2009 Digital Dividend Scoping Paper -
NZART Comments

11 June 2009
Mr Brian Miller
Manager, Radio Spectrum Policy and Planning
Radio Spectrum Management
Ministry of Economic Development
P O Box 1473
WELLINGTON 6015

Dear Brian,

Digital Dividend Scoping Paper - NZART Comments

Thank you for the opportunity to comment on your scoping paper on the NZ Digital Dividend.

From our understanding of the current proposals, there are two New Zealand Amateur allocations that are likely to be affected by the digital dividend:

* The 6 metre (50 MHz) Amateur band; and

* The Channel 39 Amateur allocation.

As the following sections discuss, NZART:

* looks forward to New Zealand Amateurs having access to the full Region 3 allocation (50 to 54 MHz) shown in the ITU Table of Frequency Allocations; and

* would like to see their current analogue Channel 39 repeater licences replaced by similar/same frequency DTT repeater licences at the appropriate time but are willing to consider other alternatives if they meet the needs of New Zealand Amateurs.

Once again, we would like to thank you for the opportunity to comment on your Scoping Paper and we look forward to further constructive dialogue on the issues it raises.

Regards,

Don Wallace

NZART Administration Liaison Officer.

The 6 Metre (50 MHz) Amateur Band

As you will be aware, the Amateur allocation in New Zealand (51 to 53 MHz) differs from that (50 to 54 MHz) available to Amateurs elsewhere in Region 3. The two missing 1 MHz segments are currently allocated, in New Zealand specific footnotes, to:

* Channel One television (50 to 51 MHz); and

* Fixed links (53 to 54 MHz).

Our views on these two segments are given below.

Segment 1: 50 to 51 MHz

On page 4, the Scoping Paper states:

The band 50 - 51 MHz has been used for broadcasting under footnote

5.166 in the ITU Radio Regulations, and it may be appropriate to consider a new use aligned to the Table of Frequency allocations (i.e. a Primary allocation to Amateur services).

NZART strongly supports this view and notes that this segment is of particular interest to New Zealand Amateurs as it is that most often used by our colleagues overseas for international contacts.

Segment 2: 53 to 54 MHz

We understand that the following quotation from the Scoping Paper relates to this segment:

There are also other uses under the New Zealand specific Footnotes in the adjacent 51 - 54 MHz band which could be reviewed, but this is beyond the strict scope of the spectrum released by the DSO process.

As you may be aware, we have a working arrangement with the organisation that is currently allocated this segment and they have allocated a number of their frequencies to us for Amateur repeaters.

While we are keen to see the entire Region 3 allocation returned to New Zealand Amateurs, we recognise that some frequencies in the 53 to 54 MHz segment are currently used for other purposes and are happy to continue working cooperatively with the organisation to whom this segment is currently allocated.

The 6 Metre (50 MHz) Amateur Band -Summary

In our discussions you have stated that your current working assumption is that future use of VHF spectrum should be in accordance with the ITU Table of Frequency Allocations for Region 3 and not rely on New Zealand specific footnotes to the Table.

NZART supports the Ministry's intention to revert to international allocations for the 6 metre Amateur band and looks forward to New Zealand Amateurs having access to the full Region 3 allocation (50 to 54 MHz) shown in the ITU Table of Frequency Allocations.

The Channel 39 Amateur allocation

The other area that is likely to be affected by the Digital Dividend is Amateurs' use of UHF Channel 39 (614 to 622 MHz).

As you will be aware, Amateurs were granted access to channel 39¹ to compensate for the removal of the 420 to 430 MHz segment from the 70 cm Amateur band - making it possible for Amateurs to continue to operate Amateur television repeaters.

The allocation of a standard UHF television channel (rather than some other non-television allocation in the UHF area) had a significant benefit; it allowed Amateurs to use standard commercial television receivers to receive the output of their repeaters and made the signals available to the general public - encouraging others to join the Amateur ranks.

Currently there are a large number (30) of Amateur television repeaters using this allocation from sites spread throughout New Zealand. Frequencies within this band are also used by Amateurs from time to time for other purposes under rules agreed between the Ministry and NZART in August 2006.

The Scoping Paper acknowledges that Amateurs are currently making use of channel 39 and makes the following comments:

...in a digital environment it is difficult to see how multiplexed repeater transmissions might occur. Policies will be required to determine if digital licences will be required or available for Amateur purposes, and whether these should be in the VHF, UHF, or other suitable spectrum.

and

The current working assumption is that current Amateur UHF analogue television licences will be discontinued at DSO. Any further requirements might be considered in the VHF bands.

The current assumption that Amateurs are only interested in techniques associated with analogue television and will not need digital licences is incorrect. As the following illustrates, Amateurs have a need for UHF digital television spectrum, preferably close to their current licences in channel 39, if we are to continue to contribute to the developments in the areas of video, radio frequency and digital techniques.

Digital Television

Amateurs have always been at the leading edge of technology, including in the areas of video and digital techniques.

Although the current Amateur television repeaters use analogue technology (like most of the current domestic television receivers), amateurs are already experimenting with digital television transmission and intend to move to digital transmission in a similar timeframe to that for commercial services.

Multiplexing Techniques

The current assumption seems to be based on the premise that all television broadcasts will consist of multiple programmes digitally multiplexed onto a radio frequency signal whereas the digital television encoding standard chosen for New Zealand allows for both single and multiple signals per carrier.

Although the majority of Amateurs are likely to be using non-multiplexed transmission techniques, a number will also be interested in experimenting and self training in the techniques required to design, build and operate the multiplexing systems required to carry multiple programmes over a single television transmitter.

Radio Frequency Spectrum

It has been suggested that Amateurs' need to transmit television signals could be met by giving them access to a multiplexed channel hosted by a third party.

While this would allow Amateurs to further develop their skills in the video and digital areas, it would preclude them from any experimentation in the radio frequency (and multiplexing) techniques associated with the transmission of digital television signals.

UHF Television Spectrum

As noted above, the current (analogue) allocation allows Amateurs to use standard commercial television receivers to receive the output of their repeaters and makes the signals available to the general public - publicising Amateur radio and encouraging others to join the Amateur ranks.

If Amateurs were required, as per the current assumption, to move their repeater outputs to the VHF bands, a special television receiver (or some kind of up-converter) would be required, raising the cost of operating such systems² and making it extremely difficult for the general public to view Amateur television transmissions.

Nationwide Allocation

It is understood that the current assumption regarding that reallocation of spectrum is based on the idea of alternating main and secondary channels on a geographical basis³ and it has been suggested to us that it may be possible to accommodate Amateurs' spectrum requirements by allocating two secondary "half" channels on a split geographical basis.

We do not believe that such a "two half channel" allocation would work for Amateurs. As the agreed rules for the use of Channel 39 note⁴, ATV repeater sites have been chosen to dominate the surrounding area and many are suitable for contests and experimental activity.

Existing sites are therefore unlikely to be suitable for providing geographically confined coverage envisaged in the proposed "main plus secondary" system.

Spectrum near Channel 39

We note that Channel 39 is not in the area proposed for reallocation to other services in the Scoping Paper so there is no technical reason why Amateur television should not continue in the 610 to 620 MHz area.

Amateurs have made a significant investment in the 30 repeaters currently licensed on Channel 39 and in their associated aerial systems. While it is relatively easy to re-tune an

Amateur television transmitter to another (UHF⁵) frequency, it is a far more complex process to change the frequency of the aerial system to which this transmitter is connected.

Amateurs already have some experience of the effect that changing frequencies has on activity. When Amateurs were required to move from the 70 cm band to Channel 39, it took quite some time to accomplish and there was a significant drop in activity while amateurs built or adapted equipment to suit the new allocation.

For this reason, Amateurs would prefer a DTT spectrum allocation as close as possible to the current Channel 39 frequency.

The Channel 39 Amateur Allocation -Summary

For the reasons outlined above, NZART would like to see their current analogue Channel 39 repeater licences replaced by similar/same frequency DTT repeater licences at the appropriate time but are willing to consider other alternatives if they meet the needs of New Zealand Amateurs.

Footnotes

1. The original allocation was 610 to 620 MHz but this was later "regularized" to match the channel 39 allocation of 614 to 622 MHz.
2. ITU-R recommendations M1041 and M1043 both note the need to make Amateur systems available at an acceptable cost as Amateur operators must fund their own stations.
3. We understand that, by the use of modern techniques, it is possible to provide a nationwide services from a single channel, removing the need for alternating main and secondary channels.
4. See council/policies/2006-access-614-mhz-band/
5. Moving from one frequency to another within the same band can normally be accomplished by retuning, moving to another (e.g. from UHF to VHF) band would normally require replacement of the transmitter as well as the aerial system.