30 September 2009
Mr Brian Miller Manager, Radio Spectrum Policy and Planning
Radio Spectrum Management
Ministry of Economic Development
P O Box 1473
Thank you for the opportunity to comment on your Digital Futures Discussion Document of August 2009.
As noted in our previous submission, the 6 Metre (50 MHz) allocation for amateurs in New Zealand differs from that available to amateurs in the rest of the world. Most amateurs in Regions 2 and 3 have exclusive primary access to the band 50 to 54 MHz whereas NZ amateurs currently have:
* extremely restricted access to 50 to 51 MHz (by special contractual permit, and only in certain geographical areas);
* effectively (by the Amateur GURL) secondary access to 51 to 53 MHz (which is allocated, on a primary basis, to fixed and mobile services); and
* no formal access to 53 to 54 MHz (which is allocated to fixed and mobile services). These non-standard allocations were put in place by NZ-specific footnotes 5.166 and 5.170 to the International Radio Regulations.
Our view is that the proposal made in your previous scoping paper is the correct one:
...that future use of VHF spectrum released by the DSO process would be in accordance with the ITU Table of Frequency Allocations for Region 3 and not rely on New Zealand footnotes to the Table.
We believe that:
* the proposal made in your previous scoping paper should be followed,
* footnotes 5.166 and 5.170 should be deleted; and
* New Zealand Amateurs, like their colleagues in other parts of Regions 2 and 3, should have exclusive primary access to the frequency range 50 to 54 MHz. We understand the needs that other parties have for VHF spectrum for their fixed and mobile services but believe that these links would be much better placed in spectrum outside the internationally standardised amateur bands.
In answer to the specific questions in your Discussion Document:
Do you agree with licensing Amateur radio use in the 50-51 MHz band on a sole Primary basis?
NZART agrees with this proposal.
Do you agree with licensing Amateur radio use in the 51-54 MHz band on a shared basis with Fixed and Mobile services?
* disagrees with this proposal;
* recommends that this spectrum should, in accordance with the ITU Table of Frequency Allocations for Region 3, be allocated to Amateurs on an exclusive primary basis;
* proposes that, in the national interest, local arrangements be made with the current Fixed and Mobile users for their use of 51 -54 MHz on secondary basis until other arrangements can be made.
NZART has no view to express on these questions.
NZART understands the reasoning used in arriving at the proposal to use the n + 2 basis for licensing of digital television but believes that single frequency networking would provide a more spectrum-efficient solution for New Zealand and suggests that that option should be pursued.
NZART has no view to express on these questions.
We were very disappointed to see that the discussion paper is proposing, with little justification, to remove our existing amateur television spectrum allocation and to not offer any suitable alternative spectrum.
UHF television spectrum was made available to NZ Amateurs to compensate them for the removal of the 420 - 430 MHz portion of the (then) 420 to 450 MHz amateur band. There is extensive and increasing use of this "Amateur Television" allocation.
As noted in our previous submission on this topic, NZART would like to see all current analogue Channel 39 repeater licences replaced by similar/same frequency DTT repeater licences at the appropriate time but are willing to consider other suitable alternatives if they meet the needs of New Zealand Amateurs.
We are not asking for more, we are not seeking change, we are just seeking a continuation of the earlier-arranged and existing "compensation swap": 8 MHz in the UHF TV band for 10 MHz at 420-430 MHz.
In answer to the specific question in your Discussion Document:
Do you agree with the proposal not to provide for Amateur television services in the UHF band? Please give reasons for your view.
NZART strongly disagrees with this proposal. Our detailed reasons for this view are given in the attached document.
NZART has no view to express on these questions.
Once again, we would like to thank you for the opportunity to comment on your Discussion Document and we look forward to further constructive dialogue on Digital Futures. Regards,
NZART Administration Liaison Officer.
The arrangement commenced with New Zealand Amateurs receiving access to 10 MHz of UHF television spectrum as compensation for the loss of the lower 10 MHz of the (then) 420 to 450 MHz amateur band. The Crown wished to allocate 420-430 MHz, for single channel fixed channel link systems and, at that time, it was not considered feasible for amateurs and fixed links to share.
The original allocation was 10 MHz (610-620 MHz). This was formalised at the World Administrative Radio Conference in 1979 (WARC-79)1 at which a new footnote to the Table in Article 5 of the ITU RRs was created which entrenched secondary access for NZ amateurs to 610 -620 MHz.
Access to the band 610 -620 MHz became available to NZ amateurs in the early 1980's when access to the 420 -430 MHz band was removed.
With the introduction of the European Channel numbering for UHF TV in NZ, the 10 MHz allocation was reduced to 8 MHz and "regularised" by shifting it slightly (to 614 to 622 MHz) to match the Channel 39 television allocation2.
More recently, as part of a simplification and "tidying-up" of the RRs by administrations, the New Zealand footnote providing access for radio amateurs to the UHF television band was deleted from the RRs. When this deletion occurred, an assurance was given to NZART that the authorised access would continue as a local arrangement and the 614-622 MHz band remained, first in the Schedule in the NZ Radio Regulations, and later in the Amateur GURL as an amateur radio band and for any transmission mode as decided by the user. About two years ago, the 614-622 MHz band was removed from the GURL and today some 30 valid licences are held for this band by NZART and provide access for both amateur television and non-television operation.
Yes! There are currently 30 Amateur Television repeater licenses for this channel. These repeaters are spread across the country3 from Whangarei in the north to Dunedin in the south. These repeaters, and their associated aerial arrays, have been constructed by volunteers using their own resources and the value of this asset is conservatively estimated at well over $150,000.
1 The proposal for this replacement allocation is clearly recorded in "The New Zealand Delegation Brief" for the "World Administrative Radio Conference, Geneva, 1979". Volume Three, page 524 states that the allocation was: "...required to compensate N.Z. amateurs for loss of 420 -430 MHz".
2 No modification was made to the figures in the footnote in the ITU RRs and the original footnote remained with the new figures considered to be a local New Zealand arrangement as the ITU RRs permit.
3 See Appendix One for a complete listing of Amateur Television Repeaters
There is also use of the band by individual amateurs on an ad-hoc basis for television and other transmissions. The conditions for such use are stated in a recent document agreed between RSM and NZART entitled "Operating on the 614 - 622 MHz band -Conditions for access".
Yes. Amateurs have always been at the leading edge of technology4, including in the areas of video and digital techniques.
As examples, amateurs in Auckland are already experimenting with digital television (albeit in another amateur allocation) and in Christchurch the local amateur TV community has stated that they are ready to meet the challenge of converting their local ATV repeater (which has been operating for many years and it can be received throughout Christchurch) to digital technology if they can get assurance that they will not lose access to suitable spectrum.
Amateurs also recognise the need to move to digital transmission for compatibility with commercial digital television transmissions.
There is, however, a much more important reason for moving to digital; to encourage self training in the techniques associated with digital television. A modern economy needs people skilled in information and communications technologies (ICT) to survive and thrive.
Amateur radio allows and encourages people in New Zealand who are interested in computer, radio and television technologies to meet others with similar interests, exchange ideas, and often leads to people choosing a career in these technologies.
No. 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 as it would allow Amateurs to further develop their skills in the video and digital areas.
While this is true, it would not allow Amateurs to experiment in the radio frequency and multiplexing techniques associated with the transmission of digital television signals and would therefore prevent amateurs developing skills (and, potentially, careers) in these important areas.
We also believe that owners of these multiplex systems are likely to want to impose conditions on Amateurs, such as restrictions on content, content throughput limits, charges, etc. which would make such a proposal impractical.
4 It must be remembered that most of the spectrum used today was originally given to Amateurs as the commercial users thought anything above LF was of no use. It was only after the Amateurs showed how useful this spectrum was that commercial users became interested.
Amateurs need access to a UHF Television Channel for two inter-related reasons:
* the majority of modern digital television sets only receive UHF channels; and
* it allows members of the public to continue to receive amateur transmissions. If, for example, amateurs were given access to one of the old VHF television channels, it would require re-engineering5 of the current repeater network. It would also require every amateur television receiver to be fitted with additional equipment6 to convert the VHF signals into a form suitable for the (UHF) digital television receiver. This would have the effect of
* discouraging amateurs from getting involved in the television area; and
* make it virtually impossible for all but the most dedicated non-amateur to receive amateur television transmissions. NZ needs science, technology & engineering to be seen & demonstrated especially to younger people. Amateur television is a very powerful medium for this and is being used in at least one high school in the Motueka area (with others to follow) to encourage young people to choose a career in the technology field.
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 (UHF) frequency, it is a far more complex and expensive7 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 420-430 MHz 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, if there must be a change, Amateurs would prefer a complete DTT spectrum allocation as close as possible to the current Channel 39.
For the reasons outlined above, NZART would like to see all 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 the alternatives meet the needs of New Zealand Amateurs.
5 Moving from one band to another (e.g. from UHF to VHF) would normally require replacement of the transmitter as well as the aerial system. The estimated cost of re-engineering the current repeater network is at well over $150,000
6 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.
7 The cost of changing frequency within the UHF band is estimated at over $100,000.
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