Australian Broadcasting Corporation

submission to

Australian Communications and Media Authority

Strategies for Wireless Access Services Spectrum Planning Discussion Paper SPP 1/06

March 2006

Australian Broadcasting Corporation Submission to the Australian Communications and Media Authority on Strategies for Wireless Access Services

Introduction

The Australian Broadcasting Corporation (ABC) welcomes the opportunity to respond to the discussion paper “Strategies for Wireless Access Services.”

The ABC notes that the paper represents an initial step by the Australian Communications and Media Authority (ACMA) towards developing spectrum strategies appropriate for wireless access services and that the proposals raised represent possible approaches, rather than firm policy positions. The Corporation understands that this paper does not discuss market allocation mechanisms for spectrum in detail and that, if support is demonstrated for the allocation of additional spectrum for wireless access services, the consideration of allocation mechanisms will be the subject of future consultation. The ABC further notes that the allocation and regulatory implications of emerging technologies such as ultra-wideband (UWB), software-defined radio and cognitive radio will also be the subject of future consultation papers.

As the ABC’s use of the radiofrequency spectrum is confined to a relatively small number of bands, the Corporation’s band-related comments are confined to those bands in which it currently operates services or which are likely to affect its operations.

The ABC submission, particularly its views on wireless access services demand and issues regarding the 2.5 GHz electronic news gathering (ENG) band, should be considered as complementing the data already provided and views expressed in the Free TV Australia submission to this inquiry. In particular, the ABC wants to support the reasons for and nature of use of the 2.5GHz band for ENG, TVOB (Television Outside Broadcast) and EFP (Electronic Field Production) as highlighted in the Free TV Australia paper and its relevant Appendixes. These references provide certain details that the ABC does not intend to repeat here in the interest of brevity. The details so provided therein that the ABC specifically wants to support include:

- the meaning of the terms ENG, TVOB, EFP; - how broadcasters derive those three different uses from the same spectrum and how the spectrum is shared between broadcasters to increase the combined productivity and the efficiency of the overall spectrum employed; - how such use is tied up with the brief of the free-to-air broadcasters to provide some local, regional, news and current affairs, sports and other program content; and

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before the audiences enjoy these programs, what are the business necessities to manipulate, collect and distribute such content prior to production and transmission; - what audience experiences in general may suffer some impact from the loss of flexibility and availability of the appropriate and adequate spectrum for these three services; - what are the characteristics of the spectrum sought for those three services and why those characteristics are best suited to the 2.5GHz spectrum in use at present; - how adjacently allocated channel plan in use by broadcasters facilitates sharing if contiguous spectrum is employed for the channel plan; - what is the nature and quantum of investment made by the broadcasters in moving these services to digital to suit the new channel plan requirements prescribed by the ACMA; - how many other countries employ the same 2.5 GHz spectrum for their broadcasters to provide similar services within those countries; and, - why the loss, if any, of the 2.5GHz band spectrum access for these services will not be adequately compensated, particularly when the world is on the cusp of increased high definition production and a whole range of new broadcasting applications that will put further huge demand on the spectrum for these services and given what broadcasters are planning to do with their 2.5 GHz spectrum access in the short to medium term future as well.

In addition to that, the ABC has also provided relevant details of its own use and its own additional views particularly within the context of the specific questions raised by the ACMA discussion paper.

Issues for comment

Spectrum demand

While the ABC understands the ACMA’s reasons for seeking to develop a wireless access services strategy, it notes that the quantum of the Australian public’s appetite for such services remains largely a matter of conjecture. By comparison, much of the spectrum proposed for use by wireless access services is occupied by mature and established services. The Corporation believes it would be inappropriate for the ACMA to adopt a strategy that caused the current spectrum occupants to vacate bands simply to make way for essentially untested services. The ABC would expect the ACMA to weigh up the alternative demonstrated uses for spectrum against the incumbent uses and the impact of the new uses on those incumbent services, taking account of the wider public interest and industry impact.

Accordingly, the ABC believes that the ACMA should allocate spectrum for wireless access services incrementally. The ACMA should make a limited initial allocation, after which it

Australian Broadcasting Corporation Submission on Strategies for Wireless Access Services 3 should spend a period monitoring the market to identify whether it is necessary or desirable to allocate further bands for such services. Only when it has been demonstrated that there is a genuine, end-user demand for wireless access services should further spectrum be allocated.

It is also unclear at this stage whether the so-called “IMT Advanced” or “Beyond IMT” services include the wireless access services generally referred to as 802.11 (Wi-Fi) and 802.16 (WiMax and WiBRo) technologies. The actual spectrum required for wireless access services would depend on such inclusion and this topic is currently under active discussions in the ITU-R Working Party (WP) 8F. This is yet another reason why an incremental approach will better suit Australia’s long-term objectives for all of these services.

Further, there is an outstanding question about co-existence or separation of different wireless access technologies in spectrum bands. As some wireless services are short-range, it is possible that services such as 802.11 may share the same spectrum space as 802.16 services. However, their potential to share with other services within the IMT suite is unclear. The incremental approach will allow adjustments down the track for what might get accepted or evolve in the market place.

The ABC believes that it is highly likely that demand for wireless access services will differ between cities and regional areas and will be affected by, among other things, broadband services provided by wire lines.

Given that wireless access services are, by definition, Internet access services delivered wirelessly using radiofrequency spectrum, the ABC would expect that services carried over such spectrum would be subject to similar regimes as wire-line Internet services, including the Telecommunications Access Regime evolved by the Australian Communications Industry Forum (ACIF). If such an approach is not adopted, the overall spectrum requirements could be quite high, as different spectrum bands would need to be found for different operators at the risk of underutilisation of some bands.

The ABC supports the adoption of open and internationally standardized wireless access across Australia. Interoperability of systems is crucial to avoid build up of lots of small unconnected islands of services and operators.

Licensing approaches are discussed separately below.

Incumbent Users

In assigning bands for the wireless access services, the ACMA should apply a principle of minimising impact on existing services. The Authority should look to suitable (allocated or unallocated) unused bands in the first instance, and then to public use ISM bands, before considering bands that have dedicated incumbents.

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Further, the ACMA should demonstrate a compelling need, based on international identification of particular spectrum bands for allocation to wireless access services before attempting to eject incumbents. Australia’s commercial broadcasters have previously vacated the 2 GHz band at the behest of the regulator and at cost to them. The ABC notes that this band had not been widely utilised since then. Similarly, there is also spectrum allocated currently under spectrum licences that is ideally suited for wireless access services, but has been effectively unused until now.

Licensing and Allocation Approach

The discussion paper seeks comments on approaches to licensing spectrum for wireless access services.

Given the uncertainty over the quantum of spectrum required for wireless access services and that many of the candidate bands mentioned in the discussion paper have incumbent users, the ABC believes that the ACMA must be able to guarantee that bands allocated for wireless access services are actually used for such services. The Corporation is aware that, as spectrum licences make no stipulation about the use to which spectrum is put, it is entirely possible that bands planned for wireless access services and sold under current spectrum licenses may end up being used for something else entirely. Such an occurrence would undermine the ACMA’s strategy and create a situation where the regulator seeks further candidate bands for wireless access services.

The Corporation would be supportive of any mechanism that spectrum allocated to wireless access services is put to the use for which it was intended.

Public Park Licensing

The ABC is supportive in principle of the idea of Public Park licensing. However, it is unable to assess it fully, given the sketchy details provided by in the discussion paper as to how exactly such licensing will work in practice. For example, it is unclear how the quality-of- service (QOS) services are to be provided by WAS operators under this model, whether the QOS and non-QOS wireless access services will both be operated under this model or just one of them and which one; and, if only one of them operates under this model, what other model will be applied to the other of them and in that case whether or not third-party access will be permitted/facilitated and how, etc.

While the discussion paper canvasses three options, the ABC is uncertain that any will work all that well in areas with high traffic density.

The site-based “command and control” approach in section 8.1.2 of the discussion paper is likely to become cumbersome if sites number in the hundreds, as seems likely to happen with wireless access services. This approach may work in very-thinly-populated areas, such as mining towns.

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The area-based “private spectrum” approach is likely to work well with apparatus licensing, but will limit the number of operators due to dead zones. Spectrum licensing results in the risk of spectrum lying fallow without additional “forced use” or “time-schedule conditions”.

The collision avoidance and collision detection approach described in section 8.2 works only when usage densities are not too high; otherwise the overheads consume most of the available capacity.

The licensing model set out in section 8.3 is prima facie attractive, but hugely challenging. It can be expected to work well initially when deployment is low. However, when deployment reaches critical mass, the approach is likely to generate innumerable disputes. Like the US Federal Communications Commission (FCC) model cited in the discussion paper, it replaces technical coordination and engineering design with ad hoc solutions negotiated between the various commercial and non-commercial private entities competing to use the spectrum. By comparison, the family of standards developed by the IEEE 802 committee rely on good technical co-ordination to work.

The ABC believes that the FCC model described in Section 8.3 could in fact result in a highly litigious regime over time. However, if the ACMA wishes to pursue this model, it may be best to refer the technical, equal-access and interconnection issues to the Australian Communications Industry Forum (ACIF) or a similar body for resolution.

The Corporation notes that comparisons are sometimes made between models of this kind and ENG. However, such comparisons are false, as ENG operators operate in accordance with a clear, dedicated channel plan, whereas this model does not recognise permanent notional channel allocation to operators on an equal basis.

The ABC is also of the view that any licensing arrangement suggested in the discussion paper can work, if no QOS services and/or no cross-carrier access are to be provided in the band to which that arrangement may be applied. For example this may be the case for WAS services in the ISM bands. Therefore appropriate licensing arrangement should be examined on their merits once appropriate spectrum and the intended nature (QOS or non-QOS) and cross-carrier access issues of the WAS service to operate in it are identified.

Candidate Bands

In general, the ABC notes that the present paper focuses on the bands below 5GHz. Some of the technologies and services discussed in the paper, for example, ETSI IEEE 802.16 and the Wireless Hiper MAN and ETSI Bran Hiper Access projects, have been discussing several higher frequency bands for certain applications. A full picture of the role of higher frequency bands in providing/complementing wireless access services is as yet unclear and therefore a closer look at this relationship (see Annex 1) will be needed sometime in the near future. Any definitive policy that focuses on only the bands identified in this discussion paper runs the

Australian Broadcasting Corporation Submission on Strategies for Wireless Access Services 6 risk of being only partially helpful to wireless access services operators in the medium-to- long term.

The overall issue will also be significantly impacted by yet another technology introduction: ultra-wideband (UWB). The ABC notes that the ACMA intends to examine allocation and regulatory implications of UWB in a future consultation paper. The ABC clearly sees some overlap in some of the objectives and services referred here and those that might be referred in a future UWB paper. The ABC cautions against too much isolated treatment of this overlap at this point in time.

The ABC provides the following specific comments in respect of candidate bands of interest to the ABC.

2500–2690 MHz (ENG and TVOB)

The ABC, along with other broadcasters, uses spectrum in these bands under a Television Outside Broadcast Network licence for electronic newsgathering (ENG), television outside broadcasts (TVOB) and electronic field production (EFP).

Australian television broadcasters (ABC, Networks Seven, Nine and Ten) are currently licensed to use 190MHz of spectrum in the 2.5 GHz band. Under arrangements agreed with the ACMA, each broadcaster is allocated a 23.5 MHz and 24MHz channel allocated sequentially across the band. A band plan showing allocations to each broadcaster is attached as Annex 3.

Each broadcaster uses, from time to time, its own channels as well as channels of other broadcasters through a sharing arrangement, whose plan is worked out in advance, but with actual co-ordination of frequency and equipment done at location as needed. This is made possible by the contiguous spectrum, over which broadcast ENG equipment is generally tunable. The tuning range is not so wide that broadcasters can use disjoint spectrum bands, nor is any equipment available in the marketplace that can achieve tunability over disjoint bands.

As the ABC notes in the Introduction section above, a range of useful information is provided about the broadcasters’ shared use of this band in the Free TV Australia paper and the ABC lists in the Introduction section the aspects that the ABC wants to support in particular. As a result, the following ABC discussion will be confined to the ABC specific matters or matters that the ABC wants to highlight further.

More details of the ABC’s ENG usage and equipment is given in Annex 2.

ENG (Electronic News Gathering) is a subset of the overall requirement of television networks for the transmission of video programming material from one point to another.

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ENG however is distinguished by the fact that it may be operated as a nomadic service, i.e., operated from a moving vehicle, helicopter, or an on-foot camera. The signal may be received by a local pick-up point, thence to a major pick-up hub via an OB link, or it might go directly to the major hub. The “mobility” aspect of ENG excludes the possibility of using antenna directivity in a co-ordination environment since the ENG antenna pointing can be constantly changing, or indeed in some situations the antenna will have a non-directional beam. This excludes the possibility of sharing spectrum-space with traditionally coordinated fixed services.

The majority of ENG operations take place in the major cities – since it is from there that the majority of the news stories emanate. But the requirement is not confined to the major cities. Bushfires, floods, human interest and other news stories can occur anywhere in areas readily accessed by air or ground transport. This suggests that at least some spectrum should be available Australia-wide for ENG use at short notice, if not the total amount available for use in the major cities and in the major corridors around the four metropolitan areas and their nearest satellite cities.

The definition of geographic boundaries for spectrum sharing between non-homogeneous services (e.g., ENG and terrestrial fixed) poses particular problems (as is evidenced by spectrum licensing), often resulting in the need for substantial buffer zones to adequately protect the quality and continuity of (sometimes) essential services. In some cases realistic boundaries that rely essentially on terrain blocking to provide adequate separation can be drawn. The boundary problems are compounded significantly however if airborne ENG operations are contemplated since potential terrain shielding advantages may be substantially lost.

Traditional analogue FM ENG services have operated with bandwidths in excess of 20MHz. The digitization of television services is seeing new digital transmission systems that can operate in bandwidths as low as 8MHz. But there are bandwidth/performance trade-offs that need to be considered that will again produce demands for bandwidth in excess of 20MHz. The tandem and two hop uses of ENG channels also mean full 24MHz are frequently needed by the operator.

The major difficulty will be meeting the “demand” in the worst case scenario, e.g., an important news story where several or all networks converge on a venue at short notice. This suggests that each network requires a “primary” right to at least a minimum amount of bandwidth, with sharing arrangements for situations where not all networks are present in a particular operational environment.

The discussion so far summarises the current usage trend.

What should also be borne in mind is that as broadcasters move to multi-channel operation and as HDTV becomes more popular, there will be two additional factors needing more

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ENG bandwidth. The first is the need to produce news and program in HDTV. The second is the need to produce more overall news and programming. This will be further helped by the incoming global trend of cheap, direct OB streaming applications. It appears at present that at the very minimum, broadcasters will need to retain existing spectrum bandwidth for the foreseeable future.

The 2.5GHz band is the only band licensed to broadcasters which is suitable for use for ENG. ENG refers to the live coverage of news and emergency events. Coverage of live on-the- ground news relies on use of 2.5 GHz spectrum to transmit the report from the location of the news event back to the studio for broadcast. This includes coverage of press, conferences, court reports, traffic reports, weather reports, State and Federal elections, emergency events and all other live news reporting that occurs outside the studio.

Program content gathered using the 2.5GHz band (ENG, TVOB and EFP) is integral to broadcasters’ programming schedules. Many hours are spent collecting the content outside the studio and transmitting it back to the station for integration into the program. Crews and equipment are constantly deployed in the band between 6am and midnight in major capital cities for ENG, TVOB and EFP purposes. The heaviest use occurs in Sydney and Melbourne.

A number of overseas jurisdictions, including many European countries and the United States, also use the 2.5GHz band for ENG, TVOB and EFP purposes. This not only helps in sourcing global equipment but also supports the use of domestic equipment in territories of other countries and use of other countries’ broadcasters collecting their content such as sports and news within the territories of Australia, without any equipment issues needing advance sorting out in emergencies and for short notice events.

Broadcasters currently share their ENG spectrum. This minimises spectrum needs but requires equipment capable of operating in all channels. If the spectrum band use were fragmented, the operational flexibility will be significantly reduced.

Annex-3 also lists many other services that currently successfully function and operate within this band. Some of these services are provided by satellites. Sharing with some other existing or future identified services is currently under study within the ITU WP 8F and other groups. Broadcasters are actively engaged in the international efforts to provide increased sharing with other services operating or likely to operate within this band, with a view to help the ACMA objectives of increased burden sharing and more spectrum productivity.

Broadcasters have made significant advances in sharing parts of this band with Broadcasting Satellite Services (Sound), also called BSS(S) Services. In several countries of the Asia Pacific, including Japan and the Republic of Korea, the BSS(S) bands are scheduled to be used for many different types of satellite delivered services, so the co-existence of ENG with BSS(S) services significantly improves the spectrum efficiency.

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Thus there are a range of services with which the ENG can share spectrum in certain situations, however, WAS services are not amongst them. Sharing with Fixed links in this or other bands where fixed links are operating is also difficult to achieve in practice as discussed below. Sharing with “beyond IMT-2000” or IMT Advanced services is currently under consideration at Working Party 8F.

It is well understood that the sharing of the radio frequency resource can take place in the dimensions of time, space, and frequency, or a combination of these. (Other sharing modalities such as spread spectrum are also possible). These three primary modes are considered in the following paragraphs:

1) Time sharing – Time sharing of bands with terrestrial fixed services in the context of this study is not a realistic option since terrestrial fixed services operate continuously, i.e., in their normal mode of operation they are “always on”. 2) Frequency (Band) Sharing – The sharing of bands on a frequency basis suggests the subdivision of the bands in question, requiring existing and future fixed services to be compacted into a smaller amount of spectrum thereby freeing some bandwidth for ENG. The feasibility of such compaction depends on a number of factors, including the level of present and future demand for transmission capacity, the spectral efficiency of the technology (bits/Hz), and in particular the “efficiency” with which the fixed services are assigned. 3) Geographic sharing- The sharing of the spectrum resources in geographic space is the third possibility. There are several dimensions to geographic sharing. One conceptually simple basis is the metropolitan versus rural/remote model, e.g., ENG in the metropolitan area and fixed links elsewhere. Another is the cellular re-use concept, which can be further dissected into “large cell” (e.g., terrestrial broadcasting), “small cell”. (e.g., mobile telephony1) and even “micro cell”, but those methods are not considered viable for ENG applications.

A less recognised type of spatial sharing is that based on the directionality of the radio emission. It is the exploitation of this aspect that makes possible very efficient use of the terrestrial microwave bands under certain conditions.2 The achievement of high reuse however requires a detailed co-ordination process supported by clearly defined interference criteria and accurate recording of licensed services. Indeed the extent of channel re-use that is possible depends, to a large extent, on the “quality” of

1 Indeed enormous spectrum efficiency achieved by modern mobile telecommunications systems is achieved by managing the spectrum resource in all three directions. 2 For example, in the Sydney “High Spectrum Demand Area” the most used 7MHz channel in the 22GHz band is concurrently used by almost 200 fixed links – and further re-use is still possible.

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the spectrum management environment that supports the frequency assignment process.

Since the primary basis of spectrum sharing between terrestrial microwave is the predictable fixed directionality of the emission, the potential problems of sharing between “nomadic” ENG and fixed point-to-point links in the same geographic area are obvious. Because the locations (hence orientation) of these services are unknown – or at least changing unpredictably – the directionality factor cannot be exploited.

The sharing problem compounds if provision needs to be made for ENG operation from a mobile platform, i.e. not merely a “temporary fixed” situation3, particularly if the ENG operation involves the use of omni directional antenna systems.

3710–4200 MHz

The ABC, like many other FTA and Pay-TV broadcasters and like many other members of the public uses C-band for the reception of TV news and program feed from satellite transmission provided by other broadcasters and content providers of other countries. purposes. If the ACMA were to change the usage pattern in Australia for this band, the broadcasters will either lose the signal or will have to run very expensive multi-channel feed of several tens of channels from somewhere in the outback to metro studio centres. This is almost impossible due to prohibitive costs running into millions of dollars a year.

A better way for the ACMA would be to await the international decision in this regard. If the band was to move out of the hands of satellite operators and into the hands of wireless access services worldwide, clearly the current satellite operations will move to other satellite bands (e.g., Ku- band or Ka-band) and then the ABC will have no objection to the use of C- band for wireless access services at that time.

820–960 MHz (Sound OB)

The ABC has several Sound Outside Broadcasts (SOB) channels around 845-850MHz range. These are crucial for the Radio content production and news coverage on location. The use is not continuous but frequent and Australia-wide. Single and multi-hop usage in conjunction with or without helicopter and outside broadcast vans are common place. The usage is increasing with digital and multi-channel. If the ABC were to lose access to this spectrum, alternative spectrum will need to be found and the SOBs relocated. This will be time consuming, expensive and labour intensive during the change. The exact cost is not known but could be estimated if the impact is known in terms of the changes needed.

3 If ENG were constrained to “temporary fixed” operations, i.e. typically “Outside Broadcast” operations it might indeed be possible to use automated real time co-ordination processes to enable these services to share spectrum with traditionally coordinated fixed links.

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Normally such moves are best synchronised with technology changes or ageing equipment replacement or capital planning cycles. To avoid future premature moves, a more permanent home for the SOBs need to be worked out in the event of changes.

520–820 MHz (Free-to-air television broadcasting)

The discussion paper identifies the bands currently used for ultrahigh-frequency (UHF) television broadcasting as very-long-term candidates for vacation and reallocation to wireless access services once the transition from analog to digital television broadcasting has been completed. The ABC acknowledges that the ACMA plans only to monitor and review the band as developments occur.

The Corporation notes that there are limitations to the range of non-broadcast uses for this spectrum, as the power levels of broadcast transmissions limit the utility of the band for more typical radiocommunications services. These power levels result in a high noise floor and widespread interference. Unlike other uses of the radio frequencies, interference in the broadcasting services bands is managed in the way broadcast services are planned. Therefore, the most logical alternative use of such spectrum is for other broadcast-type services that have similar emission characteristics.

As the ABC has previously argued, there are a number of broadcasting uses for this spectrum which should be considered before non-broadcasting uses, such as the provision of wireless access services, are considered. As a first priority, the need for spectrum to meet the objective of equivalent coverage for existing digital television services, as set out in the Broadcasting Services Act 1992, must be addressed.4 The quantity of additional spectrum required for this purpose remains to be seen. Additional priorities are for the allocation of spectrum for use by other broadcasting services (e.g., community broadcast and self-help operation). Finally, consideration should also be given to making some provision for future additional television services, including potential expansion of the spectrum allocated to existing services if Australian viewers adopt HDTV.

The ABC is concerned that the reallocation of broadcasting services bands spectrum for non- broadcasting purposes may result in broadcasting channels being interspersed with other types of radiocommunications service, including wireless access services, and that mingling services in such a fashion has the potential to create unacceptable interference from broadcasting services into wireless access services.

4 Paragraph 19(3)(f) of Schedule 4 of the Broadcasting Services Act 1992 requires that national broadcasters’ standard definition digital television broadcasts “should achieve the same level of coverage and potential reception quality as is achieved by the transmission of that service in analog mode in that area”.

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1427–1535 MHz

Commonly known as L-Band, parts of this band are identified by WARC-92 (World Administrative Radio Conference 1992) for digital sound broadcasting (DSB) and for extension of DSB services. It is this band which will be used by Radio Broadcasters for in-fill translators and gap filler transmitters for DSB. While DSB services can co-ordinate their use with DRCS (Digital Radio Concentrator System), the coexistence of DSB with wireless access services is almost impossible over all coverage areas. The ABC therefore believes that this band is certainly not suitable for wireless access services, particularly the parts of the band to be used for digital radio.

2025–2110 MHz and 2200–2300 MHz

This band is currently used by Point-to-Point links. A number of wireless access services could be accommodated in this band, provided broadcasters’ ENG operations are to continue without restriction in the 2.5GHz band. If however according to the ACMA if the ENG was to move out of the 2.5GHz band, the band 2110-2170 and 2200-2300MHz are likely considerations for migration of ENG services. The ABC does not believe that ENG services could be accommodated without displacing many fixed links and does not believe that segmented spectrum will fit-in with the shared use by broadcasters without restricting operational flexibility. These questions are currently under active joint study between the ACMA and the FTA broadcasters with ENG channels. The ABC believes that the ACMA should await the outcome of those joint studies.

Conclusion

In conclusion:

1) the ABC further notes that the paper represents an initial step by the Australian Communications and Media Authority (ACMA) towards developing spectrum strategies appropriate for wireless access services and that the proposals raised represent possible approaches, rather than firm policy positions; 2) the ABC also notes that this paper does not discuss market allocation mechanisms for spectrum in detail and if support is demonstrated for the allocation of additional wireless access services spectrum, the consideration of allocation mechanisms would be the subject of future consultation; 3) The ABC believes that there is currently uncertainty about the quantum of demand for wireless access services; 4) the ABC believes that the overall demand for wireless access services will need to be assessed with respect to the demand for UWB (802.15) services and “Beyond IMT- 2000” or “Advanced IMT” services which may or may not include 802.11 and 802.16 technologies and that this last issue is still awaiting international consideration by the ITU-R Working Party (WP) 8F;

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5) the ABC believes that if it was determined that spectrum is needed for wireless access services then suitable unused spectrum should be first put to such use as the top priority and public (ISM) spectrum be used as the next priority before considering other spectrum bands; 6) the ABC also believes that if an additional allocation was made for wireless access services, the incumbents in the band need to be protected and if the incumbents were to be re-located, adequate time, resources and suitable alternative spectrum should be provided by the ACMA that will not restrict operational flexibility of and shared use by the FTA broadcasters; 7) the ABC also believes that to minimise the impact on the incumbents and to better match the wireless access services allocation with the wireless access services demand in reality, an incremental approach to spectrum allocation should be pursued; 8) the ABC also believes that spectrum allocated for wireless access services should be subject to an effective licensing approach that ensures that the spectrum so allocated will actually be used for wireless access services in a timely and efficient manner; 9) the ABC also wants that the ABC’s services as described in various bands above will be able to be continued without disruption; 10) the ABC also believes there is no spectrum currently identified other than the existing 2.5 GHz ENG spectrum that provides sufficient spectrum with suitable characteristics for use around Australia on a 24/7 basis to cover the ABC’s ENG, EFP and TVOB requirements, particularly noting that it is impossible to pre-determine where and when the next disaster will strike or a need will arise to cover news operations in real time.

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Annex 1

IEEE 802 Standards are Complementary

802.11 802.16 802.20 Spectrum Unlicensed Licensed Licensed

Unlicensed Frequency Bands 2.4GHz, 5GHz 10-66GHz Below 3.5GHz

2-11GHz Access Type Local Area Metropolitan Area Access Metropolitan Area Access

Mobility Support Portability Fixed, Mobility Vehicular Speed Mobility

Station Power Battery Mains, Battery Battery

LOS/NLOS NLOS LOS (10-66GHz) NLOS

NLOS (2-11GHz) Group Charter PHY and MAC for LAN PHY and MAC for MAN. PHY and MAC for Vehicular Wireless Access Access Mobility

Source: aperto networks

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Annex 2

Australian Broadcasting Corporation 2.5GHz band Spectrum Usage

ABC uses the 2.5GHz band Australia-wide for news, outside broadcasts and electronic field production in all States and Territories. The implementation of digital COFDM systems has opened up immense areas of coverage never before accessible due to analogue transmission limitations, providing higher quality and more comprehensive coverage of News events as it is happening.

Essential news gathering operations in the ABC consist of a single News DENG van with fully equipped links in each of Brisbane, Adelaide, Perth, Hobart, Sydney and Melbourne, deployed for fixed and nomadic operations and single crew operations in the CBD and greater metropolitan areas. Canberra operates two News DENG vans, one from Parliament House primarily for Political issues, the second an all terrain vehicle, for CBD and regional area coverage. Darwin has been provided with a fully equipped DENG system and has become very active in providing live News material for the 7.00pm Darwin and National News bulletins, such as the Falconio murder trail bulletins, and Emergency bulletins from the Darwin Weather Bureau into the Darwin and NT regional areas in times of approaching cyclones.

The ABC has commenced deployment of wireless camera systems for linking close action shots to the news van which then operate effectively as a relay station and optionally linking News material directly from the camera to the studio for live reporting situations.

As with all other television broadcasters in Australia, ABC news operations extend from 0700 to midnight seven days a week during all seasons of the year. From each of the state capitals, news crews extend beyond a 150km limit frequently using ABC helicopters to provide regional news reports back either by transported tape or directly to the ENG collection sites in the capital cities. Helicopter systems are used daily for news bulletins and transportation of News crews to locations where News is happening.

ABC experiences congestion in the 2.5GHz band in Sydney and Melbourne on a daily basis due to the deployment of up to 3 facilities, in the case of Sydney, where at one location a news coverage deployment can include a helicopter, an ENG vehicle and other portable transmitters that may need to transmit live vision into the main news bulletin at 7pm and promos scheduled in the evening. This congestion is managed by the ABC Master Control Centre that co-ordinates the remote locations to transmit or standby, prioritizing events based on their instantaneous importance.

ABC undertakes coordinated sharing arrangements between TOBN licensees on a regular basis for Outside Broadcast situations. These scenarios involve the application of portable roaming wireless camera systems also in the 2.5GHz band. In many instances frequencies / channels in the 2.5GHz band are shared between broadcasters to fulfill electronic field production requirements.

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ABC commitments are at a peak in Sydney and Melbourne for both weekend days from daylight to dusk. Live OB events particularly necessitate the use of wireless camera technology due to the increasing prohibition of laying physical cables in areas accessed by the public or competitors due to OH&S safety issues.

The ABC use of the 2.5GHz band for OB coverage of major sporting events, such as:

the Hopman Cup Tennis in Perth and the Sydney to Hobart race where an ABC helicopter operated above the Derwent River in Hobart to provide live coverage via the 2.5 GHz DENG system of the arrival of yachts competing in the race and during the AFL season, the wireless camera systems are operational to provide roaming coverage of AFL matches in cooperation with News requirements, are typical operational activities that require the use of the 2.5 GHz spectrum for live to air programs and live and pre-recorded News gathering activities.

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