Hong Kong October 18, 2011
The Manager
National Infrastructure, Government and Space Section
Spectrum Infrastructure Branch
Australian Communications and Media Authority
PO Box 78
Belconnen ACT 2616
Email:
Subject: ACMA discussion paper for public comment: Earth Station Siting
Dear Sir/Madam:
The Cable & Satellite Broadcasting Association of Asia (CASBAA) thanks the Australian Communications and Media Authority (ACMA) for the opportunity to comment on the discussion paper “Earth Station Siting, Guidance on the establishment of new Earth stations and other space communications facilities or the expansion of existing facilities” released in August 2011.
CASBAA is an industry-based advocacy group dedicated to the promotion of multi-channel television via cable, satellite, broadband and wireless video networks across the Asia-Pacific region. Founded in 1991, CASBAA currently represents some 130 member companies, located in 16 Asian and Australasian countries and regions, which provide television programming to over 360 million homes in Asia and Australasia. In addition to multinational television networks and programmers, member corporations also comprise leading satellite operators, suppliers and manufacturers of cable and satellite technology, related business service providers, telecom companies, and new media service providers.
CASBAA would like to make the following comments on the questions raised in the ACMA discussion paper on Earth Station Siting:
1. The ACMA seeks comment on the proposed objectives for the development of a long-term sustainable strategy for the siting of satellite Earth stations and other space communications facilities.
CASBAA comment
Point two in ACMA’s Principles for spectrum management states:
provide guidance for major planning and allocation decisions to be made over the next few years
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CASBAA agrees that it is important to provide spectrum management “over the next few years”. However, CASBAA has observed that technology often develops in unexpected ways over the longer term and that projections for technological development are frequently inaccurate; in particular, proponents of new technologies are prone to vastly overstate their development prospects and the spectrum needs resulting from developments. CASBAA notes that ACMA has recently released for broadband wireless access (WAS) the band 3575–3700 MHz. CASBAA urges ACMA to monitor the uptake of this service closely before taking any decision to extend WAS further into the C-band.
2. The ACMA seeks stakeholder comment on any additional pressures that should be considered in the context of Earth station siting.
CASBAA comment
CASBAA believes that throughput the discussion paper the ACMA is underestimating the importance of C-band to the satellite industry and to end users. C-band spectrum is important not only in Australia, but also around the world. C-band use continues to grow, and this spectrum will continue to be the “workhorse” of the satellite industry due to advances in Earth station equipment and future generations of satellites. It is important to note that what Australia does with C-band will have global implications, and in turn what Australia is able to do with C-band is strongly affected by international use of C-band spectrum.
3. The ACMA seeks comment on areas of growth in the satellite industry. Where is the biggest growth expected? Are there any emerging applications for satellite services that are expected to impact spectrum requirements?
CASBAA comment
Video consumption across all technologies is growing rapidly. Whether on traditional TVs, computers, or mobile devices, consumers are consuming vastly more television programming each year. This content reaches redistribution points by means of satellite transmissions in the C-band. CASBAA would like to point out that the reason that there is not the same growth in the C-band satellites as in other bands (e.g., Ku- and Ka-bands) is that the C-band orbit/spectrum capacity is saturated (i.e., there are no orbital slots remaining where sufficient C-band spectrum is available to accommodate a new C-band satellite). The existing C-band orbit/spectrum resource is fully utilized and the satellites are replaced as they reach their end-of-life. This saturation is an indication of the valuable Fixed-Satellite Services (FSS) provided by the C-band orbit/spectrum resource, and therefore this service deserves to continue to be protected from interference.
4. The ACMA seeks comment on the methodology used to establish a benchmark population level below which Earth station operation would be reasonably secure in the long term.
CASBAA comment
CASBAA contests the calculations used by the ACMA to determine a population benchmark. The assumptions contained in Table 2.1 of the discussion paper are prejudicial to the satellite industry and are used to justify the concept of satellite parks. CASBAA
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believes that these assumptions require review and reconsideration, in order to take into account a methodology that reflects real world factors.
Specifically, CASBAA would like to underline the following problems with the assumptions contained in Table 2.1:
(A) The assumption of 4 bps/Hz fails to take into account the fact that the broadband mobile industry expects to reach an efficiency goal of 15 bps/Hz resulting from coding advances and network architecture and antenna innovations.
(B) The Contention and Activity Ratios fail to take into account the real use of broadband by users. In fact, only 10 per cent of users are online at any instant, and only 10 per cent of those users are actively occupying bandwidth at any instant. Therefore, the figure of 10 assumed by the ACMA should be 100.
(C) No justification is provided for the assumption of 25% of a town relying on some form of wireless broadband connections. The current policy of the Australian Government is to reach 93% penetration using optical fiber, with the remaining 7% using some form of wireless technology.
An adjustment of the factors used in the methodology and assumptions contained in Table 2.1 leads to a different result, which can severely differ from the population benchmark used by the ACMA and which, as it stands, is prejudicial to the satellite industry.
5. The ACMA seeks stakeholder comment on any additional categories of tools that could be used to address the various pressures on spectrum used by the satellite and space sectors.
CASBAA comment
ACMA states that “the tools available fall into two categories—economic measures, and planning and technical measures.” CASBAA believes that smaller groups that would be denied service should be protected through policy decisions. For example, many Australians rely on C-band satellite transmissions to obtain niche television programming meeting various cultural and linguistic needs. This group should assured of continued access to cable TV programming.
6. The ACMA seeks comment on using opportunity-cost pricing of spectrum for satellite Earth station licensing based on spectrum denial caused to terrestrial services.
CASBAA comment
CASBAA is of the opinion that spectrum pricing must be balanced with a policy that protects certain services that otherwise would be much more expensive. For example, many Australians obtain television programming from pay-TV companies that obtain their signals from TVRO installations. The Australian Subscription Television and Radio Association (ASTRA) will communicate the views of the Australian pay-TV operators, but we share their deep concern that for these companies to relocate their TVRO installations to a satellite
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park would entail a major expenses associated with infrastructure relocation and the transmission and reception of international programming and ongoing operational costs. Depending on pricing decisions for spectrum, costs could be driven up to the point that Australians would lose access to some international television services.
7. The ACMA seeks information on any additional planning and technical tools that could be used to manage interference into satellite Earth stations and other space communications facilities.
No CASBAA comment
8. The ACMA seeks comment on the use of filtering in Earth receive stations and its applicability and usage in interference mitigation.
CASBAA comment
CASBAA would like to point out that the retro-fitting of filters to reduce out-of-band interference is very expensive and sometimes not possible due to the construction of the low noise amplifier (LNA).
9. The ACMA seeks comment on alternative methods of interference management should guard bands be reviewed in the future.
CASBAA comment
CASBAA would like to point out that in some situations the use of guard bands does not prevent the saturation of the LNA and subsequent loss of signal at the Earth station.
10. The ACMA seeks comment on all matters related to site interference protection.
CASBAA comment
In its discussion paper, the ACMA suggests that any new deployment of FSS Earth stations and radioastronomy or space research facilities should be located well away from population centers exceeding a threshold population of 25,000. As pointed out above, CASBAA believes that the assumptions of the population threshold are in need of review and further consideration.
11. The ACMA seeks comment on issues raised in the band-by-band analysis chapter, particularly comments on specific frequency bands. Do you agree with the analysis? Why or why not?
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CASBAA comment
CASBAA would like to offer the following comments on the bands 3600 – 4200 MHz and 5925–7075 MHz referred to in the above referenced discussion paper in Section 4.1.2:
1) As pointed out in the discussion paper these bands are allocated on a primary basis to the FSS, FS and MS. CASBAA understands that all C-band Earth stations in Australia must be licensed and are subject to coordination i.e. C-band Earth stations are not able to be deployed ubiquitously in Australia.
2) CASBAA notes that ACMA has recently released for broadband wireless access (WAS) the band 3575–3700 MHz and has developed effective coordination procedures between WAS and FSS.
3) CASBAA notes the following sentence from the discussion paper “The band 3700–4200 MHz is not currently under consideration for broadband wireless access; however, the band is suited to this application and caution is advised when establishing new stations or expanding existing ones close to populated areas.”
4) CASBAA infers that one reason for the removal of FSS Earth Stations to satellite parks would be in anticipation of assigning the band (or parts of) 3700–4200 MHz to WAS.
In view of the above CASBAA urges ACMA to refrain from implementing a policy of removal of FSS Earth stations to satellite parks in the near future but to wait until more information is available on the uptake of the broadband wireless service (WAS) in the band 3575 – 3700 MHz.
CASBAA would also like to note the following points:
1) As ASTRA has pointed out, pay-TV companies operate C-band-based TVRO systems at pay-TVhead-ends and the removal of these Earth stations to satellite parks is not feasible for economic or operational reasons.
2) In addition, many hotels receive international television broadcasts directly at their premises, for in-house distribution to meet the needs of their international visitors. It is not feasible for hotels to contemplate use of satellite parks and if they lose C-band reception it will negatively impact their business, and the Australian tourism industry. There is no functional substitute for satellite C-band distribution of international television services to multiple reception points.
3) Licenses for C-band Earth Stations have been issued over the years by ACMA according to the existing ACMA regulations; we believe that ACMA needs to take account of use of multiple TVRO dishes by licensees, and should not proceed simply on the basis of an assessment of how many licenses have been issued. It is the number of dishes in use, and not the number of licenses issued, that is the relevant data.
4) The investment in C-band satellites, reception facilities, and pay-TV head-ends represents billions of dollars by the satellite and television industries, with correspondingly large investments in transmission and receiving facilities by the providers and distributors of TV programming throughout the Asia-Pacific region including Australia. C-band satellites tend to have region-wide coverage areas.
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5) The C-band provides a truly multinational service; transmissions using the C-band are received and utilized in many different markets simultaneously. Frequency decisions by individual regulatory bodies can, however, affect the commercial viability and future maintenance of these international services, by making it impossible for the multinational broadcasts to be received in a given jurisdiction.
6) For many countries in Asia located in areas with high rain rates (including many parts of northern Australia) the C-band is often the only means of reliable communication. The removal of C-band Earth stations to satellite parks negates the advantage of satellite communications as being a point-to-multipoint communication for the important function of providing a communication link of last resort.
Again, in view of the above points CABAA urges ACMA to not implement a policy of removal of FSS Earth stations to satellite parks.
12. The ACMA seeks comment on issues raised in the site-by-site analysis. Do you agree with the analysis? Why or why not?
No CASBAA comment
13. The ACMA seeks comment on the concept of satellite parks. Do you support this concept? Why or why not?
CASBAA comment
CASBAA does not agree with the concept of satellite parks, especially when applied to narrow the scope of business for companies engaged in providing needed television services to meet the needs of millions of Australian consumers.
14. The ACMA seeks comment on the usage and effectiveness of the Mingenew Satellite Park. Are the current regulatory arrangements effective?
No CASBAA comment
15. The ACMA seeks comment on the potential to implement a band plan to provide stronger legislative protection to the Mingenew Satellite Park.
No CASBAA comment
16. The ACMA seeks comment on all issues surrounding the development and establishment of an east coast satellite park, particularly on what factors would be necessary to make it an attractive option for Earth station location.
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CASBAA comment
CASBAA believes that this question is inappropriate at this time, given that the case for satellite parks has yet to be demonstrated.
17. The ACMA seeks information on areas that may be potentially suitable for the establishment of an east coast satellite park.
CASBAA comment
CASBAA believes that this question is inappropriate at this time, given that the case for satellite parks has yet to be demonstrated.
18. The ACMA seeks comment on the concept of defining a maximum guard band width for space services—both on the technical and policy basis for the development of this option and the proposed figures of 10 MHz or one adjacent channel width, whichever is smaller. Comment is also sought on the implementation of geographic exclusion zones and the proposal for a 20 km exclusion zone for C-band Earth receive stations.