Australian Broadcasting Corporation submission to Australian Communications and Media Authority Strategies for Wireless Access Services: Spectrum Access Options Spectrum Planning Discussion Paper SPP 10/06 March 2007 Australian Broadcasting Corporation Submission on ACMA Discussion Paper SP 10/06, “Strategies for Wireless Access Services: Spectrum Access Options” Introduction The Australian Broadcasting Corporation (ABC) would like to thank the Australian Communication and Media Authority (ACMA) for the opportunity to comment on the discussion paper “Strategies for Wireless Access Services: Spectrum Access Options”. Comments provided by the ABC in response to the previous discussion paper on this topic, “Strategies for Wireless Access Services,” which was released in February 2006, are still valid and applicable. The Corporation proposes to confine its input to spectrum bands directly affecting its activities. The ABC has major concerns about several of the proposals set out in this discussion paper, as they impact on its existing use of spectrum for the key functions of Electronic News Gathering (ENG), reception of international broadcast programs on C-Band and wireless microphones. All of these activities—and thus the spectrum on which they depend—are essential for the ABC to produce broadcast programs that meet its Charter. In particular, the Corporation is greatly concerned that the ACMA appears to have essentially ignored previous submissions by the ABC and other free-to-air broadcasters in relation to ENG spectrum. None of the options relating to spectrum for this purpose that are set out in the discussion paper provide adequately for its existing uses. Any of these options, if implemented, would have a significant and negative effect on broadcasters’ activities. The ABC is not satisfied that the ACMA has applied an open and transparent consultation process in the determination of the quantum of spectrum needed for wireless access services. The Corporation is also concerned that the ACMA is not applying the appropriate international time frames in its proposals for the reallocation of spectrum for higher-end wireless access services, such as IMT-2000 and IMT-Advanced, within Australia. The result, in both cases, appears to be the imposition of unnecessary pressure and expense on existing spectrum users before actual demand for future uses of the spectrum has been properly demonstrated. Spectrum Demand for Wireless Access Services The ABC recognises the need to provide spectrum for fourth-generation mobile phone technologies such as WiMAX, IMT-2000, IMT-Advanced, CDMA2000, HSUPA, HSDPA, HiperMAN, UMTS and others—collectively referred to as wireless access services. 1 ABC Submission on Wireless Access Services Spectrum Access Options 2 However, the Corporation is concerned that the ACMA is attempting to identify candidate bands for these services without having conducted an open and transparent consultation process to determine the quantum of spectrum that is actually required. The ABC believes that this is causing the ACMA to consider evicting existing spectrum users from their bands before any need to reallocate spectrum has been clearly demonstrated. In particular, the Corporation is concerned that the demand for spectrum in Australia has not been estimated in any public discussion or any publicly-available calculations. The ABC is aware that the ACMA has been working with the conclusions of a confidential estimate prepared by an interested party, as these were selectively released to the Australian Radio Study Group (ARSG) 8. The information released to that group was in the form of a summary methodology and a summary conclusion, and did not contain sufficient details of the underlying assumptions and calculations for any assessment of the validity of the estimates to be tested. As this study has not been made available for peer review and originates from a party with a commercial interest in maximising the availability of spectrum for wireless access services, the ABC has limited confidence in the figures it presents. Similarly, the ABC would be concerned if the ACMA was depending upon conclusions published by the International Telecommunications Union Radiocommunications Sector (ITU-R) Working Party 8F (WP8F), which suggest an overall spectrum demand of up to 1.2 GHz below 6 GHz band, as this position is not supported by many participants in the ITU-R study groups. The methodology used in the WP8F calculation has been challenged by a number of ITU-R working parties, and an alternative calculation developed by New Zealand participants in WP8F has called into question both the methodological assumptions of the main study and its demand estimate of 1.2 GHz. While the spectrum quantum of 1.2 GHz may perhaps correctly reflect the need for spectrum in some densely-populated cities, such as Tokyo, New York, Seoul and Paris, this quantum is totally unjustified for the population density of any area within Australia before the year 2020. The ABC believes that Australia’s need for new spectrum—i.e. spectrum not currently used for mobiles—is far less than the internationally-proposed 1.2 GHz in the 2015–2020 timeframe, not least because spectrum currently used by mobile services can and should be re-farmed for wireless access services in the future. In light of this, the ABC estimates that no more than 250 MHz of new spectrum will be needed between 2010 and 2015, and that no more than a further 300 MHz of spectrum should be needed between 2015 and 2020. Not all of this spectrum may have to be “new,” as some of the currently-licensed spectrum is not fully being utilised at present. Further, by the time fourth-generation technologies arrive, 2G and 2.5G technologies may be reaching obsolescence, freeing up yet more spectrum. Further, the ABC has consistently argued over the past three or four years that not all of the spectrum for wireless access services needs to be accommodated below 6 GHz, as some ABC Submission on Wireless Access Services Spectrum Access Options 3 short-haul links using HiperMAN technology applications (e.g. high-density short-haul links) could very well work with spectrum in higher bands. The ABC is pleased to note that the ACMA now recognises that spectrum for nomadic IMT-2000 services could be partly allocated in the bands above 6 GHz. Timing of Spectrum Allocation The ABC notes that the discussion paper identifies three specific timeframes, namely short term (within 12 months), medium term (two-to-four years) and long term (four-to-ten years). These timeframes appear to place the ACMA’s planning process ahead of international spectrum planning timetables for higher-end wireless access services, such as IMT-2000 and IMT-Advanced. For example, the medium-term timeframe of two-to-four years refers to the period from 2009 to 2011, whereas the international time table for IMT spectrum demand is from the year 2015 to 2020 in most references. The ABC thus believes that the ACMA timetable for medium-term and long-term identification of spectrum for allocation to high-end wireless access services is running ahead of international developments by about four-to-six years. Premature planning of long-term needs can result in unnecessary pressure and expense being placed on existing users of spectrum before actual demand for future uses of the spectrum is established and demonstrated for new technologies. Spectrum for Electronic News Gathering The 2500–2690 MHz band is used extensively by commercial and national free-to-air broadcasters (the ABC and the Seven, Nine and Ten Networks) for ENG/Television Outside Broadcast (TVOB) services. The ABC uses this spectrum on a regular basis for live news and sports coverage, as well as major events, such as Anzac Day marches, state funerals and election night coverage. These uses are a vital part of the Corporation’s activities and its ability to provide the services that its audiences depend upon would be significantly diminished without them. For reasons set out extensively in its submission in relation to the ACMA’s previous discussion paper, “Strategies for Wireless Access Services,” the ABC does not believe that ENG/TVOB operations can share spectrum with wireless access services, particularly in metropolitan areas. Accordingly, the ABC, like other free-to-air broadcasters, opposes the reallocation of the 2500–2690 MHz band for wireless access services until suitable alternative contiguous spectrum for the relocation of ENG/TVOB has been identified by the ACMA to the satisfaction of broadcasters. For the last two years, broadcasters have informed the ACMA about a number issues in this regard and are still awaiting a satisfactory resolution of these issues through discussion and cooperation with the ACMA. In particular, broadcasters have submitted that any premature ABC Submission on Wireless Access Services Spectrum Access Options 4 or fragmented relocation would create unacceptable disruption to their news-gathering and live-content-generating capabilities. Further, broadcasters have recently made a substantial investment in equipment to introduce digital ENG (DENG) in the band. Any change to the channel arrangements will be expensive, requiring each broadcaster to spend millions of dollars on new equipment, in addition to spectrum costs. The ABC notes that that ENG/TVOB services can successfully share the 2.5 GHz band with satellite services, while wireless access services cannot coexist with satellite services in this band. The Corporation opposes the allocation of wireless access services in this band in any time frame, and instead proposes that ENG/TVOB operations continue in the band on a shared basis with satellite services. This proposed use is spectrum efficient and creates at least as much public and national benefit as would be achieved by the introduction of wireless access services in the band. Unworkable Band Segmentation Options for 2500–2690 MHz In spite of concerns expressed by the ABC and other free-to-air broadcasters in previous submissions about the impact of wireless access services on the 2.5 GHz band used for ENG/TVOB, the ACMA has proceeded to develop band segmentation options for this band. The ABC considers Options 1 and 2 presented in the discussion paper to be entirely inappropriate, as they make no provision for ENG/TVOB operations. Options 3, 4, 5 and 6 as also unsuitable, as they provide inadequate spectrum for ENG/TVOB—30 MHz arranged in 7 MHz blocks in the case of Options 3 and 4, and 50 MHz in 8 MHz blocks in Options 5 and 6. To make any of these options feasible, minimum contiguous spectrum of 190 MHz would be required for ENG/TVOB in the middle of this band. Collectively, broadcasters share the spectrum among themselves and occasionally with other ENG/TVOB users. Although they have introduced digital technologies which are more spectrum efficient, the capacity is being fully utilised for complex two-hop production processes. Also, the available spectrum is frequently full utilised at many sporting and news gathering events around the country. Therefore, non-availability of this quantum of spectrum will adversely impact the content being put on air by the free-to-air broadcasters. Further, broadcasters are currently working on high definition (HD) content generation, consistent with their obligations to transmit 1040 hours of HD content annually under the Broadcasting Services Act 1992. This will necessarily require more spectrum than the allocations proposed in any of the Options in the discussion paper. Impediments to ENG Operations in the 2025–2110 and 2200–2300 MHz Bands The discussion paper notes that the 2025–2110 MHz and 2200–2300 MHz bands could be used for ENG/TVOB services. However, as the ABC and other free-to-air broadcasters have previously argued, the quantum of available spectrum in these bands is not adequate for ABC Submission on Wireless Access Services Spectrum Access Options 5 contiguous ENG/TVOB operations because it is fragmented into two lots. Each of the four broadcasters conducting ENG/TVOB activities uses not only its own channels, but also, from time to time, channels of other broadcasters through a sharing arrangement made possible by the contiguous spectrum. As this capability, which is necessary for certain kinds of coverage, would be compromised by fragmented spectrum, the ABC does not regard the suggested pairs of bands as suitable for ENG/TVOB. In addition, the ABC believes that the need to share with other existing services will create further difficulties in relocating ENG/TVOB services to these bands. Sharing the spectrum with fixed links would significantly limit the flexibility of ENG/TVOB operations. Satellite Program Receiver Services Using C-Band The ABC is not convinced of the need to allocate the C-band (3710–4200 MHz) for wireless access services at this time. The further allocation of C-band to IMT-2000 services is an issue that should be determined on the merits of further technical sharing studies to be completed in time for the next World Radiocommunications Conference (WRC 2011). If any of this band is released for wireless access services, only about 100 MHz of it (for example, between 3.7 GHz and 3.8 GHz) should be released between 2011 and 2015, while the remaining spectrum should only be allocated for wireless access services in selected parts of Australia and only after 2015. Further, before that can happen, a number of measures will also be required to ensure the continuing effective operation of C-band downlink services: a. The protection of current C-band earth stations by licensing and grandfathering in the short term, and by providing exclusive earth station footprint zones near metropolitan cities (e.g. at Frenchs Forest in metropolitan Sydney) in such a way that the earth station footprint zones do not allow any wireless access services inside them. This will provide an opportunity for the existing C-band earth stations to relocate or rely on signals from other similar stations clustered in “Wireless Access Services Quiet Zones” near metropolitan areas. b. Protection of earth stations outside metropolitan areas by allowing them to select sites that are unlikely to have wireless access services for a significant period and by allowing continued licensing of these types of earth stations. c. Allowing C-band earth stations in the extreme north (the Northern Territory) and most of the north-west of Australia, where there are no significant population centres and therefore no need for wireless access services in the foreseeable future. ABC Submission on Wireless Access Services Spectrum Access Options 6 Premature Consideration of Wireless Access Services in the Broadcasting Services Bands The ABC is concerned about any proposal, short term or long term, that reflects a possible allocation of the UHF terrestrial television band (520–820 MHz) for wireless access services ahead of the full establishment of digital television broadcasting and the completion of future planning of digital radio in major regional areas. The Corporation believes that before the UHF spectrum is resumed from analog television and is allocated for other services, many issues need to be addressed, including: digital television reception black spots; the identified need for additional translators to ensure equivalent coverage to analog; full-power operation of digital television transmitters and enhancement of existing digital transmission services; resolution of current problems of digital single-frequency coverage; and planning for complete digital radio deployment in Australia. The ABC believes that the only proper timeframe for discussing any allocation of UHF spectrum for wireless access services would be at the completion of the full deployment of digital television and radio broadcasting services. Further, it is too early to talk in terms of a “digital dividend” when a proper public debate in Australia on these issues has yet to take place. Wireless Microphones The ABC is an extensive user of wireless microphones that operate in the UHF band (520– 820 MHz), which is proposed in the discussion paper as a long-term candidate band for wireless access services. As well as broadcasters, many other RF users will be impacted by an changes to this band, including theatres, schools, churches, community groups, musicians, as well as major sporting and cultural events will not be able to benefit from the use of wireless microphone equipment. The Corporation also notes, that unlike most technologies, there is no next-generation technology on the drawing board that has the potential to replace these products in the foreseeable future, and certainly not by 2009. Licensing and Allocation Issues The ABC supports the principle of “use it or lose it” conditions and time-bound rollout obligations for wireless access services in order to support the introduction of genuine services in a timely fashion. This will encourage genuine users of the spectrum to apply for spectrum and prevent the stock-piling of spectrum. The Corporation also supports careful consideration of relocation needs of displaced incumbent services, including their need for suitable spectrum and financial compensation where their spectrum is auctioned to make way for other services. ABC Submission on Wireless Access Services Spectrum Access Options 7 Regardless of licensing model adopted for spectrum allocated for wireless access services, the ABC is concerned that sufficient controls be in place to enable the ACMA to deal with interference from wireless access services affecting other incumbent services. For example, the Corporation predicts that wireless access services will overwhelm the capacity of satellite dishes to receive signals if the power of transmissions exceed the satellite signal by 50 dB or more. Under these conditions, even licensed satellite receivers will not be protected without expensive retro-fits costing many thousands of dollars per dish. On this basis, the ABC concludes that in-building coverage of a wireless access service, where required, should be handled through in-building distribution, rather than high-powered antennas or transmissions directed at a particular building.
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