A Submission to the Ministry of Economic Development, Radio Spectrum Management Group, in response to the Ministry's: "Radio Frequency Auction: 2.3 GHZ and 2.5 GHz Bands - Discussion Paper"
|0.1||01/09/2007||Mark Gooding||Initial version|
|0.2||10/09/2007||Bruce Douglas||Reviewed version|
|0.3||12/09/2007||Mark Gooding||Reviewed version|
2.1 Introduction: Summary
This Submission is made on behalf of NZART Council and is in response to the Radio Frequency Auction: 2.3 GHz and 2.5 GHz Bands document that appeared on the Ministry's web page during August 2007 at http://www.rsm.govt.nz/cms/policy-and-planning/spectrum-auctions/2-3-2-5-ghz auction and which invited a response.
The New Zealand Association of Radio Transmitters Incorporated.
Contact person for further details:
General Secretary: Debby Morgan ZL2TDM,
P.O. Box 40 525,
Upper Hutt 5018.
Phone: 04 939 2189 Fax: 04 939 2190
NZART Web page: home/
Discussion with NZART's Administration Liaison Officers (ALO's) Bruce Douglas and Mark Gooding, NZART's Frequency Management and Technical Advisory Group (FTMTAG) Doug Ingham (ARE038), and Fred Johnson (ARC067); and representing the MED - Brian Miller and Alex Orange.
Notes from this meeting are contained within the NZART Headquarters InfoLine No. 134 available at;
Amateurs have an allocation in the band namely at 2.396 GHz - 2.400 GHz this 4 MHz allocation is on a secondary user basis. New Zealand amateurs are seeking, to be made primary users of this allocation, with an expansion from 2396-2400 to 2390-2400 GHz and to align with the Australian band plans by allocating an additional allocation at 2300-2302 GHz.
In November 2006, Cabinet decided to reconfigure the 2.3 GHz spectrum rights and to allocate new rights by auction.
On 9 March 2007, the Ministry of Economic Development met with representatives of the Amateur Radio Service in New Zealand. This meeting consisted of NZART's Administration Liaison Officers (ALO's) Bruce Douglas ZL2WP and Mark Gooding ZL2UFI, NZART's Frequency Management and Technical Advisory Group (FTMTAG) Doug Ingham ZL2TAR (ARE038), and Fred Johnson ZL2AMJ (ARC067).
The current proposed usage of the allocation for is linking, in particular as a linking resource for the National UHF System. The linking was proposed to use two linking pairs of an approximate 2 MHz bandwidth, which with only 4 MHz total means only two linking channels. The channels are to be a city based one on 2446-2450 and on 2396-2400 MHz. The rural based one would be a reverse of the city channel (i.e. 2396-2400 and 2446-2450). On 10 April 2007, the Ministry of Economic Development released a discussion paper for industry feedback on options for the design of a 2.3 GHz spectrum auction in late May 2007. Later in May 2007 the Minister of Communications reported to Cabinet on consideration of submissions and recommended a joint auction of the 2.3 GHz and 2.5 GHz band. After careful consideration of stakeholders' submissions, Cabinet decided to postpone the auction of 2.3 GHz spectrum, and to bring forward the auction of 2.5 GHz spectrum, to enable a joint auction in December 2007, following decisions of the World Radio Conference in November 2007. The reallocation of the 2.3 GHz and 2.5 GHz bands will provide increased certainty for investment in new broadband wireless access services using this spectrum. The current management rights in the 2.3 GHz band will expire in 2010, but some of the rights may be available for access before this date. The management rights in the 2.5 GHz band are expected to be available by January 2009. The current discussion paper (released in August 2007) covers the following:
* background, including cabinet decisions, current government policy on spectrum allocation,
and technical descriptions of available spectrum
* considerations regarding lot design
* proposed lot design options
* terms and conditions relating to management rights
* Maori Interests
* proposed allocation procedures and usage rights for managed spectrum parks
* transition planning for existing licence holders in the 2.5GHz band
This submission is in response to the consultative process that commenced last year and now the subsequent Submission on the Radio Frequency Auction: 2.3 GHz and 2.5 GHz Bands.
Amateurs have an allocation in this band namely at 2.396 GHz - 2.400 GHz, a 4 MHz allocation on a secondary user basis.
The current proposed usage of the allocation is for linking, in particular as a linking resource for the National UHF System. The linking was proposed to use two linking pairs of an approximate 2 MHz bandwidth, which with only 4 MHz total means only two linking channels. The channels are to be a city based one on 2446-2450 and on 2396-2400 MHz. The rural based one would be a reverse of the city channel (i.e. 2396-2400 and 2446-2450 MHz).
The 12cm allocation for NZ Amateur Radio is currently 2396 to 2450 MHz. 2400 to 2450 MHz is also currently designated "Industrial, Scientific and Medical" ISM Band. The industrial, scientific and medical (ISM) radio bands were originally reserved internationally for noncommercial use of RF electromagnetic fields for industrial, scientific and medical purposes.
The ISM bands are defined by the ITU-R in 5.138 and 5.150 of the Radio Regulations. Individual countries' use of the bands designated in these sections may differ due to variations in national radio regulations. In the United States of America ISM is governed by Part 18 of the FCC rules and should not be confused with Part 15 rules. Communication is not permitted under Part 18 (ISM) rules.
In recent years they have also been shared with license-free error-tolerant communications applications such as Wireless LANs, Bluetooth, Cordless Phones and TV extenders. There are also Networks for increasing coverage. These may be private or commercial. It is unknown whether these conform to current regulations which limit transmitter power to 4 W EIRP.
However equipment for increasing transmitted power and antenna gain are easily available in New Zealand and from overseas.
The problem for amateurs is a spill over from this equipment into the amateur allocation.
Further an alignment to the Australian frequencies is considered desirable, that of 2300-2302 MHz
The NZ Narrowband segment is 2.424 to 2.425 GHz, which is in the middle of the ISM band, and is being significantly "noised" up by other users. This narrowband segment is also used in Japan Amateur Bandplan for Narrowband activity http://www.iaru-r3.net/r3bandplan.doc
EME (Earth-Moon-Earth) Activity, overseas is typically on segments around 2.304 GHz. Wellington station ZL2AQE produced an EME world record almost 20 years ago on that frequency:
Therefore New Zealand amateurs are seeking, to be made primary users of this allocation, an expansion from 2396-2400 to 2390-2400 GHz and to align with the Australian band plans with an allocation at 2300-2302 GHz. Additional allocations may be requested to align with other countries subject to negotiation.
The 2.5 GHz band spans from 2500 to 2690 MHz.
Below this range:
* 2400-2483.5 MHz is an ISM band managed by a General User Licence as described earlier; and * 2483.5-2500 MHz band allocated to Fixed, Mobile and Mobile Satellite services in New Zealand is currently not used by any of these services. Hence no licenses exist in this band. Amateurs have no allocation in this band - 2.5 GHz (2500 to 2690 MHz).
Do you agree with the considerations discussed in this chapter concerning lot design? Please provide any comments under the following headings:
a. Expected technical developments and likely demand. Amateurs expect that increasing demand on the bands may result in their allocation decreasing over time, or being removed and re-allocated to the commercial services. One concern that amateurs have, is that although it is used locally by amateurs and perhaps as such appears underutilised then when commercial pressure comes on, the amateur usage is easily dismissed. It must be noted that if an auction process is used, then amateurs are immediately disadvantaged as they have no way to recover any costs involved in the auction process as amateurs are excluded from any pecuniary advantage as outlined in the International Regulations, and also those in New Zealand.
b. Size and location of the managed spectrum park or parks, including: o whether two MSPs should be provided for in the 2.5 GHz band in order to allow for FDD (including CMAR) uses.
As outlined in (a) above Amateurs have great difficultly competing in auctions due to the lack of financial backing and inability to recover costs.
d. Technical issues such as:
* accommodating TDD and FDD technologies;
* other. Guard bands are a concept that amateurs prefer to ensure that technologies do not spill over into their allocations, especially in areas where as secondary users we have to accept interference within the band, and being forced to also accept out of band interference, can make using the band impossible or at the least very difficult.
e. Preferences regarding auction type. Amateurs if allocated a band without involvement in the auction process is the best possible as amateurs have no ability to pay for spectrum allocations.
Do you prefer Option A, B or C for the lot design? Please explain why. If you prefer Option C is your preference for C(i) or C(ii)? Why? If there is an alternative option you prefer please specify it and explain why it would be preferable.
What provision should be made regarding allocation of spectrum in the 2.3 GHz and
2.5 GHz bands for use by Maori (i.e. Maori service providers)? What provision should be made regarding allocation of spectrum in the 2.3 GHz and 2.5 GHz bands for use for Maori (i.e. Maori as service consumers, or in the interests of
Maori language and culture)?
What terms and conditions should apply to this spectrum?
Amateurs have no issues with the Maori interests. However, Amateurs would like to make the comment that we have a similar interest. The Maori people are maintaining their language and culture through the use of the RF spectrum. Amateurs too, require access to spectrum to further our hobby, which has as an essential component of self training and development of technical skills associated with radio frequency engineering. The 2 GHz region is a convenient place for experimentation, both with hardware and equipment operation.
Do you agree that no restrictions should be placed on the eligibility of parties to bid for lots?
Do you consider the expiry of acquisition limits 1 year before the (December) use or lose date to be satisfactory? Do you prefer a different acquisition limit date? Please explain reasons for your view? Do you have any other comments on the time for acquisition limits to expire?
Do you prefer a date of December 2012, 2014, or 2016, for applying the use or lose test? If not what alternative date would you prefer to implement the Cabinet decisions on use or lose? Please explain. Do you prefer Option A or Option B or some other option regarding the test for 'use'? If you do not agree with the proposals, what 'use or lose' provisions do you propose? Should financial consequences result from not using rights, either in addition or as an alternative to loss? How should the amount of any financial consequence be calculated?
Do you agree with the proposed settlement terms (30 days following completion of the auction)? If not, what other factors do you see as relevant?
a. Do you agree with the suggested eligibility criteria for access to a MSP?
b. Do you agree with the suggested core technical and usage requirement?
c. Of the three options outlined above, which is your preferred method for implementing a MSP? Why?
d. Are there better alternatives or variations on these implementation options?
e. What incentives for gaming arise under the various options, and what measures, if any, could be taken to minimise such incentives?
f. What fees or resource charges should be levied (particularly for your preferred option)?
Do you have any comments on the proposed transition plan for existing licenses in the 2.5 GHz band?
The opportunity to make this submission on this very important topic is appreciated.
A meeting could be arranged for further discussions and before any decisions are made if considered to be necessary.
Bruce Douglas (President NZART)
Mark Gooding (Councillor NZART)
NZART Administration Liaison Officer[s]
Branch 74, The Wellington VHF Group, has negotiated with an equipment manufacturer for the longterm loan of multi-channel digital transceivers and has requested frequency coordination.
Each transmission has a bandwidth of about 1.5 MHz. In accordance with the existing band plans (page 4-13 of 2000 Call Book) we have selected the centre frequencies shown in Table 2.
|Site name and antenna direction||Transmit||Receive|
|Klondyke south facing||2447 MHz||2397 MHz|
|Egmont north facing||2397 MHz||2447 MHz|
|Egmont east facing||1259 MHz||1299 MHz|
|Wharite west facing||1299 MHz||1259 MHz|
|Egmont south facing||2399 MHz||2449 MHz|
|Belmont north facing||2449 MHz||2399 MHz|
|Belmont south facing||2447 MHz||2397 MHz|
|Blue Duck north facing||2397 MHz||2447 MHz|
|Blue Duck south facing||2399 MHz||2449 MHz|
|Parnassus north facing||2449 MHz||2399 MHz|
|Parnassus south facing||1259 MHz||1299 MHz|
|Marleys Hill north facing||1299 MHz||1259 MHz|
|Marleys Hill south facing||2447 MHz||2397 MHz|
|Studholme north facing||2397 MHz||2447 MHz|
|Studholme south facing||2399 MHz||2449 MHz|
|Cargill north facing||2449 MHz||2399 MHz|
Extract from FMTAG column in May/June 2001 Break-In, Page 39.
Branch 74 Wellington VHF Group. Frequency coordination for the Digital National System in the 1.3 GHz and 2.4 GHz bands. The list of frequencies was published in March/April 2001 Break-In.
NZART expresses its thanks to the following amateurs for their contributions towards this submission:
Ted Barnes ZL2IP
Stephen Hayman ZL1TPH
Kevin Murphy ZL1UJG
Brian Ryall ZL1AVZ