Radiocommunications (Communication with Space Object) Class Licence 2025

Several defined terms are central to understanding the scope and operation of this class licence. Station is defined in the Act, but the instrument adopts the broader definition used in the Radiocommunications Act. Space object is also defined by reference to a determination under section 64(1) of the Australian Communications and Media Authority Act 2005. The class licence only authorises communication with stations on space objects that are themselves properly licensed under a space licence or space receive licence - not any arbitrary satellite. This creates a chain of authorisation: the space‑object station must have its own licence before the earth station can rely on the class licence.

Device compliance day is a critical date that determines which equipment standards or equipment rules apply. Under section 5, it is the later of the day the station was manufactured (if in Australia), the day it was imported, or the day it was altered or modified in a material respect in Australia. Section 9 then requires that equipment comply with either the applicable standard in force on that day (if before 17 June 2021) or the applicable equipment rules in force on that day (if on or after 17 June 2021). This transitional arrangement exists because the Radiocommunications Legislation Amendment (Reform and Modernisation) Act 2020 replaced the older standards regime with equipment rules from 17 June 2021. Operators with older equipment may still rely on the original standards, provided the device compliance day is before that cut‑off.

Occupied bandwidth is defined as the width of a frequency band necessary to contain 99% of the true mean power of a transmitter’s emission. This term appears in the 26 GHz band constraints in section 10(9), where certain guard bands are calculated as the greater of 50 MHz or twice the occupied bandwidth above a band edge. This matters for earth stations in or near spectrum licence areas in the 27.5‑28.3 GHz range.

The 26 GHz band spectrum licence area is defined by reference to RALI SM 26, which contains Hierarchical Cell Identification Scheme (HCIS) area descriptions for 25.1‑27.5 GHz. But note the class licence uses the term only for the 27.5‑30 GHz transmission band. The HCIS itself is part of the Australian Spectrum Map Grid, which is a geographic scheme for describing radio licensing areas.

The ARPANSA Standard is the Radiation Protection Standard for Limiting Exposure to Radiofrequency Fields - 100 kHz to 300 GHz (2021), or any later replacement. Section 9(2) makes compliance with the general public exposure limits in that standard a condition of operating under the class licence. This is a binding occupational health and safety condition that applies to any accessible place, not just the station operator’s own site.

Other important concepts include ITU‑R Resolution 169 (WRC‑19) , which specifies power flux density limits for aeronautical earth stations in motion in the 27.5‑28.1 GHz band within 26 GHz band spectrum licence areas (section 10(10)). Area‑wide receive licence and point to point station are terms defined in a separate determination under the ACMA Act; they affect interference protection assumptions (sections 10(2) and 11). Metropolitan area takes its meaning from the Radiocommunications (Mobile‑Satellite Service) (1980‑2010 MHz and 2170‑2200 MHz) Frequency Band Plan 2022, which imposes tighter constraints on the 2005‑2010 MHz band when operated in a metropolitan area (section 10(8)).

The class licence directly affects any person or entity that operates a radiocommunications station on Earth (including land, aircraft, and ships) for the purpose of communicating with a satellite or other space object. This includes commercial satellite operators, teleport operators, satellite‑based broadband providers, earth observation companies, aeronautical and maritime satellite terminal operators, and hobbyists or researchers using small satellite ground stations. Because the licence is a class licence, it applies automatically to anyone meeting its conditions; there is no need to apply or pay a fee to the ACMA.

The licence excludes stations located on space objects themselves, so satellite owners still need individual space licences or space receive licences for their spacecraft. It also excludes stations that already hold an apparatus licence authorising substantially the same purpose; such stations remain under the terms of that apparatus licence. This means a person who previously paid for an apparatus licence for satellite communications cannot simply switch to the class licence unless they surrender that apparatus licence. In practice, operators who already have an apparatus licence for the same purpose will need to assess whether the class licence conditions are less restrictive; if so, they may choose to let the apparatus licence lapse.

The instrument particularly affects operators in or near 26 GHz band spectrum licence areas. Those areas are defined by RALI SM 26 and cover parts of the 25.1‑27.5 GHz band but are relevant for the 27.5‑30 GHz transmission band under this licence. Spectrum licensees in those areas have paid for exclusive access, and the class licence imposes specific power limits and guard bands to protect them. Additionally, radio astronomy observatories near the frequencies of 1610‑1626.5 MHz, 1660‑1675 MHz, and the 1668‑1670 MHz band are affected: the instrument restricts operations within 20 km or 500 km of observatories listed in Australian footnote AUS87, and requires operators to seek advice from observatory operators.

Aircraft and ship operators are also affected. The licence authorises airborne operation in the 27.5‑28.3 GHz band only if the transmitter does not exceed the power flux density limits from ITU‑R Resolution 169 for aeronautical ESIMs (section 10(10)). Ships operating in the same band must not exceed a power flux density on shore of -112.2 dBW/m²/MHz at 30 metres above ground level within a 26 GHz band spectrum licence area (section 10(11)). These conditions limit the ability of mobile satellite terminals to operate while moving.

The instrument also affects operators of point‑to‑point stations in the 10.7‑11.7 GHz, 18.2‑18.8 GHz, and 19.3‑19.7 GHz receive bands. Under section 11, earth stations in those bands receive no protection from interference caused by point‑to‑point stations; this places the risk of harmful interference on the satellite receiver operator. Similarly, Note 1 to section 10 states that stations authorised by this class licence will not be afforded protection from interference from other radiocommunications services.

The class licence confers the right to operate a station for the specified satellite communication purposes without an individual licence, provided all conditions are met. The right is conditional and revocable if the operator fails to comply with any condition.

The primary duties are set out in sections 8 through 11. First, the station must operate only in the listed frequency bands in section 8: transmission bands are 148‑150.05 MHz, 399.9‑400.05 MHz, 1610‑1660.5 MHz, 1668‑1675 MHz, 2005‑2010 MHz, 14‑14.5 GHz, and 27.5‑30 GHz; reception bands are 137‑138 MHz, 400.05‑400.15 MHz, 400.15‑401 MHz, 1518‑1559 MHz, 1613.8‑1626.5 MHz, 2195‑2200 MHz, 2483.5‑2500 MHz, 10.7‑12.75 GHz, and 17.7‑20.2 GHz. The band limits are inclusive of the upper frequency but exclusive of the lower frequency (section 5(2)), which is an important technical detail for emissions at the band edges.

Second, the equipment must comply with the applicable standard or equipment rules as at the device compliance day. For devices with a compliance day before 17 June 2021, the old standard (as defined by the Act before the 2020 amendment) applies. For devices on or after 17 June 2021, the equipment rules apply. This imposes a duty on operators to know the compliance history of their station. Furthermore, the electromagnetic energy emitted must not exceed the general public exposure limits in the ARPANSA Standard in any place accessible by the public (section 9(2)). This duty does not just apply to the operator’s own premises; it covers any area where a member of the public might be, such as near an antenna mounted on a rooftop or on an aircraft.

Third, the station must not interfere with the operation of any radiocommunications receiver (section 10(1)). This is a broad negative duty. However, section 10(2) provides a limited safe harbour: operation is taken not to interfere with an area‑wide receive station in the 27.5‑28.1 GHz band if it is outside a 26 GHz band spectrum licence area, or in the 28.1‑29.5 GHz band generally. This means operators in those bands and areas can assume no liability for interference to those specific receivers, but interference to other receivers is not excused.

Fourth, there are several specific duties in relation to radio astronomy. For the 1610‑1626.5 MHz and 1670‑1675 MHz bands, operators within 20 km of a listed radio astronomy observatory must first seek advice from the observatory operator about when to operate to minimise interference risk, and then operate consistently with that advice (section 10(3)). For the 1660‑1660.5 MHz and 1668‑1670 MHz bands, operation is not authorised at all within 500 km of such an observatory, nor on board an aircraft in the air (section 10(5)). There is also a specific power limit for the 1673.38‑1675 MHz band: emissions must not exceed -128.1 dBm/4 MHz for more than 20% of the time at the output of an earth receive licence antenna (section 10(6)).

Fifth, for the 2005‑2010 MHz band, the transmitter must not be airborne (section 10(7)(a)), and out‑of‑band emissions must not exceed -66 dBW EIRP per MHz above 2010 MHz. In a metropolitan area, the EIRP per MHz is capped at 0.5 dBW, the duty cycle at 1% averaged over 15 minutes, and each transmission at 4 seconds maximum (section 10(8)). These are severe constraints that likely make this band unsuitable for many commercial uses, especially mobile.

Sixth, for the 27.5‑28.3 GHz band on land, there is a complex set of geographic and frequency constraints tied to 26 GHz band spectrum licence areas and the 27.5‑28.1 GHz boundary. Operators must avoid operating in the 27.5‑28.1 GHz portion if inside a 26 GHz band spectrum licence area, or observe guard bands (50 MHz or twice occupied bandwidth) above 28.1 GHz within such areas. They must also limit EIRP to the horizon within 30 km of a 26 GHz band spectrum licence area. The instrument also references the Australian Radio Quiet Zone Western Australia Frequency Band Plan 2023; operation inconsistent with that plan is not authorised. Section 10(12) and Note 3 indicate that the ACMA will consider objections from the Murchison Radioastronomy Observatory when enforcing section 197 of the Act (reckless interference) within the inner quiet zone.

Finally, section 11 imposes a negative right: in the receive bands of 10.7‑11.7 GHz, 18.2‑18.8 GHz, and 19.3‑19.7 GHz, the station is not protected from interference by point‑to‑point stations. This means satellite operators in those bands must accept the risk of interference from fixed microwave links that are individually licensed. This is a cost‑bearing duty: the operator has no right to claim interference protection.

The class licence itself does not create offences. Instead, it relies on the enforcement provisions of the Radiocommunications Act 1992. If a person operates a station under the class licence but fails to comply with any of the conditions in sections 8 to 11, the station is not authorised by the class licence. That means the operation becomes unlicensed, which is a serious matter under the Act.

Section 197 of the Act makes it an offence for a person to engage in conduct that causes substantial interference with, or substantial disruption or disturbance of, radiocommunications, if the person is reckless as to that consequence. The penalty for such an offence can include significant fines and, in some cases, imprisonment for individuals. For corporations, the penalty can be very large. The note to section 10(12) indicates that the ACMA will take into account objections from the Murchison Radioastronomy Observatory in administering section 197 within the inner quiet zone, which suggests a higher risk of enforcement action if the observatory objects.

Non‑compliance with the equipment rules condition in section 9(1) could also lead to enforcement action under Part 4.1 of the Act (equipment compliance). The ARPANSA Standard condition in section 9(2) is not just a radiocommunications law issue; it may also trigger state or Commonwealth occupational health and safety laws if public exposure limits are exceeded.

The class licence imposes strict liability: there is no need to prove intention for the conditions themselves to be breached. If an operator inadvertently operates outside the authorised bands or exceeds an EIRP limit, the authorisation is lost. The operator may then be charged with operating without a licence, which is a separate offence under section 46 of the Act (unlicensed operation). Penalties for unlicensed operation can be up to 2 years imprisonment or fines up to 500 penalty units for individuals, or 5 times that for corporations.

Enforcement is also possible through civil penalties under the Act. The ACMA can issue infringement notices for certain contraventions, seek injunctions, or take other regulatory action. Because the class licence applies to a large number of operators without individual registration, enforcement may be triggered by complaints from other spectrum users, such as spectrum licensees in the 26 GHz band, radio astronomy observatories, or point‑to‑point station operators experiencing interference. The burden of proof of compliance falls on the operator, as the class licence is the source of authorisation and the operator must be able to demonstrate that its station meets all conditions.

An important practical penalty risk is the loss of protection from interference. As Note 1 to section 10 makes clear, stations under this class licence are not protected from interference from other services. That is not a penalty per se, but it represents an economic penalty: the operator bears the cost of mitigating interference without recourse to the ACMA.

The class licence sits within a web of Commonwealth radiocommunications law. It is made under section 132 of the Radiocommunications Act 1992, and therefore must be read consistently with that Act. The Act itself defines key terms used in the licence, such as apparatus licence, equipment rules, frequency band, and so on. The licence also references the Radiocommunications (Australian Radio Quiet Zone Western Australia) Frequency Band Plan 2023 and the Radiocommunications (Mobile‑Satellite Service) (1980‑2010 MHz and 2170‑2200 MHz) Frequency Band Plan 2022. Operations that conflict with those plans are not authorised.

The licence incorporates the ARPANSA Standard by reference, which is a non‑legislative document published by a Commonwealth agency. This means the radiofrequency exposure limits become legally binding conditions of the class licence. The standard itself may be updated from time to time, and the licence automatically refers to the later standard (section 5 definition of ARPANSA Standard). This dynamic reference ensures that exposure limits track current science, but also means operators must keep abreast of changes to the standard.

The licence interacts with apparatus licensing in two ways. First, some stations are excluded from the class licence if they hold an apparatus licence for substantially the same purpose (section 7(2)(b)). Second, the interference protection rules distinguish between stations operating under different licence types. For example, section 10(2) exempts interference to area‑wide receive stations (which operate under area‑wide receive licences) in certain circumstances, and section 11 removes protection from point‑to‑point stations (which operate under apparatus licences). This creates a hierarchy: apparatus licensees generally have stronger interference rights than class licence operators.

The licence also interacts with the spectrum plan, which is a legislative instrument that divides the radiofrequency spectrum into bands and allocates services. The licence references Australian footnote references AUS87 in the spectrum plan, which identifies radio astronomy observatory sites. Operators must locate those sites to comply with distance constraints.

International instruments are imported via ITU‑R Resolution 169 (WRC‑19). That resolution is a non‑binding ITU recommendation, but the class licence makes it binding for aeronautical ESIMs in the 27.5‑28.3 GHz band. Operators engaging in airborne satellite communications must therefore adhere to the power flux density limits set by that resolution.

The definition of aircraft is taken from the Civil Aviation Act 1988, which provides a broader meaning than the Radiocommunications Act. This means the licence covers unmanned aerial vehicles and other aircraft under civil aviation law, potentially including drones that carry satellite communication payloads. The note to section 5 highlights this difference.

The class licence also interacts with state and territory laws regarding radiofrequency exposure, workplace health and safety, and planning laws for antenna placement. While the class licence sets federal conditions, compliance with the ARPANSA Standard may overlap with state OH&S obligations.

This instrument is new: it is the Radiocommunications (Communication with Space Object) Class Licence 2025. It repeals and replaces the Radiocommunications (Communication with Space Object) Class Licence 2015 (F2015L01486). The source text does not include a detailed comparison between the 2015 and 2025 versions, and this analysis cannot invent amendment details. However, several structural features indicate changes from the previous instrument.

The 2015 licence would have been made under section 132 of the Act as well, but the 2025 version reflects legislative updates to the Act, particularly the transition from standards to equipment rules that occurred with the commencement of Part 1 of Schedule 4 to the Radiocommunications Legislation Amendment (Reform and Modernisation) Act 2020 on 17 June 2021. Section 9(1) of the 2025 licence explicitly addresses this transition, which was likely absent or handled differently in the 2015 licence. The 2025 licence also references the ARPANSA Standard 2021 rather than an earlier edition.

Another likely change is the inclusion of the 26 GHz band constraints relating to spectrum licence areas. The 2015 licence would have predated the widespread rollout of 26 GHz spectrum licensing, and the new conditions in section 10(9) (guard bands, EIRP limits) are designed to protect those licensed services. The 2025 licence also integrates ITU‑R Resolution 169 (WRC‑19), which was adopted at the 2019 World Radiocommunication Conference, so it was not in force when the 2015 licence was made.

The 2025 licence also references the Radiocommunications (Australian Radio Quiet Zone Western Australia) Frequency Band Plan 2023, which replaced an earlier quiet zone plan. The 2015 licence would have referenced the earlier plan.

The frequency bands themselves appear similar to the 2015 licence in broad terms, but the 2025 version has been updated to align with current spectrum allocations. The reception band of 400.15‑401 MHz (section 8(b)(iii)) and the transmission band of 27.5‑30 GHz (section 8(a)(vii)) may have been expanded or refined.

Importantly, the 2025 licence came into effect the day after registration, with no transitional period. Operators who were relying on the 2015 licence needed to ensure they complied with the new instrument immediately upon commencement. The repeal of the 2015 licence is clear: section 4 states it is repealed.

The amendment history also includes the references to other instruments as in force from time to time (section 6). This means the class licence is a living instrument that will automatically incorporate future changes to the ARPANSA Standard, RALI SM 26, ITU‑R resolutions, and frequency band plans, without requiring a formal amendment of the class licence itself. This reduces regulatory lag but increases uncertainty for operators, who must monitor external instruments for changes that alter their compliance obligations.

The source instrument does not mention any litigation. There is no reference to court cases, decisions of the Administrative Appeals Tribunal, or ACMA review proceedings within the text of the class licence. This is expected because a legislative instrument of this type typically does not recite its litigation history.

However, it is possible that the predecessor 2015 class licence was the subject of legal proceedings or ACMA enforcement actions, but the source does not provide that information. This analysis can only state what is in the source: no litigation is referenced.

That said, class licences in general can give rise to litigation, especially in disputes over interference or the scope of authorisation. For example, a person may challenge an ACMA enforcement action on the basis that they were operating within the class licence conditions. Conversely, a third party (such as a spectrum licensee) may seek judicial review if they believe the ACMA failed to enforce the conditions adequately. The class licence could also be challenged as ultra vires the Act if it is argued that section 132 does not authorise certain conditions. No such cases are recorded in this source.

The instrument’s safe harbour in section 10(2) (deemed non‑interference with area‑wide receive stations) could be tested in court if an area‑wide receive station operator claims actual interference. Similarly, the advice‑seeking requirement for radio astronomy observatories (section 10(3)) could lead to disputes about what constitutes adequate advice or compliance.

The note to section 10(12) suggests that the ACMA has an internal policy about considering observatory objections in enforcement of section 197. That policy might be challenged in a merits review if the ACMA takes enforcement action based on the observatory’s objection.

Given the instrument is new in 2025, there is no litigation history specific to this instrument. The only authoritative statements about its meaning will come from the ACMA’s regulatory guidance and any future court decisions.

Several provisions in this class licence can catch out unwary operators. The first is the non‑protection from interference. Note 1 to section 10 states plainly that stations authorised by this licence will not be protected from interference caused by other radiocommunications services. This is a departure from the usual approach in apparatus licensing, where licensees can expect some degree of interference management. Here, operators accept all risk. If a new licensed service starts up and causes interference, the class licence operator has no right to complain to the ACMA. This is a significant commercial risk for satellite services that require high reliability.

The second gotcha is the exclusion in section 7(2)(b): stations authorised by an apparatus licence for substantially the same purpose cannot use the class licence. An operator who holds an apparatus licence for satellite communication but wants to switch to the class licence must first surrender the apparatus licence. If they do not, they are not authorised by either licence for the same purpose? Actually the apparatus licence authorises them, but they cannot rely on the class licence. The risk is that if they inadvertently rely on the class licence while holding an apparatus licence, they may be operating outside the apparatus licence conditions? The class licence excludes them, so they need to be careful.

Third, the definition of device compliance day is the later of manufacture, import, or material alteration. If an operator modifies a station in a material respect (e.g., upgrades a transmitter module), the device compliance day resets to the day of modification. This could trigger a requirement to comply with newer equipment rules, potentially rendering older equipment non‑compliant if the modification was not done under the applicable equipment rules. Operators should document all modifications and reassess compliance.

Fourth, the ARPANSA exposure limits apply not just at the antenna but “in a place accessible by the public.” This includes areas that the public could access, not just where they are likely to be. A station on an aircraft or ship could expose passengers or crew, who are not the general public? But the standard uses “general public exposure limits” which are lower than occupational limits. The class licence does not reference occupational limits, only general public limits. This may be stricter than necessary for operators who are themselves professionally exposed, but the condition is clear.

Fifth, the 2005‑2010 MHz band in metropolitan areas is heavily restricted: EIRP of 0.5 dBW/MHz, 1% duty cycle, 4 second transmissions. This effectively prevents any high‑bandwidth uplink use in cities. Operators may mistakenly believe they can use this band for typical mobile satellite services, but the restrictions make it almost useless in metro areas.

Sixth, the 26 GHz band constraints for land stations are complex and differ depending on whether the station is inside or outside a spectrum licence area, and whether it is within 30 km of such area. The occupied bandwidth measurement method (99% power) means that guard bands are not fixed; they depend on the actual emission bandwidth, which changes with modulation. Operators need to calculate twice their occupied bandwidth and ensure they stay above that offset.

Seventh, the radio astronomy constraints apply to both the 1610‑1626.5 MHz and 1660‑1675 MHz bands. The 500 km exclusion zone in the 1660‑1660.5 and 1668‑1670 MHz bands is extremely wide. Operators in these bands must check the distance to any observatory listed in AUS87. The observatory list is in the spectrum plan, which is not reproduced here. Failing to do this could result in unlicensed operation.

Eighth, section 10(12) requires compliance with the Australian Radio Quiet Zone Western Australia Frequency Band Plan 2023. That plan creates inner and outer quiet zones. The note suggests the ACMA will take into account objections from the Murchison Radioastronomy Observatory when enforcing section 197. This means that even if the operator technically satisfies the quiet zone plan, the ACMA could still take action if the observatory objects. The note creates a grey area of regulatory discretion.

Ninth, section 11 means that receive stations in three bands (10.7‑11.7, 18.2‑18.8, 19.3‑19.7 GHz) have no protection from point‑to‑point stations. If a point‑to‑point link is subsequently licensed that causes interference, the satellite receiver operator has no remedy. This is a known risk for satellite operators using these bands for downlinks.

Finally, the band definitions are not inclusive of the lower frequency (section 5(2)). For example, 148‑150.05 MHz means frequencies greater than 148 MHz up to and including 150.05 MHz. A transmission exactly at 148.000000 MHz is not authorised. This subtlety matters for precise frequency planning.

Compliance with the class licence involves a series of checks and ongoing obligations. The following steps provide a practical framework.

First, confirm that the station is eligible. The station must not be on a space object (i.e., it must be an earth station) and must not hold an apparatus licence for substantially the same purpose. If an apparatus licence exists, decide whether to surrender it and rely solely on the class licence. Document this decision.

Second, verify that the station will operate only in the frequency bands listed in section 8 for transmission and reception. Ensure that the occupied bandwidth and any spurious emissions do not extend outside the authorised band edges, noting the exclusive lower bound rule. Use spectrum analysers or equipment certification data to confirm.

Third, determine the device compliance day for the station. Identify the date of manufacture (if Australian), import, or last material alteration. If before 17 June 2021, the station must comply with the relevant standard as defined by the Act at that time. If on or after 17 June 2021, the station must comply with the applicable equipment rules. Obtain a copy of the applicable standard or rules from the ACMA. Keep records of the compliance day and the standard/rules version.

Fourth, assess compliance with the ARPANSA Standard. The electromagnetic energy emitted by the station (or group of stations at the same location) must not exceed the general public exposure limits in any place accessible by the public. This requires a prediction of power density at ground level and any accessible structures. Use modelling or measurements. Ensure that antenna patterns are considered (e.g., a highly directional antenna may have low exposure off‑beam). For mobile stations (aircraft, ships), exposure scenarios are more complex but still required.

Fifth, ensure the station does not interfere with the operation of any radiocommunications receiver. This is a broad duty. Practical steps include using filters, adhering to emission masks, and avoiding known sensitive receivers. The safe harbour for area‑wide receive stations in section 10(2) applies only in certain frequency/geographic conditions; do not rely on it unless those conditions are met. For frequencies adjacent to radio astronomy, follow the advice‑seeking process in section 10(3) if within 20 km of an observatory. For the 1660‑1660.5 MHz and 1668‑1670 MHz bands, do not operate at all if within 500 km of an AUS87 observatory or on an airborne aircraft. Check the spectrum plan for current observatory locations.

Sixth, for the 2005‑2010 MHz band, ensure the transmitter is not airborne. Measure EIRP: out‑of‑band emissions above 2010 MHz must not exceed -66 dBW/MHz. If operating in a metropolitan area, comply with the strict EIRP, duty cycle, and transmission duration limits. Consider whether the band is suitable for the intended application; the metropolitan restrictions may be prohibitive.

Seventh, for the 27.5‑28.3 GHz band on land, identify if the station is inside a 26 GHz band spectrum licence area. If so, do not operate in 27.5‑28.1 GHz at all. If operating in 28.1‑28.3 GHz within such an area, ensure the transmit frequency is more than 50 MHz above 28.1 GHz (or twice the occupied bandwidth, whichever is greater). If outside such an area but within 30 km, limit EIRP to the horizon to -17.8 dBW in a 1 MHz bandwidth in the 27.5‑28.1 GHz band. Also respect the 27.5‑27.7 GHz guard band rule (50 MHz or twice occupied bandwidth above 27.5 GHz). For airborne operation, comply with the power flux density limits from ITU‑R Resolution 169 Annex 3. For ship operation, ensure power flux density on shore does not exceed -112.2 dBW/m²/MHz at 30 m above ground. Obtain RALI SM 26 maps to identify spectrum licence areas.

Eighth, check the location against the Australian Radio Quiet Zone Western Australia Frequency Band Plan 2023. If the station will operate in the inner quiet zone, note that the ACMA may consider Murchison Radioastronomy Observatory objections. It may be prudent to coordinate with the observatory in advance, even if not strictly required by the class licence.

Ninth, if using the receive bands in section 11 (10.7‑11.7 GHz, 18.2‑18.8 GHz, 19.3‑19.7 GHz), accept that the station receives no protection from point‑to‑point stations. Perform a risk assessment: are there existing point‑to‑point links in those bands? Could future licensing occur? Consider using alternative bands or implementing mitigations (e.g., frequency agility, filtered low‑noise amplifiers).

Tenth, maintain records. There is no registration requirement under the class licence, but good practice suggests keeping a compliance folder containing:

• Station description and device compliance day evidence.
• Equipment certification or test reports showing compliance with applicable standards/rules.
• ARPANSA exposure assessment.
• Frequency coordination records (e.g., advice from radio astronomy observatory).
• Maps showing distance from 26 GHz spectrum licence areas and quiet zones.
• Duty cycle and EIRP records for restricted bands (2005‑2010 MHz, 27.5‑28.3 GHz).

Eleventh, monitor for changes. Because the class licence references external instruments that change over time (e.g., ARPANSA Standard, equipment rules, RALI SM 26, ITU‑R resolutions, frequency band plans), operators should periodically review whether any updates affect their compliance. The ACMA website and the Federal Register of Legislation are the primary sources.

Finally, if any condition cannot be met, do not operate under the class licence. Seek an individual apparatus licence or apply for a variation of the class licence (the ACMA may consider, but the instrument itself is fixed). Operating outside the class licence conditions is unlicensed and carries significant penalties. Compliance is the operator’s responsibility, and ignorance of a condition is no defence.