806-960 MHz Band
Replanning Options
A Discussion Paper
First published in May 2009 by the
Radio Spectrum Policy and Planning Group
Energy and Communications Branch
Ministry of Economic Development
PO Box 1473, Wellington, New Zealand
http://www.rsm.govt.nz
ISBN 978-0-478-33631-3 (PDF)
ISBN 978-0-478-33632-0 (HTML)
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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 discussion 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 discussion document or for any error, inadequacy, deficiency, flaw in or omission
from the discussion document.
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Table of Contents
DISCLAIMER ......................................................................................................................... 2
1.
PURPOSE ...................................................................................................................... 4
1.1
Making a Submission ....................................................................................... 4
1.2
Publication and Public Release of Submissions .............................................. 4
2.
INTRODUCTION............................................................................................................... 5
2.1
Background ...................................................................................................... 5
2.2
Replanning Objectives ..................................................................................... 5
2.3
Inputs................................................................................................................ 6
2.3.1 Recent Projects .................................................................................. 6
2.3.2 International Considerations ............................................................... 6
2.3.3 Spectrum Management Considerations ............................................. 7
3.
CURRENT ALLOCATIONS ................................................................................................ 9
3.1
Band Plan......................................................................................................... 9
3.2
Utilisation of Allocations ................................................................................. 14
3.2.1 Cellular Applications ......................................................................... 14
3.2.2 Fixed Links, including Studio-to-Transmitter Links ........................... 15
3.2.3 Land Mobile Radio............................................................................ 17
3.2.4 Short-range Devices ......................................................................... 18
3.3
Summary ........................................................................................................ 21
4.
PROPOSAL FOR REPLANNING ....................................................................................... 22
4.1
Base Proposal................................................................................................ 22
4.1.1 New fixed link band at 841-849 MHz and long-term SRD
harmonisation at 915-929 MHz ...................................................................... 22
4.1.2 Licensing Arrangements for 915-921 MHz Band.............................. 23
4.1.3 Management of 841-849 MHz Band................................................. 25
4.1.4 Impacts ............................................................................................. 30
4.2
Variations ....................................................................................................... 31
4.2.1 Variation 1 – Simplex Land Mobile Radio Relocation....................... 31
4.2.2 Variation 2 – Alternative Use of 819-824 MHz SRD Band ............... 33
4.2.3 Variation 3 – Reuse of “Orphan” Cellular Spectrum ......................... 33
4.3
Illustrations of Replanning Proposal and Variation 1 ..................................... 34
5.
SUMMARY OF QUESTIONS............................................................................................. 36
6.
GLOSSARY .................................................................................................................. 40
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1. Purpose
This discussion document reviews the efficiency of spectrum allocations in the
806-960 MHz band, principally for non-cellular applications, and considers options for
replanning these allocations to achieve greater efficiency.
The Ministry seeks the opinions of interested parties, particularly broadcasters, land
mobile radio users and vendors, short-range device users and vendors, and mobile
network operators, on the analysis and options presented.
The Ministry may initiate further consultation on specific proposals after reviewing
submissions to this document.
1.1 Making a Submission
Comments should be submitted in writing, no later than 30 June 2009, as follows:
Email (preferred option)
radiospectrum@med.govt.nz
(Subject line: “806-960 MHz Band Replanning”)
Post
806-960 MHz Band Replanning
Radio Spectrum Policy and Planning
Ministry of Economic Development
PO Box 1473
WELLINGTON
Any party wishing to discuss the proposals with Ministry officials should contact, in the
first instance, Tracey Black of the Radio Spectrum Policy and Planning Group on
(04) 472 0030.
1.2 Publication and Public Release of Submissions
The Ministry intends to publish all submissions on its website www.rsm.govt.nz. The
Ministry will consider submitters to have consented to publication unless clearly specified
otherwise in the submission.
The content of submissions provided to the Ministry may become subject to public release
under the Official Information Act 1982. Please advise if you have any objection to the
release of any information contained in a submission, and in particular, which part(s) you
consider should be withheld, together with the reason(s) for withholding the information.
Confidential information should be clearly marked. The Ministry will take into account all
such objections when responding to requests for information on submissions to this
document under the Official Information Act 1982.
The Privacy Act 1993 establishes certain principles with respect to the collection, use, and
disclosure of information about individuals by various agencies including the Ministry. It also
governs access by individuals to information about themselves held by agencies. Any
personal information you supply to the Ministry in the course of making a submission will be
used by the Ministry only in conjunction with consideration of matters covered by this
document. Please clearly indicate in your submission if you do not wish your name to be
included in any summary of submissions that the Ministry may publish.
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2. Introduction
2.1 Background
The radio spectrum is an important part of an effective ICT infrastructure in New
Zealand, which contributes to achieving higher productivity and economic growth. The
Ministry undertakes periodic reviews to ensure that New Zealand spectrum allocations
are best fit with existing and planned local, regional and international environments, to
improve the overall efficiency and effectiveness of the radio spectrum, and to maximise
economic benefit to New Zealand through enabling the introduction of new technologies
and applications, and enhancing competition.
The radio frequencies from 806 to 960 MHz are considered to be the “prime real estate”
of the radio spectrum – this band’s excellent propagation and bandwidth characteristics,
and the consequent lower cost of deploying services compared to higher frequency
bands, means it is highly valued by users.
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 1 , which occurred as part of the 2007/08 cellular management rights renewal
process.
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 935-939 MHz
with the 2degrees Mobile-held management right at 841-845 MHz.
The management rights swap was completed in January 2009. The resulting ownership
arrangements now allow greater usage by the new entrant of the standard frequency
range of GSM technologies and appear to be sufficient for current needs and future inband transition to newer technologies. The Crown has also benefited from aggregating
spectrum it manages at 841-849 MHz, providing the potential for a more technically
efficient allocation.
The second stage of the review is the subject of this discussion paper, and is focussed
on the spectrum used for non-cellular services and applications in the 806-960 MHz
band. In this paper the Ministry analyses the current allocations for this spectrum, and
discusses replanning options, including what might be the best use of the new 8 MHz
band available at 841-849 MHz.
2.2 Replanning Objectives
In order to improve the overall efficiency and effectiveness of the 806-960 MHz band, the
replanning objectives, in no particular order, are to:
•
Increase technical efficiency through introduction of more efficient technologies and
reduction of fragmentation of allocations and channelling;
1
2degrees Mobile acquired management rights from Vodafone and Telecom in March and April 2008
respectively.
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•
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.
2.3 Inputs
2.3.1
Recent Projects
A range of projects undertaken by the Ministry in recent years are relevant to the review
of the 806-960 MHz band. The Ministry has drawn on feedback received in relation to
these projects to identify the issues of most apparent concern to industry, but anticipates
that in some cases technology changes may have brought about new issues, which the
Ministry hopes will be identified in this consultation process. Relevant projects include:
•
Review of spectrum allocations for short-range devices 2 (2004)
•
Review of spectrum allocations for studio-to-transmitter links 3 (2004-2007)
•
Review of digital trunked land mobile radio in the 800 MHz band 4 (2007-2008), and
•
Renewal of management rights for cellular services 5 (2006-2008).
As part of its investigation of replanning options, the Ministry commissioned an analysis
of potential interference between different services in the band to enable an assessment
to be made of the feasibility of various scenarios. The analysis, undertaken by Kordia, is
available in two separate documents. 6
2.3.2
International Considerations
New Zealand is a signatory to the International Telecommunication Union (ITU) Radio
Regulations. This treaty is an important guide to how we can achieve economies of
2
Available at http://www.rsm.govt.nz/cms/policy-and-planning/current-projects/radiocommunications/review-ofspectrum-allocations-for-short-range-devices.
3
Available at http://www.rsm.govt.nz/cms/policy-and-planning/current-projects/broadcasting/review-of-spectrumallocations-for-studio-to-transmitter-linksreview-of-spectrum-allocations-for-studio-to-transmitter-links.
4
Available at http://www.rsm.govt.nz/cms/policy-and-planning/current-projects/radiocommunications/digitaltrunked-land-mobile-radio-in-the-800-mhz-ts-band.
5
Available at http://www.rsm.govt.nz/cms/policy-and-planning/current-projects/radiocommunications/rights-atexpiry/cellular-rights.
6
The main interference analysis report is available at http://www.rsm.govt.nz/cms/policy-and-planning/currentprojects/radiocommunications/806-960-mhz-band-replanning/interference-analysis/ and a supplementary
interference analysis is available at http://www.rsm.govt.nz/cms/policy-and-planning/currentprojects/radiocommunications/806-960-mhz-band-replanning/supplementary-interference-analysis.
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scale, as the Radio Regulations together with the associated ITU recommendations
govern international telecommunications technology development.
Market alignment and regulatory harmonisation with major ICT trading partners (notably
Australia 7 , the US, the UK and Europe) of band and channel plans, and of equipment
standards, enables New Zealand to capture economies of scale as we are a small
market and predominantly an importer of overseas technology.
Internationally, a wide range of new technologies for use in the 806-960 MHz spectrum
are emerging. In addition, some services are transitioning through technology changes,
for example, moving from analogue to digital, and adopting the use of different
modulation techniques. These technical drivers for change are reflected in the next
section which examines the current band utilisation.
2.3.3
Spectrum Management Considerations
The review has also considered the licensing regime under which the different sub-bands
are managed and whether it provides for the optimum allocation of spectrum to the most
valued use. In particular, the Ministry has considered which of the two spectrum
management regimes – administrative licensing and management rights – is most
appropriate, and in the case of the latter whether management rights should be sold or
retained by the Crown and, if retained, how licences should be allocated.
The administrative radio licensing regime, where any one user may apply for a licence,
grants licences on a first-come, first-served basis for an initial fee and annual renewal
charge. A radio licence has no value as an asset and no tradability. This system
provides an effective means of allocating spectrum when the spectrum available for use
exceeds the quantity demanded for the duration of the planning period.
The management rights regime is a tradable property rights regime, which encompasses
two tiers of spectrum rights:
•
A management right, which gives right-holders (the managers) exclusive rights to a
nationwide band of spectrum for a period of up to 20 years; and
•
A tradable spectrum licence, which is assigned by the owner of the applicable
management right (right-holders are entitled to license radio spectrum for use by
their own organisation or by external organisations), and permits the licensee to
transmit radio waves within the range of frequencies specified on the licence,
and/or to receive no interference.
Management rights give right-holders a high degree of choice concerning levels and
timing of investment, and in the type and configuration of the service provided.
Management rights are typically allocated on a competitive basis initially (normally by
auction), as a market-based mechanism of competitive allocation and subsequent
trading is recognised as ensuring the most efficient allocative outcome for spectrum in
high demand over time.
7
Under the Closer Economic Relations (CER) agreement and the Trans-Tasman Mutual Recognition Agreement
(TTMRA) this is a bilateral treaty requirement.
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In addition, there is a class of licence called a general user licence (GUL), which may be
created under either the radio licensing or the management rights regime. A general
user licence allows any number of operators access to a specified band without a
requirement for individual radio licences or fee payments. The licence carries the basic
technical specifications of the equipment and the conditions of use. The technologies
employed, their conditions of operation, and their minimal operating radius normally limit
the likelihood of interference with other services. However, applications operating under
a general user licence must not create interference to other licensed services and have
no protection from interference caused by other users of the spectrum.
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3. Current Allocations
3.1 Band Plan
The current spectrum allocations in New Zealand between 806 and 960 MHz are
illustrated in Figure 1, and summarised in Table 1 on the following pages.
The portions of the band which are operated under spectrum management rights are
indicated by the letters “C” (rights held by the Crown), “N” (rights held by 2degrees
Mobile), “T” (rights held by Telecom) and “V” (rights held by Vodafone). The remaining
frequencies are allocated under individual radio licences or the General User Radio
Licence for short-range devices (SRDs).
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Figure 1: Current Band Plan 806-960 MHz
806 MHz
960 MHz
N
T
C
T
C = Crown management right
N = 2degrees Mobile management right
T = Telecom management right
V = Vodafone management right
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N
N
N
V
N
N
V
Table 1: Band Allocations 806-960 MHz
Band
Predominant use
Technology
standard
currently in use
Manager
Expiry of
Rights
Notes
806-812 MHz
Fixed links (KK Band)
Digital
Crown (radio licensing regime)
N/A
812-819 MHz
Land mobile radio
trunked dispatch
Analogue, APCO,
TETRA
Crown (radio licensing regime)
N/A
819-824 MHz
Short-range devices
(SRDs)
Crown (General User Radio
Licence (GURL))
N/A
Appears to be predominantly used for radio
microphones
824-825 MHz
Guard band
Crown (radio licensing regime)
N/A
Guard band implemented to prevent potential
interference from ubiquitous SRD devices
interfering with cellular base station receivers.
825-840 MHz
Cellular
Telecom (Management Rights 21
and 225)
2012, renewal
contract to
2031
840-841 MHz
Not used
2degrees Mobile (Management
Right 229)
29 Oct 2012,
renewal offer
to be made
Uplink for
CDMA2000
This was split from the management right
previously at 840-845 MHz as part of the
January 2009 4 MHz management right swap
with the Crown.
Subject to private agreements that:
- transmitters in this band must have the
same site sense to emissions in the lower
management right, and
- spectrum licences providing the right to
transmit must be technically compatible with
spectrum licences in the adjacent right, and
must not materially degrade services licensed
in the adjacent right.
841-845 MHz
Not used
Crown (Management Right 230)
29 Oct 2012
Was previously held by 2degrees Mobile;
gained by the Crown on 13 January 2009
through a management right swap.
845-849 MHz
Not used
Crown (radio licensing regime)
N/A
Previously used as a guard band between
former cellular allocation up to 845 MHz and
lower boundary of STL allocation at 849 MHz.
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Band
Predominant use
Technology
standard
currently in use
Manager
Expiry of
Rights
849-851 MHz
Studio-to-transmitter links
(STLs)
Analogue
Crown (radio licensing regime)
N/A
851-857 MHz
Fixed links (KK# band)
Digital
Crown (radio licensing regime)
N/A
857-864 MHz
Land mobile radio
trunked dispatch
Analogue, APCO,
TETRA
Crown (radio licensing regime)
N/A
864-868 MHz
SRDs
Various
Crown (GURL)
N/A
868-869 MHz
Land mobile radio
simplex
Analogue
Crown (radio licensing regime)
N/A
869.2-869.25
MHz
SRDs (medical telemetry)
Crown (GURL)
N/A
870-885 MHz
Cellular
Telecom (Management Rights 22
and 227)
2012, renewal
contract to
2031
885-890 MHz
Not used
2degrees Mobile
(Management Right 228)
29 Oct 2012,
renewal offer
to be made
890-900 MHz
Cellular
GSM
2degrees Mobile
(Management Right 224)
2022
900-915 MHz
Cellular
GSM, W-CDMA
uplink
Vodafone
(Management Right 253)
2016, renewal
contract to
2031
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Downlink for
CDMA2000
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Notes
Power (e.i.r.p.) -20 dBW
Subject to private agreements that:
- transmitters in this band must have the
same site sense to emissions in the lower
management right, and
- spectrum licences providing the right to
transmit must be technically compatible with
spectrum licences in the adjacent right, and
must not materially degrade services licensed
in the adjacent right.
Management Rights 251 and 252 aggregated
into Management Right 253 in 2009.
Band
915-921 MHz
Predominant use
STLs
Technology
standard
currently in use
Analogue
Manager
Crown (radio licensing regime)
Expiry of
Rights
N/A
Notes
Subject to moratorium on new licences,
except for fixed-term 12-month licences
arising from the May 2008 radio licence
auction.
Also used by low power SRDs (3 mW).
921-929 MHz
SRDs
Various
Crown (GURL)
N/A
929-935 MHz
STLs
Analogue
Crown (radio licensing regime)
N/A
935-939 MHz
Cellular
GSM
2degrees Mobile
(Management Right 243)
29 Jun 2012,
renewal offer
to be made;
(Management Right 223)
2022
Vodafone
(Management Right 257)
2016, renewal
contract to
2031
939-945 MHz
945-960 MHz
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Cellular
GSM, W-CDMA
downlink
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Uses include Radio Frequency Identification
systems and mesh networks.
935-939 MHz was previously held by the
Crown; gained by 2degrees Mobile on 13
January 2009 through a management right
swap.
Management Rights 255 and 256 aggregated
into Management Right 257 in 2009.
3.2 Utilisation of Allocations
As illustrated, the 806-960 MHz band is in high demand, particularly for cellular
applications, and also for a range of other applications, which can be broadly grouped
as:
•
fixed links, including studio-to-transmitter links
•
land mobile radio, and
•
short-range devices.
The utilisation of 806-960 MHz spectrum by each of the above groups of applications is
considered below.
3.2.1
Cellular Applications
As noted in the introduction, allocations in this band for cellular applications were
reviewed following the acceptance of renewal offers for management rights by Telecom
and Vodafone and their sale of management rights to the new mobile network entrant,
2degrees Mobile. The cellular allocations were rationalised further in January 2009 by
swapping a Crown management right (at 935-939 MHz) with a 2degrees Mobile
management right of equal size and value (at 841-845 MHz), which resulted in a reduced
number of interfaces and created opportunities for increasing spectrum efficiency
through aggregating spectrum within the 841-849 MHz and 935-945 MHz bands.
The current allocations in the 806-960 MHz band appear to be sufficient for current
technology and future requirements as part of long-term evolution of cellular applications.
However, a 1-MHz management right held by 2degrees Mobile, at 840-841 MHz (which
might be paired with 885-886 MHz), is narrower than necessary for a typical cellular
licence or network, and is therefore impractical for cellular applications. The 2degrees
Mobile-held management right at 885-890 MHz is also not paired for cellular use,
although it effectively serves as a guard band between CDMA (downlink) and the GSM
(uplink) technologies used by Telecom and 2degrees Mobile respectively.
It is the Government’s policy to ensure effective spectrum use in making offers of
renewal for commercial spectrum rights, and this is generally achieved through placing
an implementation requirement upon the right-holder as a renewal condition. The
management rights for the two unused portions of cellular spectrum, as well as the
management right at 935-939 MHz, expire in 2012, and the Ministry’s intention is to
develop appropriate renewal offers for these management rights later in 2009 8 . The
Ministry anticipates that industry feedback on this discussion paper will assist with
developing appropriate conditions for the renewal offers.
8
The Government’s policy on the allocation of commercial spectrum rights on expiry is that, subject to a case-bycase review, the rights be offered for renewal to existing right-holders five years before expiry. In the case of
these three management rights held by 2degrees Mobile expiring in 2012, the rights were only acquired within the
last 12 months.
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Question 1
Do you consider that the Ministry should investigate any other options for further
rationalisation of spectrum for cellular applications in the 806-960 MHz band? If so,
please explain.
3.2.2
Fixed Links, including Studio-to-Transmitter Links
Two types of fixed link services use the 806-960 MHz band, both of which are licensed
under the administrative radio licensing regime.
A 6-MHz pair, at 806-812 MHz and 851-857 MHz (the “KK band”), is allocated for
bidirectional low capacity data links. This allocation is principally used by utility
companies to monitor and control their networks using highly spectrally efficient digital
equipment. The allocation appears to be well subscribed and in some areas it is
congested. An increase in demand for licences has been observed as a result of new
equipment becoming available in New Zealand for this band. Nationally, however, there
does not currently appear to be a shortage of spectrum for licences in the KK band, nor
any underused portions which could be reallocated to other applications.
Other jurisdictions use these bands for the same purpose (Australia), or land mobile
radio (the US) and broadcasting (Europe). As land mobile radio and broadcasting
requirements are addressed by allocations elsewhere, there would not seem to be any
driver for considering allocation of the KK band for a different purpose.
Secondly, a total of 14 MHz of unpaired spectrum is allocated for unidirectional links,
generally studio-to-transmitter links (STLs), used for the transportation of programme
material from the studio to the transmitter site, in three sub-bands:
•
849-851 MHz
•
915-921 MHz
•
929-935 MHz
These allocations have become congested, particularly in the high-use areas of
Auckland, Wellington and Christchurch, as a result of the increased number of FM
broadcast services. In addition, the spectrum at 915-921 MHz is facing increasing risk of
interference from the growing availability of short-range devices from the US and
Australia which are designed to operate in that frequency range.
A consultation process over the period late 2004 to mid 2007 identified means of more
efficiently utilising spectrum for STLs while also considering competing demands for the
same spectrum. This work concluded that STLs should be moved from the 915-921
MHz band under a phased transition to enable the spectrum to be reallocated to shortrange devices. The Ministry undertook to identify new spectrum to make available for
STLs in the 806-960 MHz band once the cellular rights renewal process was completed.
In addition, there was agreement that narrow-band mono STLs in the 900 MHz band
should migrate to the 400 MHz band to help relieve congestion in the 900 MHz band.
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Alternative technologies are available for transporting programmes to the transmitter site,
including leased lines, infra-red links, microwave radio and satellite linking, but fixed links
are commonly used, principally for cost reasons, as well as quality assurance. 9
Various technical modifications to improve technical efficiency have been implemented
over recent years, including optimising the channel assignments at major transmitter
sites, reducing the maximum radiated power on short paths and implementing alternative
antenna types. Other engineering refinements, which have been identified but not yet
implemented, would also assist in improving the technical efficiency of band use,
including removing the minimum path length in favour of common receive signal level for
all new or modified links, and establishing engineering methods for determining the
receive signal level.
Efficiency would also be improved by the introduction of digital equipment for STLs,
which are almost exclusively engineered using analogue equipment at present. In most
instances, digital equipment would provide greater spectrum efficiency and better
tolerance to interference than analogue equipment, which requires a higher protection
ratio.
In some cases, digital radio technologies can require different planning margins to avoid
causing interference into analogue links on the same or adjacent channels. Previous
consultations with industry found that it was desirable to segment the allocations to
enable use of both analogue and digital technologies, but some digital licences are
currently interleaved with analogue licences.
The Ministry considers that the licensee has the best information in order to manage the
choice of technology to meet their requirements, and therefore it does not mandate the
use of specific technologies in order to ease spectrum congestion in high-use areas.
However, if demand for spectrum in a particular frequency range exceeds that which is
available, then the radio licensing regime is not an efficient allocation mechanism, as it is
a first-come, first-served system. While it enables the regulator to control licensing and
to make efficient decisions regarding spectrum use based on technical parameters, it has
no means of determining which of two or more competing requirements to use the
spectrum has the highest economic value.
International harmonisation is not a dominant feature within this market sector, and
hence there is little benefit to be gained from harmonising New Zealand’s fixed link
allocations with those of trading partners.
Question 2
If your organisation uses the KK band (806-812 MHz and 851-857 MHz), do you
consider that the Ministry’s assessment of utilisation of the band is accurate? If not,
please explain.
9
Industry feedback during the consultation process indicated concerns with alternative technologies, in particular
capacity, quality, latency and redundancy limitations of wireline or satellite network infrastructure (Spectrum
Allocations for Studio-to-Transmitter Links, Stage 2 Consultation: Summary of Submissions and Conclusions,
September 2007, pp 24-25).
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Question 3
If your organisation has STL licences, do you consider that the Ministry’s assessment
of the utilisation of the sub-bands (849-851 MHz, 915-921 MHz and 929-935 MHz) is
accurate? If not, please explain.
3.2.3
Land Mobile Radio
There are two allocations for land mobile radio (LMR) in the 806-960 MHz band
currently:
•
A 7-MHz pair, at 812-819 MHz and 857-864 MHz (the “TS band”), which is used for
trunked dispatch services, and
•
1 MHz at 868-869 MHz (the “TX band”), which is used for simplex applications.
During 2007/08, the Ministry worked with industry on the introduction of digital
technologies into the TS band, to enable a more spectrally efficient use of the land
mobile service and the provision of enhanced features (e.g. quality voice, a type of short
messaging service, data services, GPS tracking services and encryption), for which there
had been growing demand. New digital services now share the TS band with existing
analogue services. In this band, the two technologies have been mixed, rather than
segmented into different sub-bands, as this has proven to be successful internationally.
Similarly, there have been no reports of interference between these services in New
Zealand since this framework came into force.
The TX band uses only analogue equipment. The TX band is located in a portion of
spectrum which is used in Europe for short-range devices (SRDs), and therefore
precludes the full use of the European SRD band in New Zealand.
There appear to be sufficient allocations in the 800 MHz band for LMR applications; the
allocations are not fully utilised at present. These bands are managed under the
administrative radio licensing regime.
92
1
87
6
91
5
86
5
86
9
86
4
87
0
82
5
85
1
7
85
2
81
81
9
82
0
82
4
Figure 2: Trunked Dispatch Land Mobile Radio Spectrum Harmonisation
Figure 2 shows the extent to which trunked dispatch LMR spectrum allocations are
harmonised between the US, Australia, Europe and New Zealand, with the red ovals
showing areas where spectrum could be more closely harmonised. New Zealand’s
allocation has been harmonised with the US allocations insofar as the US duplex spacing
of 45 MHz and channel edges have been aligned. Australia has partially harmonised its
allocations with the US, although it has used a different duplex spacing. There is no
alignment with European LMR allocations.
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There is unlikely to be any economy of scale that can be gained by aligning New Zealand
land mobile radio allocations with Australia that is not already being achieved or
exceeded by the current alignment with the US, because the US is the dominant market
for supply of this equipment. In respect of European LMR allocations, the equipment
manufactured for use in these allocations follows the TETRA standard, which is capable
of being used in both the European and US allocations. Therefore, although
harmonisation has not been achieved at the allocation layer, it has been achieved at the
technical standards layer, and there seems to be no additional benefit in seeking New
Zealand spectrum alignment with European LMR allocations.
Question 4
If your organisation uses any of the land mobile radio sub-bands (812-819 MHz and
857-864 MHz, and 868-869 MHz), do you consider the Ministry’s assessment of
current usage to be accurate? If not, please explain.
3.2.4
Short-range Devices
Short-range devices (SRDs) provide low-cost communications services in a wide range
of applications, and usage has grown rapidly in recent years globally. The ITU Radio
Recommendations 10 list the following types of applications for SRDs (not limited to 806960 MHz band):
Telecommand; Telemetry; Voice and video; Equipment for detecting avalanche
victims; Broadband radio local area networks (RLANs); Railway applications,
including: Automatic vehicle identification (AVI), Balise system, Loop system; Road
transport and traffic telematics (RTTTs) also known as transport information and
control systems (TICSs); Equipment for detecting movement and equipment for
alert; Alarms including: Alarm in general, Social alarms, Model control; Inductive
applications; Radio microphones; RF identification (RFID) systems; Ultra low power
active medical implant (ULP-AMI); Wireless audio applications; RF (radar) level
gauges.
Three bands in the 806-960 MHz spectrum range are currently allocated for SRDs in
New Zealand:
•
819-824 MHz
•
864-868 MHz
•
921-929 MHz
In addition, low power (3 mW) SRDs share the band 918-921 MHz that is currently
allocated to STLs. A General User Radio Licence (GURL) for SRDs, issued in 2004,
includes those operating in the 806-960 MHz band.
International standardisation, the use of new technologies, and rapid, low-cost
deployment are opening up innovative new uses for the SRD radio spectrum, which
could be expected to provide economic benefits for New Zealand. The 2004 study of
10
Rec ITU-R SM.1538-2
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SRD allocations undertaken by the Ministry found that there was growing demand in
New Zealand in the 806-960 MHz band for the following applications in particular:
•
Radio frequency identification (RFID) devices, used for supply chain management,
e.g. tracking livestock or freight
•
Medical telemetry
•
Broadband wireless access equipment.
In addition, since 2004, advances have been made in the development of smart
electricity meters using wireless mesh network technology, which can be used to
remotely monitor usage of electricity. Smart meters are already being used in
New Zealand by several energy companies.
The determining factor for utility of SRD allocations is the degree of harmonisation with
the US and Europe, due to the ability of these markets to drive the development of new
technology, and also with Australia due to common equipment distribution channels for
the New Zealand market. Harmonisation is also a means of limiting the instance of
interference – the ubiquitous nature of SRD devices in all manner of technologies means
that can be difficult to control their use, even if operated on frequencies that are not
permitted by current SRD licence.
As illustrated in Figure 3, SRD spectrum in the 806-960 MHz band in New Zealand is
only partially aligned with these markets.
92
8.0
91
5.0
806 MHz
90
2 .5
86
1 .0
86
5.0
Figure 3: SRD Spectrum Harmonisation
960 MHz
US
Australia
Europe
92
9.0
92
1.0
870.0
86
4.0
86
8 .0
86
2 .0
81
9.0
82
4.0
New Zealand
This situation arises because the ITU Radio Regulations provide a specific SRD
allocation of 902-928 MHz in Region 2 (Americas), but make no such provision in Region
1 (Europe) or Region 3 (Asia including New Zealand), meaning that countries in those
regions determine their own allocations. It is not possible to fully align with the US
allocation, as the lower portion of this band (902-915 MHz) is held as a management
right for cellular services. However, in the medium term, greater alignment with US and
Australian SRD bands, using frequencies in the range 915-928 MHz, would be feasible,
as was forecast in the Ministry’s 2004 and 2005 papers on allocations for SRDs and
STLs. This is currently prevented by the allocation of the 915-921 MHz band to STLs.
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In the US, this band is used for high volume products such as long range cordless
phones, WLANs and RFID devices with a radiated power of up to 4 watts (RFID readers
with a power output of 1 watt are suitable for shorter range applications, such as hand
held devices used for warehouse stock control, and readers of up to 4 watts’ power
output are more suited to RFID gateways, such as for shipping container control, or other
applications where accurate reads at a distance are needed). In Australia, the band has
been made available for similar types of SRDs with a radiated power of up to 1 watt, and
in addition, Australia recently authorised a maximum high-power RFID system of 4 watts
e.i.r.p. for the 920-926 MHz band. In New Zealand, the band is confined to 921-929
MHz, which makes it impractical for many of the devices to operate, and the power limit
is 1 watt e.i.r.p..
Greater alignment with the EU SRD allocation (862-870 MHz) may also be possible, but
is partly precluded by the use of part of this spectrum (868-869 MHz) for land mobile
(simplex operation) purposes in New Zealand. SRD-type use is therefore presently
limited to the 864-868 MHz and 869.2-869.25 MHz sub-bands. It is unclear how much
demand exists for this spectrum to be harmonised; submissions received by the Ministry
in response to its 2004 consultation on SRD bands showed a strong bias towards
harmonisation with the US and Australia, rather than with Europe.
Lastly, the Ministry notes that the New Zealand SRD allocation at 819-824 MHz has no
alignment with major trading partners’ allocations, suggesting limited utility.
In the US this band is part of the allocation for land mobile radio, and similarly in
Australia most of this band is used for land mobile radio (820-825 MHz, paired with 865870 MHz). In Europe this spectrum is designated as part of the broadcasting band (470872 MHz), but SRDs such as radio microphones may also use this spectrum. In New
Zealand, radio microphones are also licensed in the management right below 806 MHz
on the basis of not causing interference to the television usage, and the requirements for
radio microphone usage will be considered as a part of the process to replan usage of
the spectrum as part of full transition of television broadcasting to digital technology
(“Digital Switch-Over”).
Reallocating the 819-824 MHz band for a trunked land mobile radio service would not be
feasible in New Zealand unless a suitable block of frequencies could be found to pair it
with. The spectrum at 819-824 MHz could, however, be considered for TDD or
unidirectional services that may have greater utility than the present use.
Question 5
With respect to the harmonisation of New Zealand’s SRD spectrum in the 806-960
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.
Question 6
Are there significant SRD-type applications that are presently precluded from being
deployed, or are more expensive to deploy, in New Zealand due to the lack of full
harmonisation with one or more trading partners in the 806-960 MHz band? Please
provide an indication of additional SRD product costs being incurred when supplied on
frequencies currently allocated for this purpose in New Zealand.
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Question 7
Does your organisation wish to supply or deploy high-powered SRDs in New Zealand
in the 915-929 MHz band? If so, what are the technical parameters of the equipment
and spectrum usage?
3.3 Summary
Analysis of the current spectrum allocations in the 806-960 MHz band as described in
the previous sections indicates the following principal problems:
•
Congestion in the spectrum available for STLs in high-use areas;
•
Increasing risk of interference to STLs in the 915-921 MHz band from SRDs
designed for use in the US and Australian markets;
•
Insufficient bandwidth in the 900 MHz band for SRDs such as RFID systems and
mesh networks, which are increasingly in demand;
•
Lack of harmonisation with the SRD allocations of the US (902-928 MHz), Australia
(915-928 MHz) and Europe (862-870 MHz), precluding some SRDs from use in
New Zealand;
•
Discrepancies between the power permitted in US and Australian SRD bands and
the New Zealand band.
Over the long term, key impacts will include the supply of spectrum for STLs falling short
of the quantity demanded resulting in the need to use higher cost options; reduced
availability to New Zealand of new technology where there is lack of spectrum
harmonisation and the consequent loss of economic opportunities; and increased risk of
potential interference if licence-exempt equipment designed for other markets, but which
is non-compliant with New Zealand’s GURL, is imported into New Zealand.
The Ministry would welcome feedback on the current 806-960 MHz spectrum allocations
and impacts on your organisation, or future issues that may affect your organisation.
Question 8
Does your organisation suffer from insufficient spectrum in the 806-960 MHz band at
present, or do you see a future need for spectrum in this band that is not currently
allowed for? If so, please provide details.
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4. Proposal for Replanning
The Ministry has developed a base proposal to replan the band, along with some
potential additional variations to the proposal. The proposal, although by no means the
only possible option for replanning the band, appears to best meet the replanning
objectives based on the information the Ministry has at present concerning current and
possible future usage of the band. The Ministry would welcome feedback on the
proposal and/or suggested alternative replanning options.
4.1 Base Proposal
4.1.1
New fixed link band at 841-849 MHz and long-term SRD
harmonisation at 915-929 MHz
The Ministry’s base proposal is to allocate the unused spectrum at 841-849 MHz for fixed
links, particularly STLs, and to harmonise the lower edge of the 921-929 MHz SRD band
with that of Australia (915 MHz) in the longer term, as illustrated in Figure 4 (page 34).
Harmonisation with the Australian band would also include permitting 4 watt RFIDs in
920-926 MHz, with the same out-of-band emission limits 11 .
Table 2: Allocation changes for new fixed link band and SRD harmonisation
Band
Current Allocation
Proposed Allocation
841-849 MHz
Unused
Fixed links (STLs)
915-921 MHz
Fixed links (STLs)
SRDs (long-term)
[whole band: 915-929 MHz]
921-929 MHz
SRDs, 1 watt e.i.r.p.
SRDs, 1 watt e.i.r.p.
Sub-band 920-926 MHz:
RFIDs up to 4 watts e.i.r.p.
Under this proposal, there will be a new interface between SRDs and adjacent
GSM/W-CDMA services at 915 MHz. The Kordia report provides a conservative analysis
of this interface. The analysis shows that there is a requirement for considerable
distance separation (8.2 km) between these services on outdoor line-of-sight paths to
reduce interference risks. Concern is raised in particular about the potential impact of
multiple SRD devices such as future check-out scanners impacting on nearby
GSM/W-CDMA base station receivers. However, the most likely scenario for SRD
deployment is indoor use, which provides a significant increase in obstruction and
multipath losses, with the consequent reduction of potential interference. The Ministry
notes that the Australian Communications and Media Authority (ACMA) has allocated
SRDs adjacent to cellular services at 915 MHz without a guard band. ACMA has not
recorded any interference issues to date.
11
Emissions below 917.75 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..
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Similarly, Kordia’s supplementary analysis of potential interference between 4 watt
RFIDs operating in 920-926 MHz (with out-of-band emission limits as specified in the
Australian class licence) and the cellular interface at 915 MHz suggests that the devices
are likely to have negligible impact on base station receivers at GSM cell sites. In the
case of W-CDMA base station receivers, while the conservative analysis suggests that a
significant distance separation (12 km) would be required, in reality filter performance
similar to that of GSM base station receivers, combined with the 5 MHz frequency
separation and the likely operation of RFIDs indoors, will mean that there should be little
impact on these base station receivers.
The analysis also suggests that 4 watt RFIDs should be able to operate in the
920-926 MHz band without causing unacceptable degradation to STLs operating in the
band above 929 MHz.
Question 9
Is the band 841-849 MHz a viable option for STL use? If not, please explain.
Question 10
Are there services or applications other than STLs for which the spectrum at 841-849
MHz would be better allocated? If so, please provide details.
Question 11
Is the proposed expansion of the SRD allocation to 915-929 MHz, along with an
increase in power from 1 watt to 4 watts for RFIDs operating at 920-926 MHz, viable
and appropriate in New Zealand? If not, please explain.
Question 12
In regards to the interface between GSM/W-CDMA and SRDs at 915 MHz, would you
suggest any mitigation measures for this interface? If so, please provide details.
4.1.2
Licensing Arrangements for 915-921 MHz Band
The outcome of consultations with industry 12 regarding proposals for more efficient
spectrum utilisation of STLs included proposed two-phase licensing arrangements for
STLs to move from the 915-921 MHz band once new spectrum had been identified. The
Ministry proposes to implement these arrangements (summarised in Table 3, page 25).
The licensing arrangements would provide for current usage of the band by STLs taking
precedence in the first phase, but with licensing of SRDs on a geographic, non-
12
The Ministry’s summary of the outcome of consultations with industry was published in September 2007, and is
available at http://www.rsm.govt.nz/cms/policy-and-planning/current-projects/broadcasting/review-of-spectrumallocations-for-studio-to-transmitter-linksreview-of-spectrum-allocations-for-studio-to-transmitter-links/summary-ofsubmissions-and-conclusions-stage-2.
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interference basis; and usage by SRDs being permitted in the second phase, from which
time STLs would have their right to protection from interference removed 13 .
The mechanism for removing interference protection may be, for example, by adding a
condition to existing licences, or by revoking completely an existing licence and providing
a replacement licence that does not provide any interference protection. In any case, the
removal of interference protection is a significant change to licensees’ expectations and
should be treated as a revocation.
The Radiocommunications Regulations 2001 specify the conditions under which the
Ministry may revoke radio licences of unlimited duration (as are all STL licences in this
band except those issued after May 2008 14 ). The minimum period for giving notice of
revocation is five years, or an earlier date provided for in a transition plan to manage
cessation of transmission under that licence, which is to be developed in consultation
with the licensee. Therefore, the Ministry proposes that current licensees be given five
years’ notice of the removal of interference protection.
Potential users of the 915-921 MHz portion of the band for operating SRDs may also
wish to consider whether their interest in seeking access to the spectrum in advance of
the expansion of the SRD band would warrant developing private arrangements with
incumbent licensees to facilitate an earlier transition out of the band by specific STLs.
Table 3: Licensing Arrangements for STLs and SRDs in the 915–921 MHz Band
Timeframe
STL Licensing Arrangements
SRD Licensing Arrangements
Phase 1:
2009 15 –2014
Radio Licences
- Moratorium on new STL licences,
with allowances for minor variations
of existing licences
- Primary over SRDs, fully protected
- Replacement spectrum available in
841-849 MHz
Radio Licences
- Area basis
- Secondary to STLs
- Fixed term to end of Phase 1
Phase 2:
2014–2019
Radio Licences
- Moratorium on new STL licences
continues
- Co-secondary with SRDs
General User Radio Licence
- All New Zealand
- Include 4 watt RFIDs in 920-926
MHz
- Co-secondary with STLs
Phase 1 would be an STL-driven period, with STL radio licences considered of primary
importance in terms of protection from interference, i.e., during Phase 1, any licences for
SRD applications would not have interference protection from existing STL licences, but
13
This proposal is slightly different to that identified in the Ministry’s Summary of Submissions and Conclusions,
September 2007, in that it allows continuing use of STL transmissions albeit without interference protection.
14
A moratorium was placed on licensing new STLs in this band in February 2008, but the moratorium was
modified to meet additional demand for STLs that was created by the commercial FM licence auction held in May
2008, allowing the creation of new licences for a fixed term of 12 months only (with replacement fixed-term
licences available if required).
15
The date would depend on the exact date that notice was given by the Chief Executive, which is an outcome to
be determined through this consultation process.
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existing STL licences would continue to be protected from harmful interference from
SRDs. These licensing arrangements would allow for higher-powered SRDs to be
permitted in the band 920-926 MHz on a licence-coordinated and geographic basis while
STLs remained fully protected in the band.
Phase 2 would be driven by SRDs, and STL radio licences would be considered cosecondary, in terms of interference protection to and from SRDs. In this phase, the
moratorium would be continued with respect to new STL licences and licences for STLs
remaining in the band would stipulate that the service must accept interference from
other licensed services in the same band. This may give an adequate service in some
geographic areas, where it is possible that the density of SRDs may be low and the
interference potential for STLs will be correspondingly low. A decision by a licensee
about whether to continue in the band would therefore require a judgement about the
likely prevalence of SRDs near the STL receive location.
A GURL would be created for SRDs operating in 915-929 MHz, with provision for 4 watt
RFIDs to operate in 920-926 MHz, with out-of-band emission limits as specified in the
Australian class licence. Under the GURL, SRDs would have no right to protection from
interference.
Question 13
Are the proposed two-phase licensing arrangements for STLs and SRDs in the 915–
921 MHz band suitable? If not, please explain.
Question 14
In Phase 2 of the licensing arrangements for STLs and SRDs in the 915-921 MHz
band, would the utility of the band for SRD use be significantly degraded by permitting
STLs to remain?
4.1.3
Management of 841-849 MHz Band
4.1.3.1
High-level Options
The Crown holds a management right for the frequency range 841-845 MHz, which
expires in October 2012, while the range 845-849 MHz is managed under the radio
licensing regime.
The high-level options for management of this overall band are:
•
To allow the management right to expire and revert to the radio licensing regime,
enabling the whole new 841-849 MHz band to be administratively licensed;
•
To create management rights at 845-849 MHz also, enabling the whole 841-849
MHz range to be managed and allocated under the management rights regime for
the long term;
•
To maintain mixed management of the band, with one portion using management
rights and spectrum licences, and the other portion using radio licences.
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Radio Licensing Regime Option
Examining first the suitability of the radio licensing regime for this band, the benefit of this
type of management is that it enables the Ministry to control licensing and to ensure that
the spectrum available is engineered in a technically efficient way, as licences are
applied for over time. This would enable maximum channel reuse. However, the radio
licensing regime is less flexible for enabling new technologies to be introduced by private
parties.
A further benefit to the Crown is that it remains the band manager, and under current
regulations may reallocate the band to a future, more valuable use, by giving five years’
notice to licensees, or less than five years provided a transition plan is implemented.
The downside for licensees is therefore limited certainty of use of the spectrum and
consequent risk for equipment investment.
A drawback of this regime in terms of spectrum management is that it does not
incorporate any kind of charge for use of the resource (the initial licence fee and annual
renewal charge recover administrative costs only). It is therefore low cost and may
incentivise licensees to use the radio spectrum, rather than alternative technologies, for
studio-to-transmitter linking. If the spectrum were in plentiful supply in the 806-960 MHz
band, this would also be an economically efficient use of the spectrum. However, the
congestion in the main centres suggests that there is insufficient supply of frequencies
for STLs in the 806-960 MHz band. New broadcasting services, for example using
licences reserved by the Crown or new digital services, are expected to occur within a
20-year period 16 . Therefore the radio licensing regime, while enabling technically efficient
allocation of the spectrum available, would not promote economically efficient use over
time.
Management Rights Regime Option
In contrast, the competitive allocation process applied under the management rights
regime is beneficial when assigning spectrum which is in high demand – the process
enables the rights to be allocated to the users who value it most and for the allocation to
change over time through trading. The management rights regime is likely to result in
less congestion as licensees factor resource charges into decision-making about the
appropriate technology to use for studio-to-transmitter linking: the right-holder is able to
determine which radio technology, whether analogue or digital, is most efficient to use for
the required service, as well as whether an alternative technology would do so more
cost-effectively.
A further benefit to right-holders is the longer period of tenure: a right-holder may hold
management rights for up to 20 years, although the rights may expire earlier if the Crown
chooses to create rights for a shorter period at the outset. The long tenure is intended to
give the right-holder greater certainty in decision-making about their investments.
On the other hand, a drawback of the management rights regime is that the spectrum
usage is no longer centrally controlled, which introduces a higher risk of disparate
technologies being used and less than optimal channel reuse, resulting in less technical
efficiency. This is an issue that can be negotiated between right-holders. There is,
however, no obligation on a right-holder to accede to requests from other parties for
16
For planning purposes it is appropriate to consider the maximum period that is possible should a management
right be created.
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licences. This may create competition concerns, but there is also an economic incentive
to maximise revenues from the asset.
Mixed Management Regime Option
The effects of adopting a mixed regime would depend on whether the portion of
spectrum under management rights was allocated to the market or not. If not, and the
management rights were retained by the Crown and licences were allocated without
resource charge, then a mixed regime would operate no differently to the radio licensing
regime and therefore deliver no additional benefit. This would also introduce
administrative complexity.
On the other hand, if some portion of the band was allocated to the market as
management rights while the Crown maintained a portion under the radio licensing
regime, this is likely to incentivise users to first seek comparatively lower cost licences in
the administratively licensed portion of the band, before seeking to purchase
management rights, or spectrum licences within management rights. As the radio
licensing regime is a first-come, first-served system, this is likely to result in an
inequitable outcome for licensees in high-use areas (where demand is likely to exceed
supply of available frequencies) who apply later.
In this context, it is worth noting that the frequency bands at 849-851 MHz and 929-935
MHz are both currently administered under the radio licensing regime and predominantly
used for STL purposes. Therefore, if the 841-849 MHz band is allocated as
management rights, STLs will be licensed under two systems in this band. However, the
existing bands are already fully utilised in high-use areas, and therefore new
requirements for any new licences in high-use areas would need to be met from the new
841-849 MHz range and the licensees have a level playing field. Meanwhile, licences for
low-use areas may be able to be granted from the administratively licensed bands, which
still have capacity in those areas. Therefore, at this time, there does not appear to be a
need to change the management of the existing STL bands at 849-851 MHz and 929935 MHz. The differences between the STL bands is an issue which might be examined
in future, when the licensees seek to transition those bands to digital technology.
The pros and cons of these different management options are summarised in Table 4
below.
Table 4: Pros and cons of different management options for 841-849 MHz
Radio licensing regime
Pros
Cons
Enables the regulator to control
licensing of the band, ensuring
technically efficient usage.
Does not incentivise users to seek
most economically efficient
solution for transporting
programmes to transmitter site.
Government may reallocate the
band if a better use is identified
– after five years if revocation
notice is given, or in shorter
period if transition plan is
implemented.
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Less flexible for new
technologies.
Limits licensees’ certainty for
investment decision-making.
Management rights
regime
Pros
Cons
Competitive allocation
encourages efficient use of the
spectrum.
Lack of central coordination
introduces higher risk of disparate
technologies being used and less
than optimal channel reuse,
resulting in less technical
efficiency.
Enables long-term decisionmaking by right-holder about
preferred link technology and
best use of spectrum.
Mixture of radio licensing
and management rights
regime
Licensees incentivised to seek
comparatively cheaper radio
licences; once radio licences are
all allocated, there is inequitable
effect on new licensees who must
seek spectrum licences.
Administratively complex.
On balance, the Ministry considers that the management right approach is likely to
provide greatest benefit as it will deliver the most economically efficient allocation
outcome over time.
Question 15
Do you agree with the creation of management rights in the 841-849 MHz band, and
the subsequent allocation of management rights to private parties? If not, what is your
preferred alternative and why?
If a management right approach is adopted, further issues for consideration include
whether the Crown should retain any rights, and if so, the purpose and appropriate size
of the block; the appropriate lot size of the remaining management rights to be allocated
to the market; and competition issues.
4.1.3.2
Proportions of Crown and Private Management Rights
The Ministry considers that most of the rights should be allocated to the market, but
recognises that there will be parties who would need licences in this spectrum but for
whom it would not be economical to purchase a nationwide block of spectrum. These
licences might be for new uses or to replace services operating in other bands, such as
the 915-921 MHz band, as equipment ages.
Therefore, it is proposed that a portion be retained by the Crown as a management right,
in order to ensure the availability of spectrum licences for parties which do not hold
management rights. The Ministry preference would be to allocate spectrum licences for
digital links only, in order to maximise the efficiency of the Crown’s spectrum. The
remaining spectrum would be subject to competitive allocation as 20-year management
rights to the market.
Crown-managed spectrum licences should be allocated on a commercial cost basis to
avoid distortions and undercutting private providers (with the cost of spectrum licences to
be derived from the market allocation process). The Crown currently reserves spectrum
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that is required to provide broadcasting services to meet objectives that may not be met
through commercial broadcasting, and does not charge a resource rental for this
spectrum, but only recovers administrative costs. These policies facilitate various noncommercial broadcasters such as Radio New Zealand, Access radio, iwi broadcasters
and the like. Current policies only provide for reservation of actual broadcasting
spectrum, and not any other spectrum a broadcaster may choose to use, such as for
studio-to-transmitter linking, because such spectrum is a substitutable resource and the
service might be obtained via various alternative technologies. As such, a subsidy by
means of not charging commercial cost to non-commercial broadcasters would be
inappropriate as it would not promote efficient use of resources. However it would also
undermine the Government’s public broadcasting objectives if the Crown did not retain
spectrum to ensure the availability of licences, and thereby force all new STL licences to
be obtained through commercial negotiations with management right-holders.
The Ministry would welcome feedback on the appropriate amount of spectrum that
should be reserved by the Crown and that should be sold. Based on the current profile
of licences in the 915-921 MHz band 17 , the Ministry considers that approximately 25 per
cent of the spectrum should be reserved, and the remainder allocated to the market, i.e.
2 MHz retained, 6 MHz allocated.
Question 16
Do you agree with the proposal that the Crown retains and commercially manages
2 MHz of spectrum in a management right in the 841-849 MHz band in order to
allocate licences for STLs to non-rightholders? If not, what portion if any do you
consider should be retained and how should it be allocated? Please explain your
reasons.
4.1.3.3
Lot Sizes and Boundary Conditions
The spectrum to be allocated to the market should be subdivided into lot sizes, with
appropriate boundary conditions, to enable the most flexible use in order to maximise
potential channel reuse. The Ministry suggests that an appropriate lot size for each
management right would be 0.5 MHz as this is the channel size for a digital STL, while it
is equivalent to two monophonic or one stereo analogue channel. Therefore, under the
proposal that 6 MHz be auctioned, there would be 12 management rights of 0.5 MHz
each. The auction process should be designed to allow parties to acquire blocks in a
contiguous configuration, up to an acquisition limit 18 .
The management right boundaries should have conditions that are appropriate for digital
STL use, which would enable right-holders to use a digital STL, or if they chose, an
analogue STL in an appropriate channel. Once allocated, the managers could negotiate
different boundary conditions with their neighbours if they wished.
In addition, STL licences in 841-849 MHz would need to be compatible with cellular
services operating in the management right up to 840 MHz. This might be facilitated by
the Crown electing to retain its portion at the bottom of the band, i.e. 841-843 MHz.
17
There are 278 licences in this band. The Register of Radio Frequencies indicates that 97 have been granted to
the Radio Network, 87 to RadioWorks, and the remainder to mostly non-commercial and iwi broadcasters, as well
radiocommunications service providers.
18
Acquisition of contiguous rights would enable aggregation and effectively remove intermediate boundaries.
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Question 17
Do you agree with the proposed 0.5 MHz lot size if management rights are sold in the
841-849 MHz band? If not, what lot size would you prefer and why?
Question 18
Do you agree that the boundaries of proposed management rights in the 841-849 MHz
band should be conditioned to enable digital STL use? If not, what boundary
conditions would you prefer and why?
4.1.3.4
Competition Issues
Competition safeguards also need to be considered. Both acquisition limits and
implementation requirements have been used in past allocations.
Implementation requirements are more complex to apply in bands used for fixed linking
than in, for example, bands used for mobile or broadband uses. This is because usage
is inevitably uneven throughout New Zealand and different parties may assess the value
of licences in the same area differently because of their business arrangements. No
implementation requirements are therefore proposed.
Acquisition caps are a means of preventing monopolisation of the resource. The Ministry
suggests that an appropriate acquisition limit may be 2.5 MHz. This would mean that at
least three parties could acquire lots. The retention of the acquisition limit for a period of
time would tend to inhibit speculative acquisition of spectrum. The Ministry therefore
suggests that the acquisition limit might be retained for five years.
Question 19
Do you agree with the proposed 2.5 MHz initial acquisition limit for parties buying
management rights in the 841-849 MHz band and retention of this limit for a five-year
period? If not, what limits and time period do you prefer and why?
4.1.4
Impacts
Under this proposal, there would be an additional 8 MHz of spectrum available for STLs
in the 841-849 MHz range, with a longer term reduction of the utility of the 915-921 MHz
range for STLs. The new band would be managed under the management rights
regime, which would promote economically efficient use of the spectrum but might result
in less technical efficiency than if the band were controlled by the regulator. A further 8
MHz already licensed to STLs in sub-bands in the 806-960 MHz band would remain
under the radio licensing regime.
Licensees currently using the 915-921 MHz band would face costs transitioning out of
that spectrum by the end of the five-year transition period (unless they were prepared to
remain in the band without interference protection). This will include the cost of retuning
equipment or deploying new equipment if the equipment is unable to be retuned. In
addition, if a radio licence in one of the alternative bands (849-851 MHz and 929-935
MHz) is not available, these costs might include the purchase of management rights
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and/or spectrum licences at competitive prices (or possibly the cost of using an
alternative technology if this were comparatively better value).
The phasing of the transitional arrangements would mean that new or replacement
equipment could be licensed over time, but this also imposes a five-year delay to the
time when full use of the present 915-921 MHz band is available for SRDs.
Companies wishing to deploy SRDs, particularly those using spread spectrum
technologies that require greater bandwidth, might wish to take advantage of
opportunities in specific locations where there is no risk of causing interference to STLs
during Phase 1 of the transition, using a radio licence. If the anticipated benefit of the
project was significant, it might be in a company’s interest to negotiate with specific STL
licensees to facilitate their early transition out of the 915-921 MHz band in the area
concerned.
This base proposal does not address the lack of harmonisation of the 864-868 MHz SRD
band with that of Europe.
Question 20
What are your views in general on the Ministry’s base proposal for replanning the 806960 MHz band and the impacts? Are there other replanning options that you believe
the Ministry should consider, and why do you prefer them?
4.2 Variations
4.2.1
Variation 1 – Simplex Land Mobile Radio Relocation
Variation 1 would build on the base proposal by relocating the simplex land mobile radio
allocation at 868-869 MHz down to 819-820 MHz, thereby harmonising the upper
boundary of the current 864-868 MHz SRD band with the European allocation of 862-870
MHz, as illustrated in Figure 5 (page 35). The current and proposed future uses are
summarised in Table 5, below.
Table 5: Allocation changes including Variation 1
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Band
Current Allocation
Proposed Allocation
819-820 MHz
SRDs
LMR simplex
841-849 MHz
Unused
Fixed links (STLs)
868-869 MHz
LMR simplex
SRDs
869-870 MHz
Unused except for
medical telemetry SRDs
at 869.2-869.25 MHz
SRDs
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Band
Current Allocation
Proposed Allocation
915-921 MHz
Fixed links (STLs)
SRDs (long-term)
[whole band: 915-929
MHz]
921-929 MHz
SRDs, 1 watt e.i.r.p.
SRDs, 1 watt e.i.r.p.
Sub-band
920-926
MHz: RFIDs up to 4
watts e.i.r.p.
4.2.1.1
Impacts
The Ministry’s research indicates that there is no equipment available for purely simplex
LMR operation at 819-820 MHz. Equipment capable of trunked land mobile applications
and also simplex operation is available for this frequency range, but is more expensive
and such investment may not be justified for simplex users unless they are planning to
set up small networks. This would affect numerous users; there are currently 157
simplex land mobile radio licences registered at 868-869 MHz.
Users of the SRD band at 819-824 MHz may need to retune equipment to take account
of the narrower band allocation available to them.
The users of European-standard SRDs that operate in the 862-870 MHz band would be
able to use this band with less risk of interference if the LMR simplex allocation is
relocated.
Conservative interference analysis of the interface between SRDs and
CDMA2000/W-CDMA at 870 MHz concluded that interference is likely to occur for which
considerable distance separation between the services will be required. CDMA
technology is, however, more effective in regards to interference rejection, and in fact
quite small separation distances would likely be sufficient. Testing would be required to
determine if SRDs could operate next to the 870 MHz cellular boundary, although as
simplex land mobile services currently operate satisfactorily up to 869 MHz, it is likely
that SRDs could do the same.
As an alternative, it might be possible to licence SRD use in the 864-870 MHz band
without relocating the land mobile services, with acknowledgement that there would be a
potential risk of interference which may be difficult in practice to remedy by controlling
the SRD use under a general user licence. The Ministry would welcome views on this
alternative scenario.
Question 21
If your organisation has licences in the TX band (868-869 MHz) for simplex land
mobile radio, do you still require access to spectrum for this purpose? If so, how long
does your organisation intend to use this technology (do you have any plans to
transition to different technology)? Is there any other band that could you use for your
land mobile radio services instead?
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Question 22
If the simplex LMR use was not relocated from 868-869 MHz, would use of the full
864-870 MHz band by SRDs be practicable by acknowledging the risk of potential
interference to land mobile radio usage?
Question 23
What, if any, provisions might be necessary to protect the cellular services operating in
the private management right above 870 MHz from interference from SRDs if they
operated up to 870 MHz?
4.2.2
Variation 2 – Alternative Use of 819-824 MHz SRD Band
The fact that this band is not harmonised with any major trading partners’ SRD bands
suggests that it is of limited utility. The Ministry would welcome feedback from the users
of this band on its utility, and also whether they are able to retune their equipment to use
different spectrum. In addition, the Ministry seeks proposals for alternative uses of the
band.
Question 24
If your organisation currently uses the 819-824 MHz band, are your able to retune your
equipment to use different spectrum?
Question 25
What alternative uses could be made of the 819-824 MHz band currently allocated to
SRDs?
4.2.3
Variation 3 – Reuse of “Orphan” Cellular Spectrum
As noted in section 3.2 describing current spectrum allocation in this band, there is
unused ‘guard band’ spectrum held in management rights at 840-841 MHz, and 885-890
MHz. The Ministry would welcome suggestions on how this spectrum might be best
utilised.
Question 26
How can the unused spectrum (held in management rights) at 840-841 MHz and 885890 MHz best be used? For example, are there technologies compatible with the
adjacent cellular use that might be deployed?
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4.3 Illustrations of Replanning Proposal and Variation 1
Figure 1: Current Band Plan 806-960 MHz
C = Crown management right
N = 2degrees Mobile management right
T = Telecom management right
V = Vodafone management right
Figure 4: Proposed new fixed link band and 900 MHz long-term SRD harmonisation
806 MHz
960 MHz
N
T
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T
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N
N
N
V
N
N
V
Figure 5: Variation 1 (Proposed new fixed link band, long-term SRD harmonisation and LMR simplex relocation)
806 MHz
960 MHz
N
T
T
N
N
N
V
N
N
V
C = Crown management right
N = 2degrees Mobile management right
T = Telecom management right
V = Vodafone management right
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5. Summary of Questions
The Ministry would welcome submissions on the issues set out in this discussion
document. Section 1.2 provides details on how to make a submission. Responses to
any of the questions the Ministry has posed in its analysis of the current situation and
proposed changes to the 806-960 MHz band would be appreciated. The questions are
repeated below.
Question 1
Do you consider that the Ministry should investigate any other options for further
rationalisation of spectrum for cellular applications in the 806-960 MHz band? If so,
please explain.
Question 2
If your organisation uses the KK band (806-812 MHz and 851-857 MHz), do you
consider that the Ministry’s assessment of utilisation of the band is accurate? If not,
please explain.
Question 3
If your organisation has STL licences, do you consider that the Ministry’s assessment
of the utilisation of the sub-bands (849-851 MHz, 915-921 MHz and 929-935 MHz) is
accurate? If not, please explain.
Question 4
If your organisation uses any of the land mobile radio sub-bands (812-819 MHz and
857-864 MHz, and 868-869 MHz), do you consider the Ministry’s assessment of
current usage to be accurate? If not, please explain.
Question 5
With respect to the harmonisation of New Zealand’s SRD spectrum in the 806-960
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.
Question 6
Are there significant SRD-type applications that are presently precluded from being
deployed, or are more expensive to deploy, in New Zealand due to the lack of full
harmonisation with one or more trading partners in the 806-960 MHz band? Please
provide an indication of additional SRD product costs being incurred when supplied on
frequencies currently allocated for this purpose in New Zealand.
Question 7
Does your organisation wish to supply or deploy high-powered SRDs in New Zealand
in the 915-929 MHz band? If so, what are the technical parameters of the equipment
and spectrum usage?
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Question 8
Does your organisation suffer from insufficient spectrum in the 806-960 MHz band at
present, or do you see a future need for spectrum in this band that is not currently
allowed for? If so, please provide details.
Question 9
Is the band 841-849 MHz a viable option for STL use? If not, please explain.
Question 10
Are there services or applications other than STLs for which the spectrum at 841-849
MHz would be better allocated? If so, please provide details.
Question 11
Is the proposed expansion of the SRD allocation to 915-929 MHz, along with an
increase in power from 1 watt to 4 watts for RFIDs operating at 920-926 MHz, viable
and appropriate in New Zealand? If not, please explain.
Question 12
In regards to the interface between GSM/W-CDMA and SRDs at 915 MHz, would you
suggest any mitigation measures for this interface? If so, please provide details.
Question 13
Are the proposed two-phase licensing arrangements for STLs and SRDs in the 915–
921 MHz band suitable? If not, please explain.
Question 14
In Phase 2 of the licensing arrangements for STLs and SRDs in the 915-921 MHz
band, would the utility of the band for SRD use be significantly degraded by permitting
STLs to remain?
Question 15
Do you agree with the creation of management rights in the 841-849 MHz band, and
the subsequent allocation of management rights to private parties? If not, what is your
preferred alternative and why?
Question 16
Do you agree with the proposal that the Crown retains and commercially manages
2 MHz of spectrum in a management right in the 841-849 MHz band in order to
allocate licences for STLs to non-rightholders? If not, what portion if any do you
consider should be retained and how should it be allocated? Please explain your
reasons.
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Question 17
Do you agree with the proposed 0.5 MHz lot size if management rights are sold in the
841-849 MHz band? If not, what lot size would you prefer and why?
Question 18
Do you agree that the boundaries of proposed management rights in the 841-849 MHz
band should be conditioned to enable digital STL use? If not, what boundary
conditions would you prefer and why?
Question 19
Do you agree with the proposed 2.5 MHz initial acquisition limit for parties buying
management rights in the 841-849 MHz band and retention of this limit for a five-year
period? If not, what limits and time period do you prefer and why?
Question 20
What are your views in general on the Ministry’s base proposal for replanning the 806960 MHz band and the impacts? Are there other replanning options that you believe
the Ministry should consider, and why do you prefer them?
Question 21
If your organisation has licences in the TX band (868-869 MHz) for simplex land
mobile radio, do you still require access to spectrum for this purpose? If so, how long
does your organisation intend to use this technology (do you have any plans to
transition to different technology)? Is there any other band that could you use for your
land mobile radio services instead?
Question 22
If the simplex LMR use was not relocated from 868-869 MHz, would use of the full
864-870 MHz band by SRDs be practicable by acknowledging the risk of potential
interference to land mobile radio usage?
Question 23
What, if any, provisions might be necessary to protect the cellular services operating in
the private management right above 870 MHz from interference from SRDs if they
operated up to 870 MHz?
Question 24
If your organisation currently uses the 819-824 MHz band, are your able to retune your
equipment to use different spectrum?
Question 25
What alternative uses could be made of the 819-824 MHz band currently allocated to
SRDs?
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Question 26
How can the unused spectrum (held in management rights) at 840-841 MHz and 885890 MHz best be used? For example, are there technologies compatible with the
adjacent cellular use that might be deployed?
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6. Glossary
APCO
Association of Public Safety Communications Officials
CDMA
Code Division Multiple Access
e.i.r.p.
Equivalent isotropically radiated power
GSM
Global System for Mobile communications
GUL
General User Licence
GURL
General User Radio Licence
ITU-R
International
Sector
LMR
Land mobile radio
RFID
Radio frequency identification
SRD
Short-range device
STL
Studio-to-transmitter link
TDD
Time-division duplexing
TETRA
Terrestrial Trunked Radio
W-CDMA
Wideband Code Division Multiple Access
WLAN
Wireless Local Area Network
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Telecommunication Union
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– Radiocommunications