Australian Broadcasting Corporation
submission to
Australian Communications and Media Authority
Draft spectrum reallocation recommendations for the 700 MHz digital dividend and 2.5GHz bands
July 2011
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Draft spectrum reallocation recommendations for the 700 MHz digital dividend and 2.5GHz bands
Introduction
The Australian Broadcasting Corporation (ABC) welcomes the opportunity to comment on the Australian Communications and Media Authority’s (ACMA) draft spectrum reallocation recommendations for the 700 MHz digital dividend and 2.5GHz bands.
700 MHz digital dividend
The ABC welcomes the reallocation of the frequency bands between 703 – 748 MHz and 758 – 803 MHz (excluding part of the Mid West Radio Quiet Zone).
The Corporation considers, however, that there remain outstanding several important issues related to the clearance of its broadcasting services from the digital dividend band. These are:
• Finalisation of international guidelines on appropriate protection ratios to prevent interference from International Mobile Telecommunications services operating in the digital dividend bands;
• The resultant size of the guard band spectrum on either side of the digital dividend band and conditions applicable to services operating within guard bands; and
• Ensuring broadcasters can continue to use wireless microphones within the guard bands and/or within the restacked digital television bands.
The ABC would like to see these issues resolved as soon as possible.
2.5GHz band
The ACMA proposes to reallocate the 2500-2570 and 2620 – 2690 MHz bands throughout Australia (excluding part of the Mid West Radio Quiet Zone).
The ACMA’s draft recommendation to the Minister for Broadband, Communications and the Digital Economy provides for the commencement of the reallocation period on 2 November 2011 and the conclusion on 30 September 2014 (except for Perth, where the end date
provided is 31 January 2016), with a reallocation deadline of 30 September 2013.
The timing of the reallocation period and the reallocation deadline concerns the Corporation.
As indicated in previous ABC submissions, the cost of moving some or all of the
Corporation’s electronic new gathering (ENG) and television outside broadcast (TVOB) operations from the 2.5GHz band, including the introduction of new equipment to allow it to
Draft spectrum reallocation recommendations for the 700 MHz digital dividend and 2.5GHz bands
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conduct ENG/TVOB activities across multiple bands and various coordination costs, are likely to be in the order of $9- 11million. It is estimated that the migration will take between 1 and 2 years from the point of commencement.
Currently, the ABC holds Television Outside Broadcast Network (TOBN) licences in the 2596 – 2619.5 MHz mid-band gap and 2500 – 2523.5 MHz in the lower 2.5GHz band. The
Corporation is concerned that the ACMA’s plans to significantly reduce the ABC’s TOBN allocation in the mid-band and reallocate the lower band will not allow the ABC to continue to provide high levels of ENG services.
It is imperative that no changes are made to the ABC’s spectrum allocation until the
Corporation is provided unfettered access to alternative spectrum. It is the ABC’s view that the following concerns related to the alternative bands proposed for use for ENG/TVOB services remain unresolved:
1. The 2200 – 2300 MHz band: this band is not suitable for regular airborne ENG transmitters because of the need to protect the earth station receivers of other users.
2. The 2025 - 2110 MHz band: ENG receivers will not be protected from interference from earth station transmitters in this band and so ENG/TVOB services will be restricted by coordination requirements.
3. The 2170 - 2300 MHz band: clearance of fixed links in this band is required for satisfactory operation of ENG collection stations.
The ABC considers that these issues should be addressed before any changes are made to the ABC’s spectrum allocation.
Conclusion
The ABC remains committed to working with the ACMA in its efforts to realise the digital dividend and reallocate the 2.5GHz band.
