Motorola Response to:
Spectrum Licensing Technical Frameworks Review
Discussion Paper
Prepared by: Michael Hill
Motorola’s response to ACMA’s “Spectrum Licensing Technical Frameworks Review” 12/06/2009
Context
Radiocommunications are vital to Australia’s diversified and growing economy.
Radiocommunications are essential for agencies involved in the defence or national security of Australia, law enforcement or the provision of emergency services. Two-way radio also provides the communication infrastructure for a wide range of industries ranging from agriculture, mining & construction through to transportation & hospitality.
Motorola is a major supplier of radiocommunications equipment to governments, emergency services organisations, the mining industry, the energy industry, manufacturing sectors, transportation, tourism, telecommunications carriers and telecommunications service providers.
Motorola is a strong supporter of standards based technology and spectrum harmonisation with other major markets in Europe and the Americas. This support helps to ensure that up-to-date radiocommunications equipment is readily available. Use of standards based technology reduces the costs to the manufacturers and service providers, maximises competition, and results in lower costs for consumers
Motorola supports the ACMA and its requirement to fulfil the object of the Radiocommunications Act 1992.
Motorola has been a leader in the field of two way radio communications for decades, excelling in the research and development, production, marketing and efficient operation of radio communications equipment and systems all over the world. Motorola’s brand is indeed synonymous with high quality radio communication products and services. As a world-wide operation with close operator links Motorola believes that its accumulated experience qualifies it well to comment on this discussion paper.
The primary commercial interest of Motorola has been, and will continue to be, in the design, manufacture and supply of communications equipment and systems. Motorola knows that issues relating to the allocation of radio frequency spectrum impact directly on the demand for its communications products and the issues discussed here are particularly relevant.
Motorola is therefore pleased to have the opportunity to comment on what it considers to be the critical issues raised by the Australian Communications and Media Authority’s invitation to comment. Motorola especially welcomes the government’s commitment to a full consultation process.
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Motorola’s response to ACMA’s “Spectrum Licensing Technical Frameworks Review” 12/06/2009
ACMA Summary (from the discussion paper)
This paper is intended to facilitate and inform discussion on a number of issues relating to technical frameworks used for spectrum licensing. Comment is sought on the issues raised in this paper (outlined below) and any others considered relevant. Responses to this paper will be employed in any future development of detailed strategies for future spectrum licensing technical frameworks.
From its internal evaluation, ACMA has formed views on the following points:
o the current methodology that Australia employs in the development of spectrum licence technical frameworks is consistent with international framework methodologies and is appropriate for Australian requirements;
o consultation with an industry working group is the most appropriate forum for creating a technical framework;
o the current method for specifying technical conditions, known as core conditions, is appropriate for Australian requirements;
o the current method for managing interference using the s.145 determination is appropriate for Australian requirements;
o in lower frequency bands, the deployment of transmitters within 30 km of a geographic spectrum boundary is restrained by current specifications in the s.145 determination;
o the current method for managing interference using the s.262 determination is appropriate for Australian requirements; and
o the creation of future technical frameworks will require underlay and overlay technologies to be considered.
Issues for comment
ACMA welcomes industry and government comment of the discussion raised in this paper.
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Motorola’s response to ACMA’s “Spectrum Licensing Technical Frameworks Review” 12/06/2009
Motorola Response
For the most part, Motorola has had few problems with the existing processes. However there are a couple of issues that are periodically encountered. These are:
· issues, from time-to-time, with some device registrations going missing from the ACMA online database; and
· issues with the device registration process in so far as, on more than one occasion, Motorola has encountered difficulties with securing the services of an Accredited Person (AP) willing to undertake device registration works. Motorola has been advised that there is little or no detailed ACMA information or guidance that adequately describes the process for submission of a device registration.
Chapter 3 – Technical Frameworks Background
· Motorola agrees with ACMA’s view that consultation with an industry working group is the most appropriate forum for creating a technical framework
Chapter 4 – Core Conditions
· Motorola agrees with ACMA’s view that the current method for specifying technical conditions, known as core conditions, is appropriate for Australian requirements.
Chapter 5 – Device Boundary Criteria (DBC)
· Motorola agrees with the ACMA’s proposal to reduce the step size to allow more accurate modelling of DBC;
· In relation to the potential for interference across spectrum license boundaries, Motorola views the current spectrum licensees responsibilities to design non-interfering coverage or negotiate with licensees in adjacent spectrum or geographic areas as being appropriate.
Propagation modelling, especially when using “small” step sizes, can provide guidance to licensees for the selection of sites, including additional fill-in sites, antenna coverage patterns and appropriate power settings to minimise interference across spectrum boundaries.
If, after using the available design tools, interference across spectrum boundaries is predicted to remain, the licensee must negotiate with the affected licensee(s).
· As noted above, Motorola has encountered difficulties with securing the services of an AP willing to undertake device registration works. Motorola has been advised that there is little or no detailed ACMA information or guidance that adequately describes the process for submission of a device registration. Motorola believes that ACMA should discuss with the AP community the requirements and difficulties associated with device registration so that the process can be improved.
Chapter 6 – Advisory Guidelines
· Motorola believes that the ACMA’s provision of Advisory Guidelines is appropriate for Australian requirements.
Chapter 7 – Future Considerations
· Motorola notes that the introduction of spectrum sharing technologies such as DySpAN and UWB technologies will cause interference to primary spectrum users in some scenarios. The expected level of interference, the expected frequency of interference and the expected duration of interference between the primary and secondary users of the spectrum will determine the viability of introducing the secondary technology. Service area geography and the criticality of the technology user’s operational requirements will also contribute to the viability debate.
Motorola believes that ACMA should continue to monitor the development and international deployment of these technologies.
In conclusion, Motorola believes that the basic structure of the Spectrum Licensing Technical Frameworks is sound and that some fine-tuning of the processes and documentation should be considered.
End of responses.
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