IFC49/2012 - Submission by Syntec International

Submission in Response to

IFC 49/2012

Proposed Variation to the Radiocommunications

(Low Interference Potential Devices) Class Licence 2000

February 4, 2013

The Manager

Spectrum Engineering and Space

Australian Communications and Media Authority

P.O. Box 78

Belconnen ACT 2616

Dear Madam/Sir,

Re: IFC 49/2012

Proposed Variation to the Radio communications (LIPD) Class Licence 2000

Syntec International Pty Limited appreciates the opportunity to submit our comments on the proposed variations to the Radio communications (Low Interference Potential Devices) Class Licence 2000.

Introduction:

Syntec International Pty Limited (Syntec) was established in Australia over 40 years ago to import and distribute equipment for professional audio users. Our customers include the whole spectrum of people and businesses who use audio equipment in their activities; from a local primary school and church to radio and television stations, emergency services, every government department, radio and TV program producers, film producers, performing entertainers at every level, entertainment venues from clubs and pubs to The Sydney Opera House.

For more than 25 years we have been the exclusive Australian importer and distributor for the German company Sennheiser. Sennheiser manufactures a range of wireless audio systems (wireless microphones and In Ear Monitoring systems) that are widely appreciated for the quality of their manufacture, and their performance, especially in demanding applications. Sennheiser has been manufacturing and successfully selling Wireless Microphone and In Ear Monitor systems for professional use continuously, ever since the initial development of such devices in the 1950’s. Their complete range of wireless audio products currently operates under the LIPD Class 2000 licence.

During the Olympic Games in Sydney in 2000, Syntec, working with Sennheiser, was responsible for the frequency planning and co-ordination of all the frequencies for more than 700 wireless audio systems being used by journalists from all over the world who were reporting the Games. We worked very closely with the then ACA on this project.

The Sennheiser Group, with its headquarters in Wedemark near Hanover, Germany, is one of the world’s leading manufacturers of microphones, headphones and wireless transmission systems. The family-owned company, which was established in 1945, recorded sales of around €531 million euros in 2011. Sennheiser employs more than 2,100 people worldwide, and has manufacturing plants in Germany, Ireland and the USA.

The company is represented worldwide by subsidiaries in France, Great Britain, Belgium, the Netherlands, Germany, Denmark (Nordic), Russia, Hong Kong, India, Singapore, Japan, China, Canada, Mexico and the USA, as well as by long-term trading partners in many other countries. Also part of the Sennheiser Group are Georg Neumann GmbH, Berlin (studio microphones and monitor loudspeakers), and the joint venture Sennheiser Communications A/S (headsets for PCs, offices and call centres).

You can find all the latest information on Sennheiser by visiting their website at www.sennheiser.com.

General Comments:

Syntec generally supports the changes that have been outlined in the Discussion Paper.

These proposed changes also bring an opportunity to make some other changes to this Class Licence.

These changes need to address the way in which these products can be operated in an environment where there is much less spectrum available, and also need to address the changes in technology (with the advent of digital techniques in these wireless audio devices) and the ability of modern technologies to share spectrum more robustly.

We have included some comments

· regarding the lack of spectrum available after the DTV Restack and the effect this will have on major users of Wireless Microphone and In Ear Monitor Systems

· regarding the potential to make spectrum available for Wireless Microphone and In Ear Monitor Systems in the L Band at 1500 MHz

· regarding the ability to operate Wireless Microphone and In Ear Monitor Systems during the Commonwealth Games on the Gold Coast in 2018

· regarding the need to immediately stop the importation of Wireless Microphone and In Ear Monitor Systems which do not meet the requirements of the revised Item 22A as applicable from January 2015 and the proposed Items 22B and 22C.

Amendment to 22A:

Syntec understands the reasons to exclude the operation of LIPDs from frequencies within the Digital Dividend (694 – 820 MHz), and broadly supports this position.

· Point 1

o We would request that the ACMA consider permitting operation of LIPDs in the Digital Dividend’s Mid Band Gap (742 – 752 MHz) and also in the Guard Bands at either end of the Digital Dividend. Such operation would have to be on condition that it did not cause interference with the licenced operators of the active Digital Dividend frequencies and/or services.

o Operation in the Mid Band Gap and in the Guard Bands may allow existing small scale users to continue to operate their equipment in a licenced environment.

o Because there are users in the market who currently own equipment which could operate in these areas of spectrum, it would be helpful if this condition was included in this revision of the LIPD Class Licence 2000, rather than excluding it now and then re-introducing it at a later date.

o We do understand that there may be challenges educating the market effectively with such a small level of detail.

· Point 2

o We note that Point 2 of the revised Item 22A still specifies a maximum bandwidth of 330 KHz for an emission. With the new technologies that are available, and regulatory specifications such as EN 300-422, we submit that an occupied bandwidth of 200 KHz, as measured by techniques in EN 300-422, could be one means of helping to permit the operation of more channels in the limited spectrum that will be available after the DTV restack.

· Point 3

o With the severely limited bandwidth available for wireless microphones and In Ear Monitor Systems after the DTV restack, we ask that the ACMA consider ways to allow for co-channel operation with licenced broadcast transmitters under certain circumstances.

o These types of events often use more than 50 channels of wireless audio for microphones and in ear monitors.

o The reduced bandwidth available for the DTV stations and wireless audio systems to share, and the block approach taken to the DTV restack, mean that it will be practically impossible to support large scale wireless audio system operation in the major urban and suburban areas across the country unless there is some relaxation of this particular point in the LIPD Class Licence. This is because there will be multiple DTV Channel Blocks licenced for many of these areas, thereby precluding the use of wireless audio systems in these locations unless some changes are made to the conditions surrounding the LIPD Class Licence 2000.

o One of the largest challenges an operator faces when planning wireless frequencies for a major production is the generation of intermodulation products. Until now, it has been possible to operate with groups of frequencies spread across the UHF spectrum between 520 MHz and 820 MHz, in the gaps between the broadcasting stations. The block planning approach that has been taken for the DTV Restavck, and the planning of multiple DTV blocks in major population areas, has taken away the ability to plan for multiple channel operation in this way. It is not possible to run as many channels in one block of 20 MHz, for example, as it is in two blocks of 10 MHz which are 20MHz apart.

o We suggest that a provision in the LIPD Class Licence 2000 be made to allow the use by wireless audio systems on frequencies licenced in that area for DTV operation, on the condition that the wireless audio systems are only used indoors in a venue which has significant RF shielding. Such venues are usually not receiving any DTV transmissions via antennae inside the venue, more likely relying on reception via a subscription TV operator or a TV antenna outside the building with a distribution system to deliver the RF signal to the TV receiver.

· Point 4

o This point specifies that the maximum signal level generated by a wireless microphone or In Ear Monitor transmitter should be less than 30dBuV/m at the boundary of a licenced broadcaster on the same frequency. We note that this level of 30 dBuV/m is carried on from the previous LIPD Class Licence specification. Given that the existing specification would probably have been formulated based on a landscape of analogue TV receivers, we would question whether this figure is still relevant in an age of digital TV receivers, with far more robust performance against interference.

o We ask that the ACMA make a formal study to identify the effects of interference from wireless microphone transmitters and In Ear Monitor systems (using both analogue and digital modulation) on the reception of modern Digital TV receivers. The results of such a study could then be used to revise the specification of this point if that was found to be necessary.

· Point 5

o We agree with the specification, at Point 5 of the revised Item 22A, that a spacing of 400 KHz remain between the centre frequency of the wireless microphone or In Ear Monitor system and a licenced broadcasting station on an adjacent channel.

o We do note though, that because of the block planning approach taken for the DTV Restack that in practical terms this will only be relevant at either end of a block rather than at the ends of an individual adjacent channel.

New Item 22B:

Syntec supports the addition of digital modulation techniques to the LIPD Class Licence 2000.

There are a number of systems readily available in the market from a number of manufacturers, right across the performance and price spectrum, from $500 per channel to $10,000 + per channel. Digital modulation techniques will become much more common in the future, so it is very important that they are supported under this licence.

We note that New Item 22B appears to be the revised Item 22A, with the reference to frequency modulation omitted. Might it be simpler to modify the newly proposed Item 22A to remove the reference to frequency modulation? This would allow the new Item 22A to cover the change in allowable frequency of operation and digital modulation within the one Item.

Syntec also suggests that this Item also allow for digitally modulated devices operating in the band from 1785 MHz to 1800 MHz.

· Point 1

o We note that Point 1 of the new Item 22B specifies a maximum bandwidth of 330 KHz for an emission. With the new technologies that are available, and regulatory specifications such as EN 300-422, we submit that an occupied bandwidth of 200 KHz, as measured by techniques in EN 300-422, could be one means of helping to permit the operation of more channels in the limited spectrum that will be available after the DTV restack.

· Point 2

o The effects of the DTV restack will especially affect the wireless audio systems used for major entertainment productions such as musical theatre, opera, music performers, some sporting events and the production of television programmes. These types of events often use more than 50 channels of wireless audio for microphones and in ear monitors.

o One of the largest challenges an operator faces when planning wireless frequencies for a major production is the generation of intermodulation products. Until now, it has been possible to operate with groups of frequencies spread across the UHF spectrum between 520 MHz and 820 MHz, in the gaps between the broadcasting stations. The block planning approach that has been taken, and the planning of multiple DTV blocks in major population areas, has taken away the ability to plan for multiple channel operation in this way. It is not possible to run as many channels in one block of 20 MHz, for example, as it is in two blocks of 10 MHz which are 20MHz apart.

We offer two suggestions for a way that this provision might be administered:

1:- To draft the text of the Revised LIPD Class Licence 2000 so that the operator of the wireless audio system must make certain that their RF emissions are not able to cause interference to licenced DTV transmissions outside the venue. This could be approached by specifying a power level that must not be exceeded outside the building, in a similar way to Item 38A (for example) in the existing LIPD Class Licence 2000. It may be that particular venues make tests outside their building while

wireless audio systems are operating inside, and document the results of those tests and keep them on file for future reference if required.