14 October 2010

Manager

Operational Policy for Allocations and Licensing

Australian Communications and Media Authority

By email:

Dear Sir

Discussion Paper: Temporary trials of 3D TV and other emerging technologies

I refer to the discussion paper on temporary trials of 3D TV and other emerging technologies issued by the Australian Communications and Media Authority (ACMA). The Australian Mobile Telecommmunications Association (AMTA) has reviewed the paper with interest.

The subject matter of the discussion paper is primarily of interest to Australia’s television broadcasters, however AMTA and its mobile carrier members have a significant interest in the timely allocation of the UHF ‘digital dividend’ spectrum. Therefore AMTA wishes to briefly make the following points in response to the discussion paper.

AMTA supports the use of spectrum on a temporary basis to trial new technologies and services, subject to appropriate interference protection for existing spectrum users. AMTA’s mobile carrier members are themselves active and frequent users of the opportunities afforded under the Radiocommunications Act 1992 to trial new technologies, whether this is by means of scientific apparatus licences or within the core conditions of spectrum licences.For example, Australian mobile carriers are currently actively trialling Long Term Evolution (LTE) technology.[1]

AMTA notes the planned shut down of analogue TV services by the end of December 2013 and the Minister for Broadband, Communications and the Digital Economy, Senator Stephen Conroy’s announcement of 24 June 2010 that the digital dividend will be released as a contiguous block of spectrum in the frequency range 694 to 820 MHz inclusive. This means, as the ACMA states, that it is unlikely that Channel B will be available in any location beyond 2013.

AMTA welcomes the ACMA’s clear statement in the discussion paper regarding the planned termination of any use of Channel B for trialling 3D TV by the end of 2013. The ACMA’s statement provides additional certainty for AMTA’s members in respect of the timely availability and use of the digital dividend spectrum by mobile carriers.

AMTA submits that should Channel B be made available for the trialling of 3D TV services, the ACMA should be particularly alert to any representation by broadcasters that 3D TV will be made available permanently on Channel B. AMTA notes the joint initiative of the ACMA and the Australian Consumer and Competition Commission (ACCC) to alert consumers that vacant spectrum being used for 3DTV trials “is available only on a temporary basis”, as well as other potential trade practices concerns with marketing of 3D TV broadcasts and receivers.[2]

While 3D TV is a potentially exciting development, it should not come at the expense of future productivity gains that will be achieved when the digital dividend is used for next generation mobile broadband services such as LTE. A recent report found that the Australian economy would be boosted by up to $10 billion if at least 120Mhz of useable spectrum unlocked from the digital dividend was made available for mobile broadband use.[3]

It is AMTA’s view that any trial of 3D TV in Channel B should not continue beyond the end of 2013 as that spectrum has been earmarked for reallocation with its most likely use being for deployment of LTE services.

It is AMTA’s expectation that the ACMA will continue to reinforce that Channel B is available only temporarily for trial services.

Yours faithfully

Chris Althaus

Chief Executive Officer

[1] See, for example, Telstra Media Release, “Telstra and Nokia Siemens Networks LTE world-first trial achieves 100Mbps at 75km using 2.6GHz”; 18 June 2010; Optus media release, “Optus successfully trials LTE mobile technology with Nokia Siemens Networks in metropolitan Sydney”, 15 July 2010.

[2] ACCC and AMTA media release, “ACCC, ACMA urge consumers to be cautious when buying a 3D television to watch AFL, NRL grand finals”, 22 September 2010.

[3]