29th RSAC Meeting Minutes by iua11789



                    Minutes of the Thirty-First Meeting
                 Held at 2:30 p.m., Wednesday, 16 May 2007
                         in OFTA Conference Room

Mr Danny K C Lau          OFTA (Chairman)
Mr Paul Anderson          Representative of Amateur Radio Societies
Mr Chan Yat Hung          Representative of Asia Satellite
                          Telecommunications Company Limited
Mr Chan Yiu Chow          Representative of Broadcasters (Free TV)
Mr Desmond Chan           Representative of Local Wireline-based Fixed
                          Telecommunications Network Services (“FTNS”)
Mr Chiu Kin Fai           Representative of Civil Aviation Department
Mr Carlson Chu            Representative of Broadcasters (Pay TV)
Mr Ken Fong               Representative of Hong Kong Wireless
                          Technology Industry Association
Mr Fung Man Fai           Representative of External FTNS Licensees
Mr Ho Wing Leung          Representative of Amateur Radio Societies
Dr Victor Hung            Representative of Consumer Council
Dr Lui Ho Chung           Representative of Hong Kong Wireless
                          Technology Industry Association
Mr Paul Lam               Representative of Sound Broadcasters
Dr Leung Kwok Wa          The City University of Hong Kong/Ad personam
Mr Pan Hsiao Chi          Representative of China Mobile Peoples
                          Telephone Company Limited
Mr Albert Siu             Representative of Hutchison Telephone Company
Ir Spencer Tao            Representative of the Hong Kong Institution of
Mr Luk Yiu Tong           Representative of the Hong Kong Police Force
Mr Tsang Wing Kei         Representative of the Hong Kong Police Force
                                   - 1 -
Ms Vicky Wong           Representative of AsiaSat
Mr Bill Yeung           Representative of Local Wireline-based FTNS
Mr Eric Fung            OFTA (Secretary)

Absent with Apologies
Mr Alan Choi            Representative of SmarTone Mobile
                        Communications Limited and SmarTone 3G
                        Limited (“SmarTone”)
Mr Bruce Lam            Representative of Communications Association of
                        Hong Kong
Mr Eric Leung           Representative of PCCW Mobile HK Limited
Dr Mow Wai Ho           The Hong Kong University of Science and
                        Technology/Ad personam
Mr Adam Wong            Representative of Hong Kong CSL Limited and
                        New World PCS Limited
Mr Edmond Wong          Representative of Radio Paging Operators
Mr Chen Xun             Representative of APT Satellite Company
                        Limited (“APT”)

In Attendance
Mr Y C Leung            OFTA
Mr Wilson Lee           OFTA
Mr P H Ma               OFTA
Mr Alex Tang            OFTA
Mr K K Wong             OFTA
Mr Kent Yu              OFTA

Mr Cyrus Lai            Representative of SmarTone
Mr Pan Li               Representative of APT
Mr Rudy Wong            Representative of PCCW Mobile HK Limited
Mr Yip King Hoi         Representative of Hong Kong CSL Limited and
                        New World PCS Limited

                                - 2 -
       The Chairman welcomed Members to join the first meeting of the
new term of the RSAC and introduced the new faces of the Committee.

Item 1: Confirmation of Minutes of the Last Meeting

2.       The minutes of the 30th meeting held on 17 February 2006 were
confirmed without amendment.

Item 2: Matters Arising from the Previous Meeting

Item 5 of the minutes of the 28th at RSAC Meeting and Item 4 of the minutes
of the 29th RSAC Meeting

3.        Mr P H Ma reported that the latest Amateur Liaison Meeting was
held on 27 April 2007. On the possible use of part of the 1240 – 1245 MHz
band by amateur on a secondary basis for terrestrial and satellite operation,
OFTA had conducted preliminary analysis and the result indicated that
interference would occur if the amateur equipment was operating in line of
sight with CAD’s radar installation at adjacent band. He said that OFTA
would continue to work with the amateur society to study the “exclusion
zone” and the guard band requirement.

Item 7 of the minutes of the 28th at RSAC Meeting and Item 4 of the minutes
of the 30th RSAC Meeting

4.       The Chairman said that the RSAC Working Group on assessment of
potential interference between broadband wireless access (“BWA”) systems
in the 3.4 – 3.6 GHz band and fixed satellite services in the 3.4 – 4.2 GHz
band had completed the study. Taking into account the assessment of the
Working Group, OFTA had compiled a report and posted it on OFTA’s
website1. He added that OFTA had decided not to allocate the 3.4 – 3.6
GHz band to the BWA service at the present stage. The band was not
included in the recently published Spectrum Release Plan for 2007/08 –

    The report is posted on the website at: http://www.ofta.gov.hk/en/ad-comm/rsac/paper/rsac5-2006.pdf
                                                   - 3 -
2009/10 2. Instead, OFTA had proposed in a recently issued consultation
paper to use spectrum in the 2.3 GHz and/or 2.5 GHz bands for BWA.

Item 6 of the minutes of the 30th RSAC Meeting

5.        Mr Wilson Lee reported that an RSAC Paper 1/2007 3 on
Preliminary Hong Kong Positions on Agenda Items to Be Discussed at
World Radiocommunication Conference 2007 (“WRC-07”) had been
circulated to Members for comments in December 2006. In early 2007,
OFTA attended the Asia-Pacific Telecommunity’s Conference Preparatory
Group (“APT APG”) meeting held in Bangkok and the International
Telecommunication Union’s Conference Preparatory Meeting (“CPM”) held
in Geneva. OFTA would further exchange views with the Ministry of
Information Industry (“MII”) of the Mainland on the WRC-07 agenda items
in end of May this year.

6.        The Chairman added that the 2.5 GHz band was included in the
Spectrum Release Plan and OFTA would closely monitor the resolutions
made at the WRC-07 on the worldwide allocation of this band.

7.        In response to Mr Fung Man Fai, Mr P H Ma replied that OFTA
would further seek Members’ views on the latest position of Hong Kong
after meeting with the MII in May and attend the next APT APG meeting to
be held in July. He requested Members to refer to the recently published
CPM report published by the ITU to keep abreast of the latest development
of the ITU on WRC-07. The Chairman said that OFTA would update
Members the latest development in the next RSAC meeting. He also invited
interested Members to attend the WRC-07 meeting to be held in Geneva in
October 2007. OFTA would arrange their attendance with the MII.

[Post meeting note: Members were informed of the website address4 to get

  The Spectrum Release Plan 2007/08 – 2009/10 (http://www.ofta.gov.hk/en/freq-spec/plan2007.pdf) lists
  the frequency bands made available to the market for the next three years through an open bidding or
  tendering process.
  The Paper is available at: http://www.ofta.gov.hk/en/ad-comm/rsac/paper/rsac1_2007.pdf
                                               - 4 -
the ITU CPM report.]

Item 3: Frequency Allocation for Radio Frequency Identification
        Equipment (II) (RSAC Paper 2/2007)

8.        Mr Alex Tang introduced Paper 2/2007 about the allocation of the
433 MHz band for active radio frequency identification (“RFID”)
application. He explained that the 433 MHz RFID would mainly be
deployed by the container shipping industry.

9.         The Chairman said that, except the 433 MHz band, the other ISO5
designated frequency bands for RFID had been opened for use by RFID in
Hong Kong on a licence-exempted basis. He explained that 433 MHz RFID
tags would only transmit upon requested by the interrogators. While
OFTA’s proposal was to allow the use of the RFID tags on a licence-
exempted basis or by a class licence, the operation of the 433 MHz RFID
interrogators would be subject to licensing. He pointed out that licensing the
use of 433 MHz RFID systems was appropriate at the initial stage as it
would ensure that the RFID interrogators would not cause interference to the
existing radiocommunications system operating in the same band.

10.        Mr Paul Anderson enquired whether the operation of 433 MHz
RFID systems would be restricted to the Kwai Chung area. The Chairman
said that there was no such limitation. Mr P H Ma added that the 433 MHz
RFID systems would mainly be used by the container shipping industry and
therefore the operation of the interrogators would likely be confined to
container ports area.

11.      Mr Paul Anderson asked whether car keys operating at 433 MHz
would cause mutual interference to RFID tags operating in the same band.
Mr P H Ma replied that use of 433 MHz for short-range radio devices had
been allowed for some time in the European countries and RFID devices
were designed to work properly with the other 433 MHz short-range devices

  The International Standard Organisation (“ISO”) has designated various frequency bands for the RFID
technology including 135 kHz, 13.56 MHz, 433 MHz, 860-960 MHz and 2.45 GHz.
                                               - 5 -
in the same frequency band.

12.      Members had expressed no objection to the proposal.          The
Chairman thanked Members’ support of the proposal.

Item 4: Frequency Bands for Mobile Television Services (RSAC Paper

13.        Mr Kent Yu introduced RSAC Paper 3/2007 and briefed Members
on the latest development on Mobile Television (“Mobile TV”) and the radio
spectrum available for Mobile TV services in Hong Kong.

14.       The Chairman said that the Government’s 3-month consultation to
seek public views on the introduction and regulation of mobile TV services
was completed in May. RSAC Paper 3/2007 was for Members’ information
about the available frequency bands for Mobile TV services. Members took
note of the information paper and had no comments to make.

Item 5: Frequency Allocations for Electronic News Gathering and
        Outside Broadcasting (II) (RSAC Paper 4/2007)

15.       Mr W K Leung introduced RSAC Paper 4/2007 which proposed
the allocation of a bandwidth of 45 MHz in the 2025 – 2110 MHz for
electronic news / outside broadcasting (“ENG/OB”) applications on a
temporary basis.

16.       The Chairman said that the proposed allocation was to meet the
imminent demand from some new programming services providers for radio
spectrum to set up ENG/OB links. However, the long term allocation of this
band would be reviewed after the WRC-07. Subject to the decision on the
long-term planning of this frequency band, the Telecommunications
Authority (“TA”) might withdraw the frequency assignment by giving a 2-
year prior notice. Such provision was in line with Government’s policy on
spectrum management on the efficient use of spectrum.

17.       Mr Carlson Chu, representing the pay TV industry, expressed
                                  - 6 -
support of the proposed frequency allocation. As regards the prior notice
period for withdrawal of frequency assignment, he said there was suggestion
from one pay TV broadcaster that the prior notice period should be three
years so as to align with the 3-year rolling period of the Spectrum Release
Plan2. Mr P H Ma said that a 2-year prior notice for a temporary assignment
should be sufficient for the assignee to plan for the alternative means of
ENG operation. The Chairman explained that the concerned frequency band
might be put up for auction if there were competing demands in accordance
with the Government’s recently announced spectrum policy. The proposed
3-year prior notice period was deemed to be too long for holding up the
concerned radio spectrum.

18.     There were no other comments.         The Chairman thanked the
Members for their support of the proposal.

Item 6: Frequency Allocation for Medical Implant Communication
        Systems (RSAC Paper 5/2007)

19.       Mr Alex Tang introduced Paper 5/2007 and briefed Members the
allocation of the 402 – 405 MHz band to mobile service for medical implant
communication systems (“MICS”) on a secondary basis. Currently, the
band was used by the Hong Kong Observatory for meteorological operation.
Sharing of this band by the MICS is technically feasible.

20.     The Chairman said that the allocation would allow the use of
medical implant communication systems which would benefit the
community. OFTA had consulted the Department of Health and the Hong
Kong Observatory and they both expressed their support of the proposal.

21.       Mr Paul Anderson asked the reason for not allowing voice
communications in the proposed allocation for MCIS. The Chairman said
that, as pointed out in RSAC Paper 5/2007, the communication of MICS
with its control unit was wireless data transfer and therefore voice
communications would not be necessary.

22.      Members expressed no objection to the proposal.
                                   - 7 -
Item 7: Frequency Allocation for Low-power FM Transmitters
(RSAC Paper 6/2007)

23.       Mr Kent Yu introduced RSAC Paper 6/2007 and briefed Members
on the background of the proposal to allocate the FM Broadcasting Band for
operation of low-power FM Transmitters on a secondary basis.

24.        The Chairman said that a number of overseas countries like the
United States, the United Kingdom, Germany and Singapore had introduced
regulations to legalise the use of low-power FM transmitters operating in the
88 – 108 MHz band. With a view to legalizing the use of low-power FM
transmitters in Hong Kong, OFTA had conducted a technical study to assess
whether these transmitters would cause interference to the FM sound
broadcasting services. The findings concluded that interference might occur
if the low-power FM transmitters were operating in short distance (typically
a few meters) to a co-channel FM receivers. OFTA’s test results were
similar to the test results of the Electronic Communications Committee.

25.       Mr Paul Lam briefed Members about his comments (Annex 1) on
the proposal. Mr Lam stressed that the sound broadcasters had a role to
maintain a quality FM broadcast signal for good reception by the general
public. The use of low-power FM transmitters proposed in the RSAC Paper
would stimulate the sale of non-compliant low-power FM transmitters in the
market, thus increasing the chance of interference from these devices to FM
broadcasts. He said that Hong Kong Commercial Broadcasting Company
Limited (“CRHK”) had conducted sample test on five low-power FM
transmitters purchased from the local market and all of them were found
exceeding the proposed technical limit.

26.        The Chairman said that there were low-power FM transmitters in
the market which complied with OFTA’s proposed specification. OFTA had
purchased five samples and two of them were found in compliance with the
proposed technical limit. He opined that if there was no standard or
legislation governing this kind of transmitters, they would spread over the
market in an unregulated manner. For the sale of these devices, OFTA
                                   - 8 -
might consider implementing certification and labelling arrangement similar
to that adopted for the Citizens Band radios and cordless telephones.
Members of the public would be advised to buy and use low-power FM
transmitters affixed with OFTA label. He said that OFTA would take
enforcement action against the sale of non-compliant low-power FM
transmitters. Mr Paul Lam said that interference was prone to occur when
a FM low-power transmitter was operating within a few meters from a radio
receiver. In Hong Kong’s congested living environment, the use of low-
power FM transmitter would adversely affect the FM broadcasting service.

27.       Mr Paul Lam further said that it would be difficult to identify
whether the source of interference was from compliant or non-compliant
products based on their experience in handling interference cases caused by
illegal devices. The Chairman said the introduction of the new regulation,
together with OFTA’s enforcement action against the sale of non-compliant
products, would encourage the radio dealers to sell low-power FM
transmitters and the number of illegal devices in the market would drop.

28.        Dr Victor Hung opined that while it would be necessary to look
after the interest of the radio listeners, the genuine need of the consumers in
the use low-power FM transmitters needed also to be considered. He tended
to support the proposal of prescribing a technical specification by OFTA so
that products complying with the specification could be made available for
use of low-power FM transmitters by consumers.

29.        Dr Lui Ho Chung and Mr Chan Yiu Chow opined that the FM
broadcasting band was reserved for sound broadcasting. The Chairman said
that spectrum was not allocated for exclusive use. Sharing use of the
frequency spectrum for different services in the same frequency band is the
normal spectrum management practice in order to make the most efficient
use of the scarce public resource.

30.        Mr Chan Yiu Chow suggested deferring the proposal in view of
the interference concerns raised by Members. The Chairman said that there
would not be any change in the debated issues by deferring the discussion of
the proposal. To allow Members to have a better assessment of the level of
                                    - 9 -
    interference caused by low-power FM transmitters to FM sound
    broadcasting service, he proposed that OFTA arrange a joint field test with

    31.        Ir Spencer Tao said that CRHK should consider if the proposed
    effective radiated power of 50 nW was acceptable as their tests were based
    on some non-compliant products with higher output power. In response, Mr
    Paul Lam maintained the view that the possible interference to normal FM
    sound reception would still be an issue that needed to be addressed. In
    response to Ir Tao on whether the proposal of allowing the use of low-power
    FM transmitter was a request from the commercial sector, the Chairman said
    that the proposed frequency allocation to low-power FM transmitter was
    initiated by OFTA after taking note of the recent development in overseas

    32.        The Chairman concluded that there were concerns from the sound
    broadcasters on the possible interference caused by the low-power FM
    transmitters to their services. OFTA would further discuss with the sound
    broadcasters to address their concerns before finalising the proposal of
    legalising the use of low-power FM transmitters. Meanwhile, OFTA would
    arrange the field test as suggested and invite Members to join the test.

`   Item 8: Spectrum Release Plan for 2007/08 – 2009/10 (RSAC Paper

    33.      Mr W K Leung introduced RSAC Paper 7/2007 and briefed
    Members on the background of the different frequency bands listed in the
    Spectrum Release Plan.

    34.       The Chairman said that in preparing the Spectrum Release Plan,
    the TA had considered various factors such as the spectrum policy objectives,
    the availability of radio spectrum for assignment primarily for non-
    government use, international radio spectrum allocation guidance, regional
    spectrum allocation decisions, technology and equipment availability,
    proposals from the industry and the discussions at the RSAC meetings. He
    added that the Spectrum Release Plan would be updated annually on a
                                       - 10 -
rolling basis or as necessary taking into account the latest developments.
Members took note of the information paper and had no comments to make.

35.        The Chairman opined that, with the implementation of the
Spectrum Policy Framework, more RSAC meetings may need to be held in
future in order to solicit the views of the Members on issues including the
identification of candidate bands to be included in the Spectrum Release

Item 9:    Any Other Business

36.       There being no other business, the meeting was adjourned at 4:50

Office of the Telecommunications Authority
May 2007

                                  - 11 -
                                                                    Annex 1

               CRHK’s comments on RSAC Paper 6/2007

We write with reference to the discussion paper (RSAC Paper 6/2007), due
to be discussed on 16th May, 2007 and requesting comments regarding the
allocation of frequency in the FM broadcasting band for the operation of
low-power FM transmitters.

We would like to submit the following for discussion and consideration.

   1) Our own tests of such devices have shown serious potential
      interference to our current FM broadcasts. We tested five currently
      available low-power transmitter devices. All of them exceed the limits
      suggested by OFTA and caused interference to our listening
      audience. Three of the samples we tested caused harmful interference
      to an area with a diameter of some 25 meters.

   2) Currently, there are no low-power transmitter devices that meet
      OFTA’s suggested technical specifications. It is therefore highly
      likely that if such devices are allowed, many of them would not meet
      the required specifications and would cause even greater interruption
      of the current FM signals. In addition, prosecution of illegal
      transmissions becomes impractical, as it is technically difficult to
      identify whether the transmission devices comply with OFTA’s
      suggested limits.

   3) While such devices may not have appeared to provide too much
      interference in other countries, a number of factors unique to Hong
      Kong make such comparisons unreliable. Firstly, due to current
      limitations on FM broadcast transmitting power and Hong Kong’s
      unique system of relay transmitters, our current FM broadcast signals
      are more vulnerable to interruption from low-power devices than
      those of other countries. Secondly, when Hong Kong’s uniquely
      crowded living environment is taken into consideration, interference
      even in limited spaces of a few meters at very low power, could cause
                                  - 12 -
      significant interruption of the current FM broadcast signals. (Two
      obvious examples of this are a) the much smaller average size of
      living spaces here and their close proximity to each other and b) the
      fact that the vast majority of all driving in Hong Kong is experienced
      in heavily congested areas, with cars often just feet apart)

   4) Lastly, and again unlike in other countries, the current radio broadcast
      licensees pay substantial amounts to the government in annual license
      fees for the privilege and responsibility of uninterrupted access to the
      FM broadcast band; we believe that allowing such low-power devices
      would undermine our ability to provide a technically reliable service
      to our listeners.

In conclusion therefore, we believe that, notwithstanding the experience of
other countries (which we believe to operate in a very different environment
from Hong Kong), the operation of low-power FM transmitters, even at the
low power levels suggested by OFTA, would pose a serious threat to the
continued provision of technically acceptable radio broadcasts over the FM
band and we therefore oppose the suggestions contained in the discussion

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