MHz Band Re-planning Options

Transcription

1 MHz Band Re-planning Options Summary of Submissions and Conclusions First published in June 2010 by the Radio Spectrum Policy and Planning Group Energy and Communications Branch Ministry of Economic Development PO Box 1473, Wellington, New Zealand ISBN (PDF) ISBN (HTML) Page 1 -

2 Disclaimer The opinions and proposals contained in this document are those of the Ministry of Economic Development and do not reflect government policy. Readers are advised to seek specific legal advice from a qualified professional person before undertaking any action in reliance on the contents of this publication. The contents of this document must not be construed as legal advice. The Ministry does not accept any responsibility or liability whatsoever whether in contract, tort (including negligence), equity or otherwise for any action taken as a result of reading, or reliance placed on the Ministry because of having read, any part, or all, of the information in this document or for any error, inadequacy, deficiency, flaw in or omission from the document Page 2 -

3 Table of Contents EXECUTIVE SUMMARY PURPOSE Background Re-planning Objectives SUMMARY OF RE-PLANNING OPTIONS Current issues in the band Base Proposal Variations to base proposal Variation 1 Simplex Land Mobile Radio Relocation Variation 2 Alternative Use of MHz SRD Band Variation 3 Reuse of Orphan Cellular Spectrum Illustrations of Re-planning Proposal and Variation SUBMISSIONS ANALYSIS Base Proposal Suitability of spectrum for proposed services Transition Management of the MHz band Variations to base proposal Variation 1 Simplex Land Mobile Radio Relocation Variation 2 Alternative Use of MHz SRD Band Variation 3 Reuse of Orphan Cellular Spectrum Other Issues Amateur Service Fixed Service Land Mobile Radio Service Short-range Devices Cellular Mobile Service NEXT STEPS GLOSSARY APPENDIX A: SUMMARY OF SUBMISSIONS Page 3 -

4 Executive Summary In 2008, the Ministry of Economic Development ( the Ministry ) reviewed the cellular allocations in the MHz band. That process resulted in a new allocation opportunity for the unused MHz range of frequencies. Issues with other parts of the band had also previously been identified through reviews of the spectrum allocations for short-range devices (SRDs) and for studio-to-transmitter links (STLs). The Ministry therefore took the opportunity to review the non-cellular uses of the whole MHz in 2009, with a view to improving utilisation of the band and facilitating adoption of new technologies. The Ministry developed proposals to re-plan some of the allocations in this band and consulted industry in 2009/10. Responses to the consultation process, which are summarised in the appendix to this paper, were broadly supportive of the base proposal for spectrum allocation changes, to: allocate MHz for fixed service (STLs), and open the MHz frequencies (currently used by STLs) for use by 1 W SRDs, with a specific allocation at MHz for higher power RFID (4 W e.i.r.p.). The Ministry s conclusion is that these proposals are broadly suitable, but some amendments have been made as a result of the consultation process. These include: employing a 3.5 MHz frequency separation above Telecom s management right ( MHz) for STLs being licensed in the MHz band, at those sites where the cellular base station receivers require filtering to prevent interference from the STL; allowing the Crown management right at MHz to revert to the radio licensing regime upon expiry; permitting immediate use of MHz by short-range devices with a radiated power of up to 4 W, by allowing 1 W devices employing frequency hopping or digital modulation techniques to operate with gain antennas; allocating the MHz frequencies (currently allocated for SRDs and the Amateur service) for STLs to assist with their transition from the MHz band. In addition, low power SRDs (2 mw e.i.r.p.) will be permitted to use the MHz band. The Ministry will make some immediate changes to the SRD and Amateur General User Radio Licences, and once coordination guidelines for the 840 MHz interface have been finalised, will give five years notice to the licence-holders in the MHz band of the removal of their protection from interference Page 4 -

5 1. Purpose In , the Ministry consulted industry on options for re-planning some spectrum allocations in the MHz band. This paper summarises the submissions received in response to a discussion paper the Ministry published in May 2009, MHz Band Re-planning Options 1, and sets out the Ministry s analysis and conclusions. 1.1 Background The Ministry began a two-stage review of this band following the sale of management rights in the band by both Telecom and Vodafone to new market entrant 2degrees Mobile 2, which occurred as part of the 2007/08 renewal process for cellular management rights. The first stage of the review examined the allocations of cellular spectrum in the band and found that a more technically efficient and commercially viable allocation of cellular spectrum could be achieved by swapping a Crown management right at MHz with 2degrees management right at MHz. This enabled 2degrees to utilise MHz, paired with MHz, to deploy GSM technology for its 2G services. The second stage of the review focussed on the spectrum used for non-cellular services in the MHz band, including opportunities for using the now contiguous MHz band, and was the subject of the May 2009 discussion paper. 1.2 Re-planning Objectives In order to improve the overall efficiency and effectiveness of the MHz band, the replanning objectives, in no particular order, were to: increase spectrum utility through introduction of more efficient technologies (technical efficiency) and reduction of fragmentation of allocations and channelling; minimise unused or under-utilised spectrum including guard bands; take account of technical drivers for change, such as technological changes, and demand for new or additional services or technologies; address any sub-bands where demand for spectrum exceeds current supply; harmonise the band, to the extent possible, with those of our major ICT trading partners in order to take advantage of economies of scale and new technologies; and ensure that the band is managed under the appropriate regime to encourage efficient use of allocations. 1 The discussion paper is available at: 2 2degrees acquired management rights from Vodafone and Telecom in March and April 2008 respectively Page 5 -

6 2. Summary of Re-planning Options 2.1 Current issues in the band In summary, the Ministry s analysis of the current spectrum allocations in the MHz band indicated the following principal problems: congestion in the spectrum available for studio-to-transmitter links (STLs) in highuse areas; lack of harmonisation with the allocations for short-range devices (SRDs) in the US ( MHz), Australia ( MHz) and Europe ( MHz), precluding some SRDs from use in New Zealand; increasing risk of interference to STLs in the MHz band from SRDs designed for use in the US and Australian markets; insufficient bandwidth in the 900 MHz band for SRDs such as radio frequency identification (RFID) systems and mesh networks, which are increasingly in demand; discrepancies between the power permitted in US and Australian SRD bands and the New Zealand band. For further details of the analysis, see the May 2009 discussion paper. 2.2 Base Proposal The Ministry s base proposal for re-planning the band was to: allocate unused spectrum at MHz for fixed services, particularly STLs; harmonise the lower edge of the MHz band for SRDs with that of Australia (915 MHz), as illustrated in Figure 2 (page 8); and permit 4 watt RFIDs in MHz, with the same out-of-band emission limits used in Australia to protect adjacent services 3. The Ministry proposed to give current licensees in the MHz band (principally STL users) five years notice of the introduction of SRDs to the band, in accordance with the Radiocommunications Regulations Rather than revoking licences entirely, however, it was suggested that only a licensee s right to protection from interference be removed. This would allow STL users to choose whether to continue transmissions in areas where low density of SRDs means there is low risk of interference to the STL. It was also proposed that, while SRDs would not be permitted in the expanded part of the band on a general-user basis prior to the expiry of the notice period, licensing of SRDs would be permitted provided usage could be coordinated with existing STLs. This 3 Emissions below MHz must be no greater than -37 dbm e.i.r.p. and emissions above 926 MHz must be no greater than -33 dbm e.i.r.p Page 6 -

7 approach would enable higher power devices to be licensed in the MHz band during the transition period. Table 1: Proposed allocation changes for new fixed link band and SRD harmonisation Band Current Allocation Proposed Allocation MHz Unused Fixed links (STLs) MHz Fixed links (STLs) SRDs (following notice period) [whole band: MHz] MHz SRDs, 1 watt e.i.r.p. SRDs, 1 watt e.i.r.p. Sub-band MHz: RFIDs up to 4 watts e.i.r.p. (following notice period) In addition, the Ministry considered which spectrum management approach should be applied to the MHz band, of which half is owned by the Crown in a management right expiring in 2012, and half is administered under the radio licensing regime. The Ministry suggested that the management right approach would be likely to provide greatest benefit as it would deliver the most economically efficient allocation outcome over time. The proposal was for six of the eight megahertz to be sold at auction, in 0.5 MHz lots with a 2.5 MHz acquisition cap. Under the proposal, it was suggested the Crown would retain the remaining 2 MHz for allocation of spectrum licences to those broadcasters for whom it was uneconomical to purchase nationwide rights. 2.3 Variations to base proposal In addition to the base proposal, the Ministry sought views on other possible changes to the band, as follows Variation 1 Simplex Land Mobile Radio Relocation Variation 1 suggested the relocation of the simplex land mobile radio allocation at MHz down to MHz, thereby enabling harmonisation of the upper boundary of the current MHz SRD band with the European allocation of MHz, as illustrated in Figure 3 (page 9) Variation 2 Alternative Use of MHz SRD Band The Ministry suggested that this band might be suitable for allocation to a different use given it is not harmonised with any major trading partners SRD bands. Feedback was sought from any existing users and potential new users on an appropriate service Page 7 -

8 2.3.3 Variation 3 Reuse of Orphan Cellular Spectrum The Ministry sought suggestions on how unused guard band spectrum held by 2degrees in management rights at MHz and MHz, and expiring in October 2012, might be best utilised following expiry. This information will assist the Ministry with development of any renewal offer Page 8 -

9 Illustrations of Re-planning Proposal and Variation 1 Figure 1: Current band plan, MHz C = Crown management right N = 2degrees Mobile management right T = Telecom management right V = Vodafone management right Figure 2: Proposed new fixed link band and 900 MHz long-term SRD harmonisation Page 9 -

10 Figure 3: Variation 1 (Proposed new fixed link band, long-term SRD harmonisation and LMR simplex relocation) C = Crown management right N = 2degrees Mobile management right T = Telecom management right V = Vodafone management right Page 10 -

11 3. Submissions Submissions were received from the following organisations/individuals. The Ministry has published all submissions on its website Name Interests in the band 1 Arc Innovations Advanced metering infrastructure user 2 Bay Networks Land mobile radio user 3 Department of Conservation (DOC) Land mobile radio user 4 4RF Communications Fixed service equipment manufacturer 5 Gallagher Group Manufacturer of equipment incorporating RFID 6 Kordia Fixed and land mobile radio service provider 7 Metrix Advanced metering infrastructure user 8 Motorola Land mobile radio equipment manufacturer 9 Mount Campbell Networks Limited Broadband wireless access service provision 10 NZ Amateur Radio Transmitters (NZART) Radio Amateurs 11 Pathfinder Group/EPCglobal New Zealand RFID suppliers 12 Radio Broadcasters Association (RBA) Studio-to-transmitter link users 13 Radio Frequency Users Association of New Zealand (RFUANZ) Land mobile radio users and service providers 14 TeamTalk Fixed and land mobile radio service provider 15 Telecom NZ Cellular mobile network operator 16 Tesa SRD supplier (weather stations) 17 Times-7 RFID manufacturer 18 Tony Brown Approved Radio Engineer 19 TrustPower Advanced metering infrastructure prospective user 20 2degrees Mobile Cellular mobile network operator 21 Vodafone Cellular mobile network operator 22 WEL Networks Advanced metering infrastructure user 23 Wellington VHF Group Radio Amateurs 24 Widarcom Land mobile radio user 25 Wireless Control Systems SRD supplier Page 11 -

12 A summary of responses by submitters to each of the questions the Ministry posed in its discussion document is attached as Appendix A. The Ministry also carried out additional consultation with several stakeholders after receiving submissions to expand on issues raised and work through possible obstacles that had been identified. The Ministry s proposals for re-planning the band are analysed in the next section, in light of the submissions and information received Page 12 -

13 4. Analysis 4.1 Base Proposal There was general support from submitters for the proposed changes. The MHz band was considered, with some caveats, to be suitable for use by STLs, and there was strong support for increased harmonisation of the SRD spectrum with the European, US and Australian bands. In general, the submissions indicated greatest concern with the issues of transition timeframe and costs relating to opening the MHz band to SRDs, and the management framework for the MHz band. These issues are analysed in the following sections Suitability of spectrum for proposed services MHz band Two alternative uses for the MHz band were suggested by submitters: bi-directional fixed services (pairing part of the band with MHz), or wideband land mobile radio. In weighing up these suggestions against the proposals, the Ministry notes that there is still a reasonable amount of capacity in the KK (fixed link) band, and that standards for UHF digital wideband radio systems are still under development, making allocation for that purpose premature. Meanwhile, the STL bands are heavily used, particularly in the main cities, indicating a high level of demand. Therefore the MHz band currently used for STLs cannot be opened for use by SRDs without providing a replacement STL band. With respect to the suitability of the MHz frequencies for use by STLs, the principal issue identified was the potential for interference to Telecom s W-CDMA base station receivers operating up to the 840 MHz boundary of the Telecom management right. This interference would arise as a result of the adjacent channel selectivity (ACS) of the W-CDMA receivers. An analysis of the interference potential of current STLs in the MHz band, if shifted in frequency to within the W-CDMA first adjacent channel ( MHz), indicated that 51 existing Telecom base stations would be affected 4. The interference could be mitigated at all but one site by fitting antenna filters to the base stations. However, for the filters to work effectively, a frequency separation of 3.5 MHz would be required for STLs likely to cause interference (i.e., licensing at that location would need to be at a frequency above MHz). 4 Some additional isolation might be achieved by placing the interfering STLs in the second adjacent channel ( MHz), but the current 3GPP standard does not specify the ACS of the second adjacent channel. If ACS improved in the second adjacent channel, fewer base stations would be affected Page 13 -

14 Any STLs of which harmful interference could not be mitigated by an antenna filter being fitted to the mobile base station would need to be licensed in an alternative STL band (unless the transmission power could be reduced). Emission-shaping filters may also need to be fitted to some STL transmitters to reduce the likelihood of harmful interference to the adjacent cellular service. This will depend on power, location (separation between the sites) and frequency. The Ministry considers that the potential for interference to the cellular mobile service by STLs can be addressed through the use of filtering and appropriate coordination when licensing the services MHz band In respect of the proposal to permit STLs to remain in the MHz band after the five-year notice period, but without protection from interference, some submitters expressed concern that this would deny access to part of the band for the SRDs. The Ministry agrees that this would be the case in the immediate path of the STL transmit antenna, but notes that due to the potential for SRDs to interfere with any STLs remaining in the band, it is likely that STL licences in this band will only be retained for locations where there is a low density of SRDs. The Ministry therefore expects the practical impact on SRDs to be very low. Regarding the proposal to introduce a new range of frequencies specifically for higher power RFIDs MHz, harmonising with Australia submitters raised two key issues: RFID users would prefer these devices to be permitted in a larger range of frequencies to provide sufficient bandwidth to allow for the anticipated ubiquitous uptake of this technology; and users of radio mesh networks for smart metering suggested it was inappropriate to restrict the band to RFID; permitting higher power devices to be used in the mesh network could enable geographic or technical constraints to be overcome. The Ministry notes that, in both New Zealand and Australia, the lower adjacent frequencies are used for mobile base station receivers and the higher adjacent frequencies are used for fixed services. Frequency separation and/or power limitations are required to prevent interference from SRDs into these adjacent services. The Ministry considers that it is not practicable to permit higher power SRDs to operate in the whole MHz range of frequencies. However, a greater range of frequencies than the MHz proposed could be used, by enabling devices with a maximum transmitter power of 1 W, and employing frequency hopping or digital modulation techniques, to operate with gain antennas up to a peak power of 4 W e.i.r.p. The Ministry has concluded that it is suitable to permit use of such devices within the MHz frequency range. This will enable closer alignment with the US band to be achieved, and will allow use of a wider range of technologies than just RFID. Implementing out-of-band emission limits as specified for the Australian MHz band will ensure protection for adjacent services Page 14 -

15 It is not clear whether a specific band for RFIDs with transmitter power of up to 4 watts will continue to be necessary as initially proposed. The Ministry will address this issue prior to opening the new SRD band from 915 MHz. Allocation of MHz for STLs The MHz frequencies are currently available for SRDs and Radio Amateurs under general user radio licences. Some submitters noted that there was likely little benefit being derived from the inclusion of the frequencies at MHz in the current band for SRDS ( MHz) given that this is not harmonised with the Australian and US bands in particular, both of which cease at 928 MHz. The band is not widely used by Amateurs, nor is it harmonised internationally. It was suggested that this spectrum would be better allocated to STLs, which are licensed in the adjacent spectrum MHz. The Ministry concurs, and proposes that this spectrum be used to assist with the transition of licensees from the MHz band. s also suggested that the MHz could be exchanged for 1 MHz of spectrum for SRDs, e.g., MHz. This would enable greater use of harmonised spectrum for some devices, e.g., smart meters. However, existing users would still require to be transitioned out of the MHz. The Ministry encourages prospective users of the MHz frequency range to liaise with incumbent licensees about this possibility. If industry supported an early transition, the Ministry would seek to facilitate this Transition Incumbent users of the MHz band and prospective users presented contrasting views on the timing for transitioning the use of the band. On the one hand, the Radio Broadcasters Association (RBA) stated that five years was insufficient time for its members to move from the band. This was because it is not possible to retune STLs operating in this band to the new band in 800 MHz, meaning that equipment that was still operable would need to be written off. The RBA also suggested that such a short transition period was not justified as demand for use of the band for SRDs appeared to be minimal. On the other hand, SRD users/suppliers indicated that they sought access to an expanded band immediately, and that there was an opportunity cost to them of not having access to the band now. They also noted that it was not possible to apply for site licences in every instance, which was a suggested option to enable shared use of the MHz band in the interim. A balance must be struck between recognising the rights of existing users and facilitating new users who may realise greater benefits from the use of the spectrum. The Regulations do envisage parties negotiating transition arrangements if less than five years notice is to be given, but to date such a negotiation has not occurred in respect of the MHz band. It is an expectation of using a radio licence that it may be cancelled without compensation if five or more years notice is provided, and the Ministry sees no special case in this instance to provide additional relief. The Ministry therefore intends to give Page 15 -

16 five years notice to incumbent licensees of the change to the MHz band as soon as coordination guidelines for the 840 MHz interface have been finalised. s deploying mesh networks advocated for an additional transition period, such that 4 W devices would only be permitted in the expanded SRD band ( MHz) after it had been available for the use of 1 W devices for a year. This was to allow existing devices to be reconfigured to operate across the full MHz range of frequencies before any undue influences from 4 W devices. The Ministry does not accept that an additional transition period is required, as the devices in the band will be required to operate on an equal basis and will need to co-exist. s wishing to use higher power RFIDs requested that they be permitted to use some 900 MHz frequencies, if not the full range proposed, as soon as possible. During the transition period, STLs will continue to operate up to 921 MHz. Until their protection from interference is removed at the end of the transition period, they require adequate protection from RFIDs. This can be achieved by introducing a 0.5 MHz guard band and adopting -33 dbm as the unwanted emission limit. This would enable the MHz band to be used during the transition period by 1 W devices using gain antennas with a maximum radiated power of 4 W e.i.r.p. The Ministry proposes to amend the SRD GURL immediately to include this band. One submitter intending to deploy a region-based mesh network (Waikato) noted that there is little use of the MHz band for STLs in that region. It was suggested that an accelerated transition process might be possible in this case. The Ministry encourages prospective users of the MHz range of frequencies to liaise with incumbent licensees about this possibility. If industry supported an early transition for a particular region, the Ministry would seek to facilitate this (e.g., through a specific regional General User Radio Licence for fixed SRDs) Management of the MHz band No submitters supported the MED proposal to allocate the MHz band as management rights, although one submitter noted that there was no current pricing mechanism to signal the costs of STL spectrum use. The objections to the management of the band under the tradeable management rights regime included: there is no need to allocate rights through a competitive process as there would be sufficient supply of frequencies for STLs; perceptions of high cost to purchase management rights; perception that as the broadcasters had paid market rates for spectrum licences for actual broadcasting, they should not have to pay market rates for spectrum simply used as an inexpensive means of transporting programming from the studio to the transmitter; perceived loss of the frequencies for a significant period of time, making it unavailable for future potential users; assessment that this would result in denial of access to the band for small broadcasters; and Page 16 -

17 assessment that managing the band under management rights would remove flexibility and make spectrum efficiency less achievable. In respect of the last two points in particular, the Ministry notes that new information emerged during the consultation process which relate to those concerns. Telecom identified that a frequency separation of up to 3.5 MHz between STLs and the Telecom band will be required in locations where it needs to fit filters to protect its base station receivers. This means that the full range of MHz would not be available for STLs in all locations. Management rights normally allow for nationwide geographical coverage, but if used in an affected area, there would be licensing restrictions in some locations. Therefore only 5.5 MHz could be allocated to the market without any geographical restrictions, rather than the 6 MHz proposed. The proposed retention by the Crown of the remaining 2.5 MHz ( MHz) would also constrain the Crown s ability to meet all expected needs. After reviewing these issues, the Ministry has changed its recommendation concerning the allocation of the spectrum as management rights, and believes that administrative radio licensing would be the most effective management approach to use as it will enable maximum flexibility for licensing. There are no provisions in legislation to cancel a management right, i.e., the Crownowned right over MHz, which expires on 29 October Until that time, spectrum licences can be issued if necessary, which will be converted to a radio licence upon expiry of the management right. 4.2 Variations to base proposal Variation 1 Simplex Land Mobile Radio Relocation There was general support for the concept of greater harmonisation of the current MHz SRD band with the European SRD band ( MHz). However, incumbent users of the MHz band (simplex land mobile radio), which could not share the band with high power SRDs, indicated that there was a lack of equipment that could tune to the proposed replacement band for simplex land mobile radio at MHz. It was identified that any replacement band needs to be within the range MHz. Suggested alternative frequency ranges for a simplex land mobile band included: 1. taking 1 MHz from the KK band, e.g., MHz this would orphan MHz, with which it is paired; 2. taking 1 MHz from the TS band, e.g., MHz - this would orphan MHz, with which it is paired; or MHz. Using the MHz band (suggestion 3 above) for simplex land mobile services is not considered practicable in New Zealand because the upper adjacent frequencies are Page 17 -

18 used for cellular services (mobile receive). The itinerant nature of simplex services means that there would be a risk of interference into this band and mitigation through additional filtering to mobile handsets is impracticable. While suggestions 1 and 2 are practicable, on balance the Ministry considers that, rather than displacing other services, the feedback from organisations wanting to supply SRDs in the MHz band suggests that the simplex land mobile radio service would not need to be relocated in order for this to occur. The Ministry noted that there was no particular demand for use of higher power SRDs in the MHz frequencies. The demand rather appears to be for devices with very low power and low duty cycle. Use of the to MHz frequencies by 10 mw devices with a 0.1% duty cycle is already permitted. The Ministry considers the potential for harmful interference with the incumbent land mobile radio services by devices with such low output power and intermittent signal to be low, and that it will diminish further as land mobile radio continues the transition to digital technology. SRD use under general user licence is permitted on the basis of not interfering with licensed services, and while there may be some rare instances where degradation could occur and require cessation of SRD use, the benefit in permitting operation of the great majority of devices without any adverse effects outweighs the disadvantages. The Ministry therefore proposes to include an amendment to the General User Radio Licence for SRDs to permit use of the MHz band by devices with up to 2 mw e.i.r.p. and 1% duty cycle Variation 2 Alternative Use of MHz SRD Band No submitters indicated that they currently use this band. It seems likely, as the Ministry surmised, that it is unused given that it is not harmonised with the SRD bands of any major trading partners. Aside from the Ministry s proposal that 1 MHz of this band might be allocated for simplex land mobile radio use (which, as discussed above, was found not to be viable), there were three suggested alternative uses of the MHz band: allocation for STL use; or allocation for bi-directional fixed links, paired with 5 MHz in the MHz band; or allocation for trunked mobile radio use, paired with MHz to more closely align with US spectrum allocation and to provide for future expansion of land mobile radio use. The Ministry did not consider any of these suggestions to be preferable to the status quo. There is benefit in retaining MHz for SRDs so that New Zealand can benefit from economies of scale available by importing equipment manufactured for the European market. The MHz band is to be allocated to STLs (as discussed under 4.1.1) and so suitable spectrum would not be available for pairing in order to allocate MHz for bi-directional fixed links Page 18 -

19 Therefore, for the time being, this band will remain allocated to SRDs. As one submitter noted, however, rapid technology developments may create future spectrum access requirements or new opportunities for this band in the future Variation 3 Reuse of Orphan Cellular Spectrum The Ministry will consider feedback that it received from submitters on possible uses of the guard band spectrum, currently held by 2degrees and expiring in 2012, when it determines any renewal options for 2degrees management rights in the 800/900 MHz bands. Suggestions from submitters on uses of the spectrum were: MHz MHz allocation for fixed service applications, allowing for around 12 channels with 75 khz spacing, or a similar narrow band arrangement; allocation for STLs; or continuation of use as a guard band between the cellular mobile service and STLs. continuation of use as a guard band between European and North American cellular systems; use by applications employing digital modulation or frequency hopping technologies; or partial use for mobile services by 2degrees, subject to a frequency pair being found and suitable management of the interface between the different cellular systems in the 850 MHz and 900 MHz bands. 4.3 Other Issues Amateur Service Current Amateur use of the MHz band is limited to 25 W e.i.r.p. Amateurs requested that the radio amateur GURL be extended to 915 MHz also, and if higher power SRDs are permitted, then Amateurs would seek a similar relative increase, i.e., to 100 W e.i.r.p., to mitigate the effects on Amateur communications. The Ministry considers that the band available for Radio Amateurs could be extended to 915 MHz, similarly to the SRD band, after the five-year notice period. This would be subject to suitable coordination with adjacent spectrum usage (Vodafone). As indicated above, the top MHz will also be removed immediately from the Amateur service GURL to enable full use of the spectrum by STLs. The Ministry does not consider, however, that the suggested power increase is warranted. The Amateur community currently only has access to reused and lower Page 19 -

20 power transmission equipment, and the band is not internationally harmonised for Amateur use. No significant degradation to the current services is considered likely given the anticipated use by Amateurs Fixed Service A suggestion regarding the KK fixed links band was to consider introduction of a 250 khz channel spacing, in addition to the existing 500 khz raster. A submitter also noted that the L and LL bands (within the MHz frequency range) are relatively congested. The Ministry intends to undertake a review of fixed service bands in 2010/11 with a view to determining how to transition these bands to fully digital transmissions. These issues will be considered in that review Land Mobile Radio Service One submitter noted that the trunked land mobile band was congested in metropolitan areas, and suggested that this could be alleviated by restricting use of the band to digital technology only. The Ministry considers that, having opened the band to digital services in 2008, it is too soon to require users of analogue technology to vacate the band or convert. It is expected that the introduction of digital services over time will ameliorate the congestion Short-range Devices Several submitters indicated that it would be beneficial for them if the listen-before-talk (LBT) and frequency hopping spread spectrum (FHSS) features of RFIDs were optional for both the MHz and MHz SRD bands. With respect to LBT, the Ministry notes that this is not a requirement for RFIDs using the MHz band. It can be expected that the majority of RFIDs that would be used in the MHz band would be sourced from manufacturers supplying the US market (the US SRD band in this frequency range being MHz). The US band does not require LBT, and the Ministry does not consider that it is warranted to impose this extra requirement on use of the devices in New Zealand. In the case of FHSS, however, the Ministry assesses that feature should be required for both bands, noting that this is specified for devices operating up to 4 W radiated power using these bands in other main markets. The advantages of having FHSS include: the power spectral density of the devices is distributed (lowered) across the band, therefore minimising potential interference to adjacent services and also to other in-band receivers; and the channelisation of the band by means of FHSS allows better frequency reuse of the band and increased capacity for numerous ubiquitous devices sharing the band. Lifting the FHSS condition would result in FHSS equipment from Europe and the US not being able to easily co-exist, in the same band and geographical area, with devices that do not have the FHSS feature. The Ministry does not see that as practical for a general user band Page 20 -

21 4.3.5 Cellular Mobile Service 2degrees commented in its submission on the need for the mobile network operators to have like for like spectrum (i.e., it should hold as much spectrum as both Telecom and Vodafone, which each have 15 MHz paired compared with 2degrees 9.8 MHz of useable paired spectrum). 2degrees suggested that MHz should be paired with MHz, giving it 14.8 MHz paired, to enable true competition to develop on an equal spectrum cost basis. The Ministry notes that this proposal would place a mobile transmit and a mobile receive band immediately adjacent to each other (Telecom s mobile transmit band is MHz). In order for the full 5 MHz to be used, expensive filtering and antenna separation would be required. Partial use of the band might be possible, provided suitable management of the interface could be achieved Page 21 -

22 5. Next Steps The following changes will be made in the MHz band: Frequency range Current usage New usage Timeframe MHz (Crown management right, expiring 29 Oct 2012) None Fixed service (STLs) (To revert to radio licensing regime following expiry of management right) After expiry of management right, but spectrum licences may be issued if necessary in the meantime, to be converted to a radio licence after expiry MHz None Fixed service (STLs) As soon as possible in 2010 following finalisation of coordination guidelines for 840 MHz interface MHz Simplex land mobile radio ( MHz) SRD (10 mw, 0.1% duty cycle, MHz) In addition to current use: SRD (2 mw, 1% duty cycle) July MHz Fixed service (STLs) SRD ( MHz) (1 W e.i.r.p.) SRD (3 mw e.i.r.p., MHz; 1 W e.i.r.p., MHz) Amateur service ( MHz) Amateur service (no change to output power limit) Fixed service (STLs) with no protection from interference as part of licence Five years after notice is given to existing licensees in MHz band Site licensing for appropriate SRDs to be permitted immediately MHz SRD employing FHSS July 2010 or digital modulation MHz Five years after notice (1 W maximum given to existing transmitter power, to licensees, as above maximum of 4 W e.i.r.p. with gain antenna) * MHz SRD and Amateur service Fixed service (STLs) July 2010 * The Ministry will review the need to specifically permit RFIDs with transmitter power of up to 4 watts prior to expiry of the transition period Page 22 -

23 Changes to frequency ranges used for SRDs and the Amateur service require the General User Radio Licences to be amended. The Ministry expects to be able to make these changes in July Coordination guidelines for managing the 840 MHz interface between the cellular mobile service and STLs will be developed in consultation with Telecom and STL users. Following this, five years notice will be given to licensees in the MHz band that the band will be opened to SRDs. The Ministry expects this to occur in 2010, meaning that final transition to full use of the MHz band by SRDs will be in Page 23 -

24 6. Glossary 3GPP e.i.r.p. GSM GURL LMR RFID SRD STL TETRA UHF W-CDMA The 3rd Generation Partnership Project: the production of technical specifications for a 3rd generation mobile system based on the evolved GSM core networks. Equivalent isotropically radiated power Global System for Mobile communications General User Radio Licence Land mobile radio Radio frequency identification Short-range device Studio-to-transmitter link Terrestrial Trunked Radio Ultra high frequency band: MHz Wideband Code Division Multiple Access Page 24 -

25 Appendix A: Summary of submissions Question 1: Do you consider that the Ministry should investigate any other options for further rationalisation of spectrum for cellular applications in the MHz band? If so, please explain. Arc Innovations Yes, see Q26. Kordia Metrix RFUANZ TeamTalk Telecom 2degrees No. Yes. No. Extensive spectrum is available for cellular services in other bands. No, seems to have been reviewed sufficiently. Usage of bands adjacent to Telecom s management rights should not be inconsistent with Telecom using any or all of the three W-CDMA channels with uplinks in MHz and downlinks in MHz. Adjacent band sharing needs to be no worse for compatibility than sharing between W-CDMA channels within Telecom management rights. The current allocation [of spectrum to 2degrees] in this band is not sufficient for future needs. Current allocation is 9.8 MHz paired, and in order to move to like-for-like full 3G network, 2degrees needs 10 MHz paired, allowing 2 x 5 MHz 3G channels. This spectrum band should be reviewed as part of a wide-ranging policy review that considers all inputs into wireless competition. MED failed to ignite competition between 1999 and 2009 because it deferred to incumbent investors and failed to consider the impact of the network effect on potential entrants. A more synchronised approach is needed to the way spectrum is managed and competition policies are set; recommends passing spectrum management function to the Commerce Commission. MED also now has a conflict of interest in managing spectrum because of its role developing a statefunded broadband network. Most marginal spectrum allocations relate to wireless data, and as a consequence, growth in this area will marginalise the prospects of a fibre network. The limited resources of the private sector will conflict with the unlimited resources of the Government. Appendix states that priority should be given to security for the spectrum assets of the three mobile network operators Page 25 -

26 Question 2: If your organisation uses the KK band ( MHz and MHz), do you consider that the Ministry s assessment of utilisation of the band is accurate? If not, please explain. 4RF Communications Kordia TeamTalk Congestion is starting to be seen outside the major population centres, for example in the Waikato. Railways has begun using the KK band. Growth in use of this band and relative congestion in L and LL bands indicates that available spectrum does not meet demand. The assessment is accurate. The assessment is accurate. Question 3: If your organisation has STL licences, do you consider that the Ministry s assessment of the utilisation of the sub-bands ( MHz, MHz and MHz) is accurate? If not, please explain. DOC Kordia RBA Telecom Tony Brown 2degrees Agrees there is pressure on the band. However, not all measures previously identified to relieve congestion have been implemented (consolidation of common path STLs, use of digital technology). If additional spectrum is provided for STLs, a similar situation may arise in future unless the way STLs are used changes. The assessment is accurate. Agrees with assessment. The potential for digital technology to improve spectral efficiency is limited due to equipment availability, which is more costly than analogue equipment and no more spectrally efficient. Bit rate compression would offer efficiencies, but is not practical for broadcasting when the programme comes from various sources and already has been compressed, e.g., calls to radio via heavily compressed cell phone link. Harmonisation with the US 950 MHz band for STLs would provide economies of scale for digital equipment, but the band is allocated to cellular services in New Zealand. It is important to establish whether there is a real congestion issue in the current STL band which would require the use of the 850 MHz band for STLs. The demand for this type of linking is not certain and there is currently no pricing mechanism to signal the costs of STL spectrum use. STL spectrum is being freed up by operators such as Telecom as STL links are retired; there are other technologies available for linking, such as copper or fibre circuits or microwave bearers; and ongoing technical management or link rearrangements may free up further spectrum in the current STL band. Agree, there is a shortage of STL frequencies, especially in the three major cities MHz should be paired with [the current STL band] MHz to increase the 900 MHz 3G capability to a like-for-like basis to that of Vodafone. This would enable true competition to develop on an equal spectrum cost basis Page 26 -

27 Question 4: If your organisation uses any of the land mobile radio sub-bands ( MHz and MHz, and MHz), do you consider the Ministry s assessment of current usage to be accurate? If not, please explain. DOC Kordia Motorola RBA RFUANZ TeamTalk Tesa Widarcom ITU has recommended that PPDR wideband services be accommodated in part of this band. Standards for UHF digital wideband radio systems are still to be developed. Existing emergency service D band ( MHz paired with MHz) is small and may not be large enough for deploying those technologies. More investigation is needed to ensure sufficient spectrum will be available for those services. Yes. Ministry s statement that Australia has partially harmonised its allocations with the US, although it has used a different duplex spacing is not accurate. Australia s frequency allocation is not fully aligned with the US allocation, but the duplex spacing is the same. Notes that the Ministry suggests that lack of LMR simplex equipment that can operate at MHz is a reason that the MHz band cannot be better harmonised with European SRD band, and points out that the STL use of MHz is a parallel situation, as cost-effective and reliable STL equipment that can operate outside of MHz is difficult to find. Yes. Agrees with the Ministry s assessment, but notes that there was no discussion of likely future demands. The MHz A band has become largely unusable because of high noise level; the EN and EE bands are heavily used throughout the country; C and D bands are heavily used in the cities and the upper F band is being used for public safety purposes in some areas. Accordingly, 800 MHz services are increasingly being used, especially as new digital services are being introduced. New applications are likely to increase the popularity of LMR services. The TX band is shared with a considerable volume of SRD analogue devices with less than 3 mw e.i.r.p., with no reported interference. As LMR technology is developed in this band, digital modes (with error correction) can be expected to minimise any unwanted signal from shared SRD usage. Uses the LMR sub-bands for TETRA radio transmissions. Notes that digital equipment is also licensed in the TX band (discussion paper stated analogue equipment only was licensed in this band). The TX band frequencies are vitally important to the digital radio future as there are specific functionalities in TETRA radio which utilise simplex frequencies as a method of extending coverage areas where there is no realistic trunked mode coverage available. The suggested transition of the TX band to MHz is not compatible with the TETRA 800 MHz standard (simplex operation is only available between MHz) Page 27 -

28 Question 5: With respect to the harmonisation of New Zealand s SRD spectrum in the MHz band, do you have a preferred ITU Region or trading partner with which New Zealand s allocation should be harmonised? Please explain your preference. Arc Innovations DOC Kordia Metrix Motorola Pathfinder Group/EPCglobal NZ RBA Tesa Times-7 Prefers alignment with Australia, as this will give New Zealand-based companies access to technology without requiring modification, as well as ability to leverage off regional volumes. At present the limited bandwidth available impacts on the usability of the SRD technologies and complicates deployments. Ideally should also match the European SRD band as closely as possible, suggests adopting a band from MHz, and allowing an e.i.r.p. of 1 W for digital modulation or frequency hopping transmitters compliant with AS/New Zealand 4268; and analogue transmitter types at a maximum e.i.r.p. of 25 mw. The band should be harmonised with both the Europe and North America markets MHz seems to have no international equivalent for SRDs and should be kept in mind for possible new applications. The band should be harmonised as much as possible with Australia, which would make it easier to access technology and leverage off regional volumes. Ideally should also match the European SRD band as closely as possible, suggests adopting a band from MHz, and allowing an e.i.r.p. of 1 W for digital modulation or frequency hopping transmitters compliant with AS/New Zealand 4268; and analogue transmitter types at a maximum e.i.r.p. of 25 mw. Current frequency allocations for SRDs in the MHz band in New Zealand provide a degree of harmonisation with Europe, the US and Australia. Motorola supports this approach. Prefers alignment with the US allocation of MHz and other countries that are partly harmonised with this, e.g., Australia, Brazil, Canada, China, Hong Kong, Korea, Malaysia, South Africa and Taiwan. Reasons: gives access to cheaper products through economies of scale, an improved supply capability, a more secure risk profile and a closer alignment with the leading countries in UHF RFID adoption. Moving away from the EU allocation would also mean not having to use RFID readers with the Listen Before Talk feature. Evidence suggests that current allocations are adequate. Interested in marketing and distributing weather stations that are intended to operate in the European SRD allocation MHz. The weather station products use frequencies between and MHz. The minimum but sufficient extended SRD band that would satisfy Tesa is MHz. Matching Australia s 4 W e.i.r.p. allocation at MHz should be a minimum goal. Matching the US MHz allocation would be ideal. Maintaining the existing MHz band, with 4 W e.i.r.p. emissions permitted as at present, is also desired to protect existing investments. In addition, would like the Frequency Hopping Spread Spectrum restrictions removed Page 28 -