To - Consumer Electronics Suppliers Association … upload Apr17/Free TV... · Web viewSource: RegionalTAM, 6 aggregated regional markets, all people, Total TV, based on survey 1-10

20th January 2017

Manager - Spectrum Licensing Policy Section

Spectrum Management Policy BranchAustralian Communications and Media AuthorityPO Box 78BELCONNEN ACT 2616Email: [email protected]

Dear Manager - Spectrum Licensing Policy Section

Re: Free TV Response to ACMA’s Five-year Spectrum Outlook 2016 – 2020

Free TV Australia welcomes the opportunity to comment on the ACMA’s Five Year Spectrum Outlook 2016 – 2020.

Free TV Australia (Free TV) is the peak industry body representing Australia’s metropolitan and regional commercial free-to-air television broadcasting licensees. At no cost to the public, our members provide fifteen channels of content across a broad range of genres, as well as rich online and mobile offerings. On any given day, free-to-air television is watched by more than 13.5 million Australians.

Free TV members have a fundamental role in bringing local content to Australian audiences. This includes the provision of local news services, current affairs, sports and other culturally significant programs that are relevant and responsive to regional and rural areas.

Free TV’s response and observations on the ACMA’s Five Year Spectrum Outlook 2016 – 2020 are based on bands of interest to Free TV Australia’ membership.

Free TV Australia and its membership looks forward to working with ACMA as it finalises the Five Year Spectrum Outlook 2016 – 2020.

Yours sincerely,

ROGER BUNCHDirector of Engineering

44 Avenue RoadMosman NSWAustralia 2088

T : 61 2 8968 7100F : 61 2 9969 3520W : freetv.com.au

Free TV Australia response to Five Year Spectrum Outlook 2016 – 2020

1. IntroductionThis edition of the Five Year Spectrum Outlook 2016 – 2020 introduces the following:

Demand for access to spectrum by new and increasingly sophisticated wireless technologies and uses, continues to put pressure on the spectrum management framework. When making decisions, the ACMA needs to balance this unprecedented growth in demand by new users against the requirements of existing users for ongoing access to spectrum. The ACMA must also strike the balance between government uses of the spectrum1 and other applications that it may be inappropriate to leave to market forces to address, and its availability for use by the broader community.

For over a decade, the growth in mobile telephony, including the recent rapid rise in mobile broadband traffic, has been a key driver of changes in the demand for radiofrequency spectrum. The ACMA has provided detailed public guidance on its associated strategy and work program because mobile broadband often favours bands that are heavily encumbered for a range of reasons. Therefore, how the ACMA continues to accommodate its future growth will be of interest to other industry sectors and users that value access to fit-for-purpose spectrum.

The ACMA scans the domestic and international spectrum environment to identify trends in spectrum use and likely future pressure points on spectrum. While there is an inherent degree of uncertainty in predicting spectrum requirements in future years, consideration of available evidence in advance of the likely pressure points on spectrum is valuable for two reasons. Firstly, it should ensure that the ACMA’s work priorities are closely linked to actual emerging demand pressures. Secondly, it should provide a greater degree of industry certainty about the ACMA’s priorities and promote dialogue with spectrum users about these priorities.

The ACMA is required to make spectrum management decisions and develop subordinate legislation for the purposes of planning, allocation, licensing and pricing. To ensure that these decisions are well-informed, robust and meaningful, the ACMA has developed a spectrum management decision-making framework (the Framework).2 This uniform approach to the assessment of relevant information ensures consistency in the ACMA’s decision-making and accords with the principles of best regulatory practice.

The Framework is informed by:

assessing the spectrum environment through: monitoring international developments listening to the needs of industry awareness of broader government requirements identification of spectrum demand/supply equation future needs of incumbents

It is clear from this introduction the ACMA identifies the growth in mobile telephony, including the recent rapid rise in mobile broadband traffic, has been a key driver of changes in the demand for radiofrequency spectrum as the major priority to identify trends in spectrum use and likely future pressure points on spectrum.

1 Government uses includes defence, emergency and public safety services, and scientific purposes.2 www.acma.gov.au/theACMA/About/The-ACMA-story/Facilitating/decisionmaking-process-fyso-25-1

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This edition of FYSO recognises an important part of the WRC preparatory process which involves the ACMA working closely with Asia Pacific Telecommunity (APT) to achieve a coordinated approach to radiocommunications issues in the Asia–Pacific region. Cooperation within the APT results in Australia’s positions and proposals to a WRC being harmonised with those of other countries in the region, increasing the likelihood of these being considered favourably at the WRC.

This recognition in the ACMA’s Five Year Spectrum Outlook of the work programs of the World Radio Conference Agenda Items need to be a clearly articulated i.e. the interdependence, and links between the two activities – all the agenda items within ACMA’s Preparatory Group for WRC-19 and the work programs within the FYSO.

Free TV Australia members appreciate the report provided in this edition of the completed projects within the 2015-19 FYSO, in particular, the satellite earth station coordination arrangements.

2. Issues for commentFree TV considers the emphasis the ACMA has placed on calling for comment on 5G, Internet of Things, Dynamic Spectrum Access(DSA) and ACMA’s 12 month work plan does not fully recognise the plethora of emerging issues which are being faced by a number of other existing radiocommunications services.

The list of questions, as issues for comment, present a line of inquiry projected towards proof of concept and implementation of 5G, Internet of DSA. This section of Part 1 on these new technologies does not provide any assessment on the impact on existing services within specific bands i.e. a balance with the spectrum requirements for incumbent spectrum licensees and other stakeholders.

5G, Internet of Things, (DSA) are concepts which are presented without any proposed definition to which service they are to be applied e.g. Mobile, Fixed.

It would be highly appropriate for the ACMA, when introducing concepts, to provide some evaluation of the system requirements of the technologies and technical frameworks required for their implementation as envisaged by the ACMA, to enable potentially affected existing spectrum stakeholders to provide feedback.

This edition of FYSO considers and encourages discussion on a range of spectrum related topics, it acknowledges that a key focus is the ACMA’s analysis of current and future demand for a particular use—mobile broadband. This is presumably driven by a demand for mobile broadband is likely to continue for a number of years. This demand needs to be differentiated between what may be allocated for Mobile network requirements and planned on a Primary basis and spectrum use for mobile applications which will operate on a Secondary basis.

The future mobile broadband demand will need to be evaluated in the studies for WRC-19 based upon the various broadband applications and mobile data within new frequency allocations suitable for mobile broadband (such as Wi-Fi) and spectrum suitable for 5G mobile broadband network services.

Free TV recognises

The ACMA and stakeholders will need to build capabilities to respond to a number of significant challenges, including:

demand for mobile broadband capacity, including the rollout and development of 5G technologies, will lead to continuing demand for additional spectrum

certain developments in technology, such as DSA, will require spectrum but at the same time potentially provide solutions to more efficient use of spectrum for services such as broadcasting and land mobile

existing services, including broadcasting, satellite, fixed and science services, will require ongoing access to spectrum.

We note that FYSO indicates in relation to the potential implementation of DSA

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geolocation with database look up, sensing, and beacon transmissions techniques of DSA can be used to make use of spectrum ‘white space’, where secondary users take advantage of intermittent, occasional or itinerant use by primary users. Services can be geographically variable but relatively slow-changing, like in a frequency band used by broadcasting services, or have relatively high levels of temporal availability that is constantly changing, like in a frequency band used by land mobile services.

Secondary intermittent, occasional or itinerant use by secondary users in a frequency range does not provide / maintain certainty for Primary users. It is necessary to establish technical frameworks which provide clearly articulated technical and regulatory guidance for both Primary and Secondary users. The issue of latency in the switch off of the DSA systems needs to be accurately specified.

Any regulatory regime established for implementation of DSA needs to be balanced against the resources required to assess the impact of these new developments on and the technology advancements and future spectrum requirements of existing Primary services. As has been clearly defined in the ACMA’s Radiocommunications (Low Interference Potential Devices) Class Licence 2000 for many devices including wireless microphones.

ACMA is seeking comment (along with evidence) 10. When, or under what circumstances, would it be appropriate to move beyond monitoring

international regulatory and technical developments and consider implementation of arrangements in Australia?

Free TV Comment: It would only be appropriate to move beyond monitoring international regulatory and technical developments and consider implementation of arrangements in Australia when proof of performance of the DSA technologies can be assured.

12. Are there simple changes that can be made to the regulatory framework that would better allow facilitation of trials of DSA approaches and development of implementation arrangements?

Free TV Comment: Australia is not a DSA technology standards setter or manufacturer. It would be prudent for Australia to follow testing which has been undertaken elsewhere and seek replication of studies to gain proof of performance and suitable implementation models which meet Australian requirements.13. Are there any spectrum bands, services and/or applications, in particular that will be, or

should/shouldn’t be, targeted in Australia for trials or initial implementation of DSA frameworks?

Free TV Comment: Any spectrum bands where existing spectrum stakeholders have implemented services where there are well established protection ratios should provide sufficient modelling to assess the impact of implementing DSA in those bands.How can Australian spectrum stakeholders provide the evidence the ACMA requires on these new technologies and application without candidate specifications for DSA to evaluate the potential interference on existing services within specific bands in Australia?

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3. Topics of interest to Australian commercial television broadcastersOn 25 August 2015, the government agreed to implement the recommendations of the Spectrum Review undertaken by the Department of Communications and the Arts (DoCA). Free TV Australia is aware this edition of the ACMA’s Five Year Spectrum Outlook will be applied concurrently to implementation of the government’s Spectrum Review reforms which will impact licensing, device supply schemes, pricing, compliance, enforcement and ACMA’s spectrum management functions. Of particular interest, will be what this edition of the FYSO indicates are reforms towards better integrating the management of public sector and broadcasting spectrum to improve the consistency and integrity of the framework:

a) Monitoring current mobile broadband spectrum planning project – 600MHzb) Review of the Apparatus Licence Tax arrangements associated with television outside

broadcast servicesc) Customer Self Serviced) Planning for roll out of digital radio in regional areas of Australiae) Remake of the ACMA’s Broadcasting Services (Technical Planning) Guidelines 2007f) Any variations to TLAPsg) Ongoing advice on TV reception difficultiesh) Support to spectrum management for major events

Part 1 - ACMA’s priorities and annual work programFree TV appreciates this section sets out the ACMA’s high-level approach to decision-making, how evidence is used to identify priorities and develop work programs, and information on external pressures that affect spectrum management. The key issue for the ACMA will be the extent to which implementation of the Spectrum Review recommendations will affect the ACMA’s spectrum management priorities in the future.

Part 1 also includes a discussion of the ACMA’s response to the significant issues affecting current and future demand for spectrum with particular emphasis on the mobile broadband.

Part 2 - ACMA’s work plan 2016-17Free TV notes the following overriding issue which will be concurrent in the time frame 2016-2020:

The ACMA welcomes the Spectrum Review recommendation that the ACMA should provide the minister with an annual work program, prepared in consultation with stakeholders, including key priorities over a three-to-five-year time frame. The present measure does not, however, purport to anticipate or pre-empt implementation of this recommendation, which awaits passage of a new Act and any ministerial directions or requests. In the interim (prior to implementation of the review) however, the Authority would welcome industry engagement and feedback on the format and the increased level of detail provided about each project. The work plan is presented under three broad themes: maximising the overall public benefit arising from use of spectrum; reducing the cost to business arising from regulation; and implementing current reform priorities.

A new feature of this edition of the Five Year Spectrum outlook is the ACMA’s 12 month work plan, which assigns milestones and timings to priority spectrum management activities over the 2016–17 financial year. We note the ACMA considers it is not intended that the work plan will remain static, but rather, it will be adjusted in accordance with shifts in priorities and extrinsic factors such as the government’s priorities overall and, in particular, spectrum reform.

As indicated above, the FYSO work plan needs to be linked to the work programs of the World Radio Conference Agenda Items, as they progress within the Australian Radio Study Groups. If implied, this is not a stated objective.

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It is encouraging to read the first part of ACMA’s work plan for the 2016–17 financial year towards maximising the overall public benefit arising from the use of spectrum will ensure ACMA’s spectrum management decisions in support of mobile broadband needs to be balanced with the impacts on other spectrum users i.e.

in the first part, key priority projects are grouped under three broad themes:◦ maximising the overall public benefit arising from the use of spectrum

◦ reducing the cost to business arising from regulation

◦ implementing reform outcomes.

in the second part, projects and activities are listed in two tables on the following basis:

◦ band-by-band projects

◦ regulatory and service-planning projects.

Part 3 - Mobile broadband work programThis edition of FYSO contains the ACMA’s mobile broadband strategy update. This is the first mobile broadband annual update to be included in a FYSO. The update outlines each of the projects that fall under the program, with details such as the project phase, work undertaken and next steps.

It is noted this edition of FYSO states

evidence suggests Australia currently has sufficient spectrum available for mobile broadband services in the short to medium term. However, long lead-times for making additional spectrum available, and the importance of international harmonisation, mean that the ACMA will press ahead with work in this area.

While international harmonisation may be required for a percentage of usage for global roaming / cross border operation of mobile devices, how this translates to overall individual national spectrum demand, sub band allocation and planning needs to be determined. It should not be implied the spectrum requirements of one country’s spectrum requirements applies to all other countries spectrum requirements. Accuracy in determining national spectrum requirements is essential.

This edition of FYSO also states

While there is a focus on dedicated high frequency mmW spectrum bands for 5G, there has been some interest in the use of lower frequency bands, including the 2.3 GHz3, 2.5 GHz4, 3.5 GHz and 3.6 GHz bands. The 2.3 GHz, 2.5 GHz and 3.5 GHz bands are already available for use for mobile broadband services in Australia and could feasibly be used for early deployment of 5G or pre-standard 5G in Australia.

Free TV Australia is aware that potentially not all of these bands will be available for 5G on a global basis.

Of concern to Free TV Australia is that while this edition of the FYSO indicates

…. the ACMA needs to balance this unprecedented growth in demand by new users against the requirements of existing users for ongoing access to spectrum,

the balance between the future requirements for mobile broadband and the requirements of existing users of spectrum does not appear to have been identified as an objective within the mobile broadband work plan nor indicated as tasks as translated from the frequency bands within the monitoring stage of the current mobile broadband spectrum planning projects to the band-by-band work program in Schedule 1.

3 Spectrum Challenges for 5G, Eric Fournier, Chairman, Electronic Communications Committee. 4 Paving the Road to 5G, Sprint news release, 3 June, 2016.

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Is the ACMA going to undertake a study to provide evidence into the spectrum requirements for 5G in Australia? i.e.

traffic requirements on existing or future networks applications for deployment in frequency bands above 23GHz applications for deployment in frequency bands below 6GHz bandwidth requirements for frequency bands above 23GHz bandwidth requirements for frequency bands below 6GHz

Having these elements contained within the Mobile Broadband Work Program would allow existing users some certainty in assessing their own requirements against those seeking potential candidate bands for 5G, and permit the ACMA to further develop the Mobile Broadband Work Program with greater transparency.

The frequency range of major concern to Free TV Australia which the FYSO proposes for monitoring is the 600MHz band. Free TV has major concerns regarding its spectral definition as “520-694MHz” (refer Table 13).

It is surprising to Free TV Australia the ACMA has had informal discussions with other regulators including FCC on the US incentive auctions prior to having discussions with Australian free-to-air terrestrial television broadcasters regarding their future spectrum requirements. Further, any suggestion that the situation in the United States for terrestrial television broadcasting mirrors that in Australia for Australian free-to-air terrestrial television broadcasters, would be an error.

Table 14 within this edition of the FYSO indicates that a relevant issue is that the US and 13 other countries have identified the 600MHz band for IMT. More accurately all or part of the 600MHz band was identified for IMT by the Bahamas, Barbados, Belize, Canada, Colombia, the US, Mexico, Micronesia, the Solomon Islands, Tuvalu, Vanuatu, Bangladesh, Maldives and New Zealand.

All but 2 of the countries who added their names to country footnotes in the Radio Regulations at WRC-15 are small in geographic area and have a much smaller requirement for spectrum for terrestrial television broadcasting than Australia i.e. Bahamas, Barbados, Belize, Colombia, Micronesia, the Solomon Islands, Tuvalu, Vanuatu, Bangladesh, Maldives and New Zealand.

In the case of Canada, Mexico and the US they have access to the VHF band as well as the larger UHF band (470-698MHz) for their terrestrial television broadcasting and are focusing on the frequency range 614-698MHz at present for the Incentive Auction.

As developments since February 2016, this edition of the FYSO indicates

- the FCC incentive auction began on 29 March 2016. - In February 2016, ITU-R Working Party 5D commenced revision of Recommendation ITU-R

M.1036-5 on Frequency arrangements for implementation of the terrestrial component of International Mobile Telecommunications (IMT) in the bands identified for IMT in the Radio Regulations (RR). The draft revision includes arrangements for the frequency band 470–698 MHz. Working Party 5D is aiming to complete the revision in late 2017.

- the AWG has a work plan to develop a recommendation on frequency arrangements for the 470–698 MHz band. The current proposal is to finalise the work in late 2017.

FYSO indicates next steps will include

The ACMA will also engage with industry and the government regarding technological evolution of terrestrial digital television, including DVB-T2 and HEVC. Adoption of these technologies is likely to be a pre-requisite for any future reallocation of broadcasting spectrum for non-broadcasting uses, though it is also key to the more efficient use of spectrum by the television industry itself. Both the government and the ACMA have emphasised the availability of ‘sixth channel’ spectrum for trialling the new standards.

This suggests that developments for future reallocation of the UHF band currently assigned to terrestrial television broadcasting are well in advance of any consideration of the future

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requirements and facilitation of the requirements of terrestrial television broadcasting and its future evolution.

4. Spectrum requirements for terrestrial television broadcasting Continuing access to radiofrequency spectrum in the television broadcasting bands (174-230MHz and 520-694MHz) is essential for providing television services across Australia. As a result of the Digital Dividend and the re allocation from television broadcasting to mobile telecommunications of the band 694-820MHz, the allocation of spectrum to television broadcasting in Australia is limited.

Currently free-to-air television broadcasters have in the order of the following distribution of channel assignments at transmission sites by spectrum band across Australia:

Frequency Band Location No of Sites Location Number of SitesVHF Band III (174-230MHz) Metropolitan 7 Regional 76

UHF Band IV (526-582MHz) Metropolitan 9 Regional 156

UHF Band V (582-694MHz) Metropolitan 12 Regional 382

Source: ACMA Indicative Channel Chart – December 2014

4.1 The importance of free-to-air commercial broadcasting to rural and regional AustraliaThere is a predominance of UHF band assignments to regional broadcasting service areas in Australia.

Following is an extract from the Free TV Australia submission to the Standing Committee of the Department of Communication and the Arts – February 2016:

Television reaches almost 4.8 million regional Australians every night between 6pm and midnight. People in regional Australia watch on average just under 3 hours and 15 minutes of television per day.5 Commercial free-to-air television is highly valued by viewers in regional and rural Australia. Overall, 80.9 percent of regional Australians watch commercial free-to-air television in any week.6

In 2013 the ACMA conducted an investigation into the operation and effectiveness of the existing regulatory arrangements for the broadcast of material of local significance on regional commercial television, including community research conducted by Newspoll, to identify community attitudes and behaviour relating to local content in regional Australia via a national omnibus survey.

It found that local content was very important to regional Australians and that satisfaction with existing sources of local content was high. In particular:

91% of regional Australians consider local content to be important and 62% consider it to be very important;

91% of regional Australians report having access to all the local content they would like; Television is the preferred source for local news; While regional Australians do access local content online, a significant amount of online local

content is re-purposed content from television broadcasters, which would not exist but for the presence of the regional broadcasters; and

Television is the preferred source for local news in regional Australia ahead of both radio and local newspapers.7

These findings demonstrate the significance of local content provided by commercial free-to-air television to regional and rural Australians.

5 Source: RegionalTAM, 6 aggregated regional markets, all people, Total TV, based on survey 1-10 2015 ex Easter (08/02/2015 – 28/03/2015; 12/04/2015 – 28/11/2015), based on average daily reach and time spent viewing consolidated data.6 Source: RegionalTAM, 6 aggregated regional markets, all people, Free TV, based on survey 1-10 2015 ex Easter (08/02/2015 – 28/03/2015; 12/04/2015 – 28/11/2015), based on average weekly cumulative reach, consolidated data.7 ACMA, Regional commercial television local content investigation, December 2013, at 29.

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Refer Attachment A - The importance of commercial broadcasting to rural and regional Australia

4.2 Spectrum allocations for terrestrial television broadcastingInternationally, there are a number of significant variations which indicate that Australia, as a country with services dispersed over large geographic areas, has significantly less spectrum for DTTB than countries in other regions. Refer Table 1.

Table 1Television Broadcasting Spectrum Allocations

  Region 1(Africa / Europe)

Region 2(Americas)

Region 3(Asia Pacific)

Australia

Band I 21 MHz 18 MHz 17 MHz 21 MHzBand III 56 MHz 42 MHz 56 MHz 56 MHzBand IV/V 392 MHz* 414 MHz 420 MHz 174 MHzTotal 469MHz 474MHz 493MHz 251MHz* In Region 1 only 392 MHz is available across the Region but in the African broadcasting area a further 98 MHz is available between 862 – 960 MHz.

Refer Attachment B - Spectrum allocations for terrestrial television broadcasting

Not all of the spectrum identified for television broadcasting is necessarily available for DTTB, due to assignments to other services in the bands, such as DAB in VHF Band III e.g., for Australia Table 2 below shows the broadcast spectrum available for DTTB. For the planning of DVB-T services for 2001, Australia did not consider VHF Bands I and II.

Table 2Spectrum allocated to DTTB in Australia

  Australia Australian DTTBBand I 21 MHz -Band III 56 MHz 42Band IV/V 174 MHz 174

Notes:

1. Of the 56MHz allocated to VHF Band III only 42MHz is available in most areas, 14MHz is allocated to Digital Audio Broadcasting in Adelaide, Brisbane, Melbourne, Perth and Sydney as a sub-band. The ACMA is now planning rollout of digital radio in regional areas including trial services in Canberra and Darwin.

2. Noting that not all of the available UHF spectrum identified for DTTB can actually be used as Channel 27 is only 6 MHz.

For a comparison of Australia’s available DTTB spectrum with the broadcast spectrum potentially available in other countries shows some interesting differences, particularly channel assignment availability, refer Table 3.

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Table 3Spectrum allocations and system variants for DTTB in other countries

AustraliaFrequency rangesVHF - 174-230MHzUHF - 520-694MHzChannel Raster 7MHzNumber of available DTTB channels30DTTB SystemDVB-T

United KingdomFrequency rangesVHF – NilUHF – 470 to 790MHz8

Channel Raster 8MHzNumber of available DTTB channels40DTTB System(s)DVB-T / DVB-T2

CanadaFrequency rangesVHF – 54 to 72, and 174 to 216MHzUHF – 470 to 608 and 614 to 698MHz9

Channel Raster 6MHzNumber of available DTTB channels47DTTB SystemATSC

United StatesFrequency rangesVHF – 54 to 72, and 174 to 216MHzUHF – 470 to 608 and 614 to 698MHz10

Channel Raster 6MHzNumber of available DTTB channels47DTTB SystemATSC

JapanFrequency rangesVHF – 170 to 222MHzUHF – 470 to 710MHzChannel Raster 6MHzNumber of available DTTB channels48DTTB SystemISDB-T

Russian FederationFrequency rangesVHF –47 to 74, 76 to 100 and 174 to 230UHF – 470 to 790 MHz.Channel Raster 8MHzNumber of available DTTB channels47DTTB SystemDVB-T

8 In the UK Ofcom is currently in the process of clearing the 700MHz band. Refer - https://www.ofcom.org.uk/consultations-and-statements/category-1/maximising-benefits-700mhz-clearance

9 Industry Canada has low power TV assignments up to 800MHz on a co-primary basis. “Industry Canada will determine what the required changes are to the Canadian Table, and implement these changes after the US incentive auction results become available.” Refer - http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf11049.html The UHF band (470-698MHz) is widely used for low power wireless microphones and camera systems.

10 In the US the future use of the band 614 to 698MHz is subject to the outcomes of the “Incentive Auction”.

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4.3 Technological evolution of terrestrial digital televisionFree TV is encouraged by the following in relation to the monitoring of developments with the 600MHz band:

The ACMA will also engage with industry and the government regarding technological evolution of terrestrial digital television, including DVB-T2 and HEVC. Adoption of these technologies is likely to be a pre-requisite for any future reallocation of broadcasting spectrum for non-broadcasting uses, though it is also key to the more efficient use of spectrum by the television industry itself. Both the government and the ACMA have emphasised the availability of ‘sixth channel’ spectrum for trialling the new standards.

This is in line with the Free TV submission to the Department of Communications consultation on Digital Television Regulation in 2015 where Free TV stated in its submission:

The preferred technology pathway is one that takes broadcasters from where we are now (DVBT/MPEG2) towards the most efficient modulation and compression technologies (DVBT2/HEVC), with minimal disruption to consumers.

Refer Attachment C - Technological evolution of terrestrial digital television.

4.4 Australian terrestrial television broadcaster’s spectrum requirements In a Free TV Australia input contribution (Document 6B/22) to the January 2016 meeting of Working Party 6B of ITU-R Study Group 6, Free TV Australia sought advice from interested stakeholders (television broadcasters and regulatory agencies in other countries) on the requirements for delivering one of the new broadcasting technologies under development, ultra-high definition television. Refer Attachment D Australian terrestrial television broadcaster’s spectrum requirements.

Free TV Australia indicated the capacity currently available in an Australian 7MHz TV channel for providing digital TV program content i.e. 23Mbps, using the DVB-T transmission system and MPEG-2 coding typically delivered 1 x High Definition (HDTV) programs and 4 x Standard Definition (SDTV) programs plus soundtracks and ancillary data.

Free TV also indicated that now a sufficient number of digital television receivers had the capability of MPEG-4 coding and Australian television broadcasters had commenced transmissions which provided the potential capability of 5 x HDTV programs.

Free TV was aware of the current specification (ITU-R Recommendation BT.2073) indicating the delivery of ultra-high definition (4k) programs would require a maximum bit rate of 30Mbps for HEVC coding.

Free TV was also aware that adoption of the new transmission technology, DVB-T2, would potentially provide an increase to 30Mbps in a 7MHz channel. This could potentially deliver a number of HDTV programs or one UHDTV program.

Currently Australian commercial television broadcasters have business models which rely on 1 x HDTV programs and up to 5 x SDTV programs (refer Attachment D).

Under this business model, the spectrum limitations of only 1 x 7MHz channel available, Australian commercial television broadcasters could not provide any UHDTV programs.

Working Party 6B has taken Free TV’s proposals into consideration and developed a study based on these challenges facing Free TV and recognised by television broadcasters in other countries i.e. the establishment of a Rapporteur, Mr Craig Tanner (CBS Network, United States) to consider and report upon bit rate requirements for UHDTV. Refer Annex 11 to 6B/29 - http://www.itu.int/md/R15-WP6B-C-0029/en.

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5. Migrating to new digital television broadcasting technologiesIn Australia, the migration to digital television broadcasting, the European DVB-T system and MPEG coding, commenced in 2001 and was completed in 2013.

Terrestrial television broadcasters in many countries have recently been migrating to the new digital television broadcast transmission technology, DVB-T2, and recently the newer High Efficiency Video Coding (HEVC). Refer Attachment E - DVB-T2 Fact Sheet.

These countries are relying on the availability of sufficient spectrum being available to be able to provide a “simulcast” of the existing DVB-T services to launch new DVB-T2 services thus allowing the public to acquire DVB-T2 capable receivers. This is the case in Germany at present - https://www.dvb.org/news/dvb_t2-hd-service-launched-in-germany/country/germany

In Australia, the only vacant spectrum assigned to terrestrial television broadcasting is 1 x 7MHz channel at each transmission site within a service area. As indicated by the ACMA in the FYSO Both the government and the ACMA have emphasised the availability of ‘sixth channel’ spectrum for trialling the new standards.

There does not appear to be sufficient spectrum to achieve a “simulcast” of the existing DVB-T services, launch a full suite of new DVB-T2 services to meet the Australian television broadcaster’s business models and allow the public to acquire DVB-T2 capable receivers.

In relation to the ACMA’s Mobile Broadband Work Plan and the monitoring of the 600MHz band i.e. Next Steps states:

The ACMA will also engage with industry and the government regarding technological evolution of terrestrial digital television, including DVB-T2 and HEVC. Adoption of these technologies is likely to be a pre-requisite for any future reallocation of broadcasting spectrum for non-broadcasting uses, though it is also key to the more efficient use of spectrum by the television industry itself.

Free TV Australia questions the availability of the 600MHz band for the reallocation of broadcasting spectrum for non-broadcasting uses without the following being considered:

a) Should the ACMA redefine the “600MHz band” as 614-694MHz?b) What are ACMA’s proposals for replacing the television services to the Australian public

within the areas covered by 559 transmission sites in metropolitan and regional Australia, if the band 520-694MHz were to be reallocated to non-broadcasting uses?

Free TV Australia considers the ACMA should withdraw any consideration of the band 520-694MHz being reallocated to non-broadcasting uses from the Mobile Broadband Work Plan.

Whilst we note the Next Steps proposed by the ACMA, the work plan does not indicate a requirement for a migration to new technologies, should a portion of the 600MHz band be reallocated to non-broadcasting uses.

6. Part 4 - Project work program 2017-20As a preface to the forecast 2017 – 2020 project work program, the ACMA has provided in Part 2, the band-by-band projects for 2016-17 and regulatory and service planning projects for 2016-17.

Free TV Australia appreciates Part 4 of this edition of the FYSO sets out the ACMA’s spectrum management 2017 – 2020 work programs it expects to commence, or continue to progress. It represents the ACMA’s preliminary thinking on priorities and provides an early opportunity for stakeholders to provide feedback on the ACMA’s proposed planning framework.

While both are necessarily sequential, it is unfortunate the proposed Mobile Broadband Work Program for the same period which is outlined in Part 3 has not been considered in an overall ACMA spectrum work plan for 2016 – 2020.

Clarification is sought as to whether the proposed Mobile Broadband Work Program for 2016-2020 stands outside the other programs outlined in the FYSO?

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Is it possible that work plans on bands could be established with conflicting outcomes if all work plans are not addressed in one overall plan rather than separate work plans?

Schedule 1: Band by band work program 2017-20As outlined above there are several frequency ranges in Schedule 1 for the period 2017-2020 which overlap with frequency ranges listed in the band by band projects for 2016-2017. Readers of this edition of the FYSO have to take this into consideration with any detailed appreciation of the overall 2016-2020 work programs. In future editions of the FYSO could this information be presented as parts of an overall work plan?

Schedule 2: Regulatory and service planning work programs 2017-20Regulatory and service planning work programs are essentially the regulatory outcomes of a preceding stakeholder engagement that accounts for

- spectrum demand analysis,- spectrum and technology determinations, and- spectrum re allocation assessment.

It is anticipated the regulatory and service planning work programs for the period 2017-20 are going to be related to the band by band projects and regulatory and service planning projects for 2016-2017. However, the regulatory and service planning work programs in Schedule 2 do not relate completely to the work plan in Part 2, nor the band-by-band projects for 2016-17 and regulatory and service planning projects for 2016-17.

One of the most important resource and management aspects of spectrum planning for any organisation, whether it be the ACMA or spectrum licensees, are qualified, skilled and experienced staff to undertake engagement on spectrum matters, spectrum requirements forecasting and spectrum planning.

The disjointed presentation of the material in this edition of the FYSO does not provide an overall comprehensive plan to assist with a full appreciation of the issues which potentially will need to be addreseds in the period 2016-2020.

Many organisations who have analysed this edition of the FYSO may have been inclined to reformat the document so corresponding information was presented in a continuum. Having done so, the interleaving process indicates much clarification is required to satisfy the interests of many spectrum stakeholders.

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Attachment AThe importance of commercial broadcasting to rural and regional Australia(Extracted from Free TV Australia submission to Standing Committee on Communication and the Arts – February 2016)

Attachment BSpectrum allocations for terrestrial television broadcasting

Attachment CTechnological evolution of terrestrial digital television

Attachment DAustralian terrestrial television broadcaster’s spectrum requirements

Attachment EDVB-T2 Fact Sheet

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