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									                              SBS SUBMISSION


   Spectrum reallocation in the 700 MHz digital dividend band


                                 Discussion Paper


Introduction

SBS welcomes this opportunity to provide input to ACMA on the reallocation of
the digital dividend spectrum.


SBS currently provides two national television services in order to meet its
principal Charter function of providing multilingual and multicultural radio and
television services that inform, educate and entertain all Australians and reflect
Australia’s multicultural society (Special Broadcasting Service Act 1991). SBS
ONE is available in analogue and digital (SD and HD). SBS TWO is a digital-only
(SD) multi-channel. SBS also provides multilingual analogue and digital radio
services analogue and delivers content online on its website.


The restack provides the opportunity for improvements to spectrum allocation
by allowing SBS to shift from the UHF to VHF band. This will deliver clear
benefits to consumers and SBS, with all broadcasters available through the
same single band antenna.
Configuration

Harmonisation with ITU Region 3
The Discussion Paper refers to further studies being undertaken by the AWF in
respect of coexistence of mobile services with adjacent broadcasting services
below 698 MHz. The outcome of these studies may affect SBS’s position on this
question. SBS considers that a decision on this issue should not be made until
those further studies have been finalised. Subject to these results, SBS does not
have any issues with ACMA aligning its configuration of the digital dividend
spectrum with the harmonised ITU Region 3 arrangements.


Low interference potential devices
SBS notes ACMA’s statement that it will examine the possibility of determining
a specific allocation for wireless microphones or suitable sharing arrangements.


SBS makes extensive use of wireless microphones throughout Australia,
including remote areas. Based on past experience and given the dense use that
will be made of the broadcasting services bands post restack, alternative bands
are needed.


SBS would prefer a clear Australia-wide allocation of spectrum for their use.


Remote areas
If broadcast services are to be allocated above 672 MHz in remote areas, SBS
recommends not restacking those areas. Given the low penetration of
telecommunications services in these areas, SBS recommends that remote areas
be excised from the digital dividend.




SBS Submission – Spectrum reallocation in the 700 MHz digital dividend band     2
Allocation – licence design

Commencement date
Commencement date is dependent on the restack process. ACMA will need to
ensure that time is available to resolve any unanticipated consequences of that
process. It is important that viewers do not lose access to SBS during the
restack.


It would be preferable therefore to make the commencement date flexible and
dependent on the availability of spectrum under the restack process.


Licence duration
The release of 126 MHz of broadcasting spectrum as the digital dividend for
non-broadcasting purposes and the consequent restack of broadcasters will
limit, if not curtail, Australia’s capacity to transition to new technologies in the
future.


It is important that free-to-air television broadcasters have the capacity to
migrate to next generation broadcasting technologies to be able to make the
most of the benefits they offer. To get the full benefit of these new
technologies will require a transition ultimately to DVB-T2. Spectrum, which the
digital dividend has effectively taken away, will be required to support this
transition.


SBS therefore considers that a shorter licence term is preferable to allow the
option of reintroducing broadcast services into at least some of the spectrum
within 10 years for technological transition purposes. At the very least there
should be provision for a review of the spectrum allocation within a 10 year
timeframe to determine whether spectrum is required for such purposes.




SBS Submission – Spectrum reallocation in the 700 MHz digital dividend band        3
Optional conditions
SBS suggests the inclusion of a licence condition that would require reports of
interference to broadcasting services to be examined and, if found to be
genuine, resolved by the licensee at no cost to the broadcaster or consumer.


Timing

SBS notes ACMA’s comments on the timing of the restack and reallocation
process referred to at ACMA’s Spectrum Tune-Up 2010 Conference (3
November) which indicated restack completion by end 2014.


The restack process needs to be carefully managed to minimise costs and
disruption to viewers. The timing of the restack is dependent on a number of
variables including:
   Cost of combiners: By purchasing a number of combiners and swapping
    them in to existing sites timing could be reduced but at higher total cost.
    Replumbing them will still take at least one midnight to dawn outage.
   Availability of technical expertise: With a limited number of skilled people
    within Australia (e.g. six people able to tune a combiner) either additional
    skilled staff will need to be recruited from elsewhere (if available at all) or
    the timetable will need to be extended.
   Acceptable level of disruption to viewers: Given that retuning each channel
    in a combiner can take up to one day, a complete combiner retune may
    take up to a week. To lessen disruption to viewers it may be possible to
    retune a single module every night putting all services off between
    midnight and dawn for a week.
   Number of retunes imposed on viewers: Some sites may require more than
    a single night to restack.




SBS Submission – Spectrum reallocation in the 700 MHz digital dividend band           4
   Acceptable level of interference to viewers: New channels in adjacent
    markets may cause some interference until the next market is restacked.
   Time to retune Master Antenna Systems: Number varies from market to
    market.
   Simulcast options: If simulcast is considered additional costs will be
    incurred. Space within existing buildings may not be adequate. Additional
    transmitters will be required. Some antennas may not have sufficient
    capacity.
   Issues associated with services provided by parties other than the
    broadcasters (self-help services) will need to be resolved, including funding
    for their restack. Where funding is not available, the restack process will be
    delayed, which could have a flow-on effect.


SBS considers that, given the logistics involved, the timetable is very optimistic
and probably unrealisable.


SBS will discuss timing issues in its consultations with the ACMA and the Digital
Switchover Taskforce regarding the restack.


Related issues

Digital radio
SBS refers ACMA to its impending submission to the ‘Review of digital radio
technologies for regional Australia’ being conducted by the Department of
Broadband, Communications and the Digital Economy.


The restacking process presents an opportunity for the Government to plan for
the extension of digital radio services throughout Australia and to address
serious imbalances in the radio services available to communities in regional
Australia.




SBS Submission – Spectrum reallocation in the 700 MHz digital dividend band     5
SBS strongly believes that at least three contiguous VHF Band III channels
should be allocated to DAB. This is the minimum required to provide
interference free services throughout Australia with sufficient multiplexes to
accommodate all existing radio broadcasters. Congestion is particularly
noticeable in the Sydney, Melbourne and Brisbane regions with multiple
adjacent commercial radio markets. One means to achieve this may be to free
up Channel 27 and to allocate this to Channel A in the metropolitan markets.


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SBS Submission – Spectrum reallocation in the 700 MHz digital dividend band      6

								
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