Australian Communications and Media Authority

9 December, 2016

The Manager

Spectrum PlanningSection

PO Box 78

BELCONNEN ACT 2616

COMMENTS ON IFC 25/2016

FUTURE USE OF THE 1.5 GHz AND 3.6 GHz BANDS

DB Telecommunications Pty Ltd is pleased to be able to offer comment on the future use of the 1.5 GHz and 3.6 GHz bands.

The comments in this submission are limited to the 3.6 GHz band.

As an ACMA Accredited Person, David Britt of DB Telecommunications has performed a significant number of assignments for 3.6 GHz BWA services in Tasmania and remote parts of Western Australia. This has provided DB Telecommunications with a good insight into the demand for 3.6 GHz services in these regions and the issues confronting potential users of the band.

To assist the ACMA in conducting a comprehensive assessment of the highest-value use for the 3.6 GHz band, responses to the following questions are requested:

Do you see increasing demand for fixed broadband/MBB services in the 3.6 GHz band? What benefits do you envision from using the band for fixed broadband/MBB services?

Over the past 5 years DB Telecommunications has seen increasing demand for 3.6 GHz spectrum from fixed wireless broadband service providers, typically targeting SME size commercial customers, as opposed to the residential market. Tasmania is one such area of strong demand.

There has also been increasing demand for 3.6 GHz spectrum for segments of the mining industry in remote parts of WA and presumably other remote parts of Australia. These services tend to be used by small to medium size mines, with the larger miners trending towards the use of private LTE.

Another emergency service client of DB Telecommunications uses 3.6 GHz BWA services to extend its corporate intranet services to some of its volunteer staffed fire stations. Given the somewhat intermittent manning of these stations, provision of intranet services to these sites would not be cost effective using tradition wireline or fixed wireless services.

One of the most attractive features of the 3.6 GHz band for the provision of fixed wireless broadband services is the availability of relatively low cost, reliable, high performance equipment from manufacturers such as Ubiqity and Cambium. The low cost and relatively small size has assisted these wireless operators to contain their equipment and site infrastructure costs in this highly competitive market which is now facing further cost pressures from the emerging NBN.

The PMP nature of the 3.6 GHz BWA services provides greater flexibility for the addition of new customers at relatively low cost, compared to fixed point to point infrastructure.

Which regions of Australia will be in demand for fixed broadband/MBB services in the 3.6 GHz band?

With the reach of the NBN continuing to extend in the more populated areas, demand for fixed broadband/MBB services is likely to remain greatest in regional parts of Australia and smaller states like Tasmania.

Indeed demand for 3.6GHz spectrum in most parts of Tasmania outstrips the supply, with the limited number of channels having been licensed by a relatively small number of organisations. In recent times this has made it impossible for potential new entrants to the market to gain even a single 10MHz channel in Hobart, Launceston and Devonport due to the 30 km co-channel re-use distance constraints of RALI FX19.

There definitely seems to be a need for additional 3.6 GHz band spectrum or access to 3.4 GHz spectrum in these areas.

Is demand the same or similar across regions, or are some regions/areas more likely to be in demand for MBB providers?

DB Telecommunications believes one of the greatest areas of demand for fixed broadband/MBB could be in the capital cities such as Melbourne, Sydney, and Brisbane etc.

Due to the current embargo 42 which applies to the 3.6 GHz band and spectrum licensing in the 3.4 GHz band, there is very little spectrum available for fixed broadband/MBB in these capital cities. Most SME fixed wireless broadband operators in these areas are forced to use class licensed 5.8 GHz spectrum. Due to the largely unregulated nature of this band, interference is rising and many wireless network operators are struggling to maintain quality of service standards.

Many such organisations have approached DB Telecommunications to explore licensed spectrum options for the provision of fixed wireless broadband services. Many have explored the use of the fixed microwave services bands but have found the relatively high cost of microwave equipment and spectrum generally presented a significant barrier to entry.

Access the 3.4 or 3.6 GHz spectrum at reasonable cost would definitely be welcomed by SME fixed wireless broadband service providers.

Do incumbent 3.6 GHz band licensees require ongoing access to the band, or are there plans to cease operation at some future point?

DB Telecommunications believes that most of its 3.6 GHz BWA licence clients would hope to have ongoing access to the 3.6 GHz band in order to continue to grow their fixed wireless service businesses. Being able to access additional spectrum at reasonable cost would be the key to that objective.

Do other options exist for the delivery of fixed, fixed-satellite and amateur incumbent services, how practical are they? What are the costs involved? Will there be a diminution of the service delivered if MBB services are introduced in the band?

DB Telecommunications has no specific comments on this issue.

Should further consideration be given to the migration of incumbent 3.6 GHz band FSS earth stations to low density population areas?

DB Telecommunications believes that it would desirable to relocate FSS earth stations to low density population areas both from the perspective of minimising interference to FSS earth stations and to avoid imposing unnecessary limitations on the geographic areas where 3.6 GHz BWA services can be deployed.

RELATED ISSUES

RALI FX19

When RALI FX19 was first developed there was a 30 MHz limit on the spectrum that a single licensee could operate in the same area in the3.6 GHz band. That limit was abolished in the August 2011 revision.

DB Telecommunications has done quite a few 3.6 GHz BWA assignments in Tasmania over the past couple of years and has noticed that the relaxation of the assignment limits has allowed a small number of licensees to acquire a significant proportion of the available bandwidth in the major cities of Hobart,Launceston, Devonport and Burnie. This is making it hard for any new players to acquire any bandwidth in those areas, given the current 30 km co-channel re-use restriction for spectrum operated for different licensees.

For example, near Devonport two licensees have 110 MHz of the 120 MHz of bandwidth in the band, with the larger of the two licensees having 80 MHz. There is clearly a need for 3.6 GHz spectrum in these areas to allow other operators to enter the market.

Even if additional 3.6 GHz spectrum is able to be provided to support fixed broadband/MBB services, DB Telecommunications would urge the ACMA to look at re-introducing an assignment limit in the 3.6 GHz BWA band to try and provide reasonable access to the band for intending new participants.

EMBARGO 42

The scope of Embargo 42 was recently changed to restrict any new assignments in the frequency range 3575 – 3710, including assignments for existing licensees seeking to expand or modify their existing networks.

DB Telecommunications attended the Comms Connect Conference in Melbourne shortly after the embargo changes were announced and it is fair to say that the changes were not well received by industry along with the lack of notice of the proposed changes.

The latest changes to Embargo 42 seem to unfairly restrict SME fixed wireless operators from operating and expanding their businesses, given that these types of reviews rarely run to schedule and can go on for years.

DB Telecommunications would recommend that the ACMA give strong consideration to modifying Embargo 42 along the lines of Embargo 64 which applies to the 900 MHz band.

Embargo 64 allows for some expansion of existing networks, providing that the licensee acknowledges that the band is under review and the licensee may need to relocate of cease operations in the future.

It has been DB Telecommunications’ experience that the provisions of Embargo 64 have worked fairly well for incumbent licensees.

DB Telecommunications apologises for the brevity of this submission, but it is an extremely busy time for APs leaving only limited time to prepare a submission.If you would like additional information or wish to discuss any aspect of my submission, please do not hesitate to contact me on (03) 9331 3170 or by email .

Yours sincerely,

David Britt

Director