and trailer are insured under a valid and subsisting contract of accident insurance providing insurance against liability to third parties in the amount of at least $200 000, and

(b) the driver carries written evidence, supplied by the insurer, of the insurance referred to in paragraph (a), or a copy of that written evidence, and produces it, on demand, to a peace officer or an official.

(2) Motor vehicles operated by the government that are subject to a government self-indemnification plan are exempt from the requirements of subsection (1).
[am. B.C. Reg. 354/2004, Sch. B, s. 2.]

[Editor’s notes: For clarity, the insurance exemption under section 2 (5) of the Motor Vehicle Act referred to above is for farm implements.

If travelling on a Resource Road the vehicle or trailer must have third-party liability insurance of minimum $200,000 and proof must be carried and shown if requested by a peace officer or official.

A reminder also that anyone operating two-way radio equipment is subject to any applicable distracted driving legislation that may be in force.]

Offence

s.13 (1) A person who contravenes section 3 (3), 5 (1), 6 (5), 10 (1) or 11 (1) or (3) commits an offence and is liable on conviction to a fine not exceeding $5 000 or to imprisonment for not more than 6 months or to both.

(2) A person who contravenes section 4, 6 (3) or (4), 7, 8 or 12 (1) commits an offence.

Resource Road User Safety Recommendations

http://www.bcforestsafe.org/files/tk_pdfs/gde_resrd.pdf and Resource Road Radio Communications

Government in collaboration with industrial and other stakeholders has moved forward with implementation of standard radio communication protocols on Forest Service Roads (FSR) and other natural resource roads across the province. FSRs with industrial activity and many other resource roads have adopted and are using the standard protocols which consist of:

standard call protocols - call content and order
standardized signage
dedicated, standardized bank of resource road radio channels

The standard bank of resource road mobile radio channels is available, to those with applicable [NOT Amateur] mobile radio licences, for programming at local commercial mobile radio shops.

It is important to note that not all resource roads have adopted the protocols and standard bank of resource road radio channels. It is recommended that road users retain current radio frequencies until such time that they are sure they are no longer required.
Most resource roads are "radio assist" and use of mobile radios for communicating location and direction is not mandatory. Always drive safely according to road and weather conditions and if using a mobile radio, do not solely rely on mobile radio communications recognizing that not everyone has or is using a mobile radio.

In the transition to new resource road radio channels and communications protocols, resource road users are advised to exercise additional caution when traveling on resource roads. Drive safely according to the road conditions and weather at all times. This should be communicated by employers to all their affected employees and contractors.

Most Forest Service Roads and natural resource roads are radio-assisted, but not all roads are radio-controlled. Road users are reminded not to drive exclusively according to the radio. Where posted, road users using mobile radios must use the posted channels and call protocols.

Channel Maps

A standard bank of resource radio channels has been provided by Innovation, Science and Economic Development Canada (ISED) for dedicated use for mobile radio communications on resource roads in BC. By agreement, the Ministry of Forests, Lands and Natural Resource Operations is responsible for administering the use of the standard bank of resource road radio channels in BC.

The standard bank of resource road radio channels has been distributed across the B.C. landscape to minimize the likelihood of interference. Channel assignment maps have been developed, and periodically are changed, to reflect channel assignments as planning tools. The maps should not be relied upon for appropriate channel selection in the field as in some cases, the channel assignments have not been implemented on the ground. The radio channel signage in the field will always govern over the maps. See the mobile resource road radio planning maps:

Resource Road Radio Channel Planning Maps

Best management practices for mobile 2-way radio use on resource roads in BC, installation and maintenance

Radio requirements on BC resource roads (and elsewhere) will be for narrow-band communications. Radios manufactured after 1997 have this capability but older radios may only communicate with wideband transmissions. Wideband transmissions sound overly loud when received by narrowband radios and narrowband calls received by these radios may sound too quiet. Wideband radios should be replaced with newer, narrowband capable radios.

FRS, GMRS and Other Common Non-Amateur Frequencies

It should be no surprise to you that the licence exempt radios marketed for these bands are very low power and have narrow channel spacing. Licence exempt devices include cordless telephones, baby monitors, family radio service (FRS) walkie-talkies, remote garage door openers, or wireless local area networks. Although licence-exempt radio devices generally transmit signals at low-power levels, the power level alone does not determine if a licence from Industry Canada is required. By law, licence exemptions only apply to radio equipment that has been tested and certified to comply with specific technical standards and operates in specially designated frequency bands.

For the General Mobile Radio Service (GMRS) in Canada transmit power is capped at 2 watts by law, while the units sold in US can operate at 5 watts. Everything else is the same - frequencies and the communication standard. One needs a BS licence to operate a GMRS radio in the States (easily obtainable by anyone and does not require any test), but no licence is needed in Canada.

These devices may not be modified or fitted with different antennas. It is NOT permissible for you to transmit on any of these channels with your amateur equipment as you will exceed power and/or bandwidth limits. As with other frequencies, you may monitor them as receive only.

The answers to our original questions

Some VHF and UHF FM radios purchased for use in the amateur service can also be programmed to communicate on frequencies used for land mobile service. Under what conditions is this permissible?

C. The radio is certified under the proper Radio Standards Specification for use in Canada and is licenced by Industry Canada on the specified frequencies

You can wade through RSS-119 — Radio Transmitters and Receivers Operating in the Land Mobile and Fixed Services, but it all boils down to: “The radio is certified under the proper Radio Standards Specification for use in Canada and is licenced by Industry Canada on the specified frequencies.”

And the answer to the second question

Which of the following statements is NOT correct? A person may operate radio apparatus, authorized in the amateur service:

D. on aeronautical, marine or land mobile frequencies
You are certified to operate ONLY on the frequencies assigned to the Amateur Service. This means “on aeronautical, marine or land mobile frequencies” is incorrect.

So there it is. I’m not preaching but, as a Basic Amateur Radio course instructor, simply passing along the existing regulations and policy to answer the question that come up in every class. These rules exist for a purpose. Do with it as you will but be aware that there is enforcement and you are subject to the penalties if you are caught.

~ John VE7TI

Thanks to Kasun Somaratne (ISED) for the review of this article to confirm it reflects current ISED policy and regulation.

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