18 October 2012 Radio Spectrum 5‐Year Outlook Radio Spectrum Policy and Planning Ministry of Business, Innovation and Employment P O Box 1473 Wellington 6140 UBER GROUP SUBMISSION ON THE 5‐YEAR OUTLOOK Uber Group has reviewed the Radio Spectrum 5‐Year Outlook 2012‐2016 and thanks the Ministry of Business, Innovation and Employment for the opportunity to make a submission. We wish to submit on the following points. 1. Suggested increase in the e.i.r.p. limit for the 5470 ‐> 5725Mhz band from 1 W to 4 W We ask the Ministry to consider increasing the e.i.r.p. limit from 1 watt to 4 watts in the 5470 ‐> 5725 Mhz band. This will enable users of 802.11x equipment to achieve higher modulation rates, thereby allowing increased transmission speeds while still maintaining the same channel width and link distance. While Uber recognises this will increase the potential for harmful interference, we consider the risks can be managed adequately through a proactive approach to compliance monitoring and enforcement, education, and by industry self‐regulation 2. Isolation of the 5600Mhz allocation to Metservice from the GURL There have been several instances of inadvertent interference with the Metservice rain radar systems. This is a critical public service and we suggest the possibility of interference could be removed permanently by removing the 5600 MHz to 5620 MHz allocation currently used by Metservice from the General User License. 3. An increase in the 5Ghz band for fixed point to point links An increase in the fixed point to point (200 W e.i.r.p.) allotment of the 5 GHz band by another 100 MHz would allow multiple providers running high capacity links to share the same physical sites, and we suggest this option is considered. www.ubergroup.co.nz | 53 Port Road Whangarei | ultrafast@ubergroup.co.nz | 09 438 5472 Some background on our company Uber was established in 2003 to provide wireless broadband services to remote Northland communities. It now provides both wireless and fibre broadband services (including phone) to over 1,000 business and residential customers in Northland. Uber wireless broadband gives stable, symmetric 6Mbps internet access with optional phone services. Our key strengths are the speed and reliability of our broadband, high end technology which minimises faults calls, and our locally‐based staff and contractors. We are a privately owned Northland company. Uber owns and runs its own wireless network of over 130 transmission sites which cover around 80% of the land area of Northland from Snells Beach and Warkworth up to Te Kao in the north. This has been achieved using terrestrial radio transmission with repeaters to extend coverage into even the most difficult‐to‐reach areas. Uber Group is leading an initiative to form an industry‐wide body representing wireless internet service providers around New Zealand, for the purposes of engaging with regulatory authorities and government with one voice, sharing information, educating members and carrying out some form of self‐regulation. We understand from the Manager, Radio Spectrum Policy and Planning, that this initiative will be welcome. This submission is Uber Group’s own view but we will copy it to other WISPs and interested providers to the sector, ahead of the formation of the industry group. Thank you again for the opportunity to comment on the Outlook. Yours sincerely Hayden Simon Managing Director www.ubergroup.co.nz | 53 Port Road Whangarei | ultrafast@ubergroup.co.nz | 09 438 5472