Digital Dividend Discussion Submission

In August of 2011, New Zealand’s Ministry of Economic Development Radio Spectrum Management group published a discussion paper entitled “Digital Dividend – Opportunities for New Zealand”. The Digital Dividend is defined as the part of the radiofrequency spectrum that is able to be freed up following the switch from analogue to digital television, however this discussion paper only considers the “700MHz band” of spectrum and its most likely repurpose for use by cellular telephone and broadband providers. I discuss the Digital Dividend in some detail in an earlier blog post.

This discussion document is part of a consultation process kicked off by the Ministry in April 2011, with an Auckland meeting of industry participants held under Chatham House Rule. A public workshop was held in September to discuss the paper, and written responses were due for submission on Friday the 7th of October. These submissions, including the one below, will be published by the MED, as the initial positions of various industry participants. Comments on submissions will then be sought in a cross-submissions period, with responses due the 9th of November.
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700MHz and The Digital Dividend

As the process to release Digital Dividend radio spectrum kicks off, media outlets have started covering the issue with enthusiasm. Computerworld, The Dominion Post, NBR, and TUANZ have all featured articles on this spectrum in the last week. There’s plenty of fodder for the news, as matters of contention are both technical and market driven.

From a technical standpoint the most likely bidders (Telecom, Vodafone, and 2Degrees Mobile) agree the spectrum should follow the APT Wireless Forum’s Region 3 Harmonized FDD Arrangement, which divides the 108 MHz available into a pair of 45MHz blocks, separated by guard bands at the bottom, middle, and top of the block. This plan assumes the use of “LTE” or Long Term Evolution technology and allows for subdivision a number of ways, into spectrum for three, four, or five national cellular carriers.
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New Zealand Radiocommunications Map

The map below plots 19,750 radiocommunications licenses across New Zealand in VHF and UHF bands. These licenses support voice and/or data communications from individual towers to multiple end users. They could be paging, data radio, radiotelephone, or cellular mobile licenses.

A number of extracts from New Zealand’s Radio Spectrum Management license database were taken in March 2011 and combined to form the underlying data set. Only public data were considered – no suppressed licenses are included. Data were normalized to common organisation names – i.e. multiple forms of the same name, or multiple organisation IDs tied to the same limited company were given a common name. Licenses were further tagged with colors to represent some unique commercial operators and operator types. Location data were transformed from NZMG to NZTM2000 – which is assumed to be near equivalent to WGS84, the standard used by Google Maps.
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Submission to the MED on the RBI Non-Discrimination Consultation Paper – March 2011

Dear Sirs,

A.) I am an independent consultant with a background in rural telecommunications and mobile co-location. In my former role as Managing Director of Araneo Limited, I co-located fixed wireless broadband access on rural towers from Kaitaia to Southland, providing wireless access to libraries, schools, farms, hospitals, power stations, and defence force installations. I have written a number of documents on rural towers and co-location based on my experiences which can be found on my blog:

B.) I would like to respond to “Question 3” of the “Response to RBI Non-Discrimination Discussion Document MARCH 2011.pdf”.

Q.3 Do you consider the proposed approach to co-location would be effective in providing fair access that will promote competition. If not, what do you consider to be the appropriate approach and why?

C.) I do not believe the approach to co-location will provide fair access that will promote competition for several reasons.
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Mobile Infrastructure Sharing / Mobile Co-Location

“Mobile infrastructure sharing is an alternative for lowering the cost of network deployment, especially in rural and less populated or marginalized areas.” (Lefevre, 2008) Infrastructure sharing can be as basic as sharing a hilltop or as complicated as sharing active network equipment. In this post, the various options available for passive infrastructure sharing will be discussed, with a focus on rural towers.

Passive Infrastructure refers to that infrastructure not directly involved in actively transmitting information. In addition to physical objects, elements such as electricity, cooling technology, and non-cellular transmission are considered passive, because management of these elements does not have an impact on the coverage or capacity of the mobile network.
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Cellular Spectrum in New Zealand

Radio Spectrum in New Zealand is allocated for a number of uses, including broadcast, narrow-band radio communications, point to point linking, and cellular, to name a few. Cellular spectrum in New Zealand is auctioned on the basis of blocks of a particular frequency range that is exclusive for the use of an operator across the entire country. These blocks are awarded on twenty year terms that appreciate the huge capital expenditure and time commitments involved in building national cellular networks.

Some carriers have dedicated an immense amount of resources to the acquisition of prime spectrum in New Zealand, while others have taken a value for money approach to acquisition. The following chart shows the amount of national spectrum licensed in megahertz (MHz), and the approximate aggregate dollar value of that spectrum (in Q3 2010 dollars), on a per-carrier basis.

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Vodafone NZ 3G Data Capabilities

Vodafone New Zealand operates cellular networks at 950/1800 and 2100MHz, with 3G data supported in the 950 and 2100MHz bands. As of December 2010, Vodafone had 2,465,000 mobile subscribers. This analysis includes only 3G capable towers and does not take into account any 2G-only towers.

As at 1 February 2011, Vodafone was licensed for 1150 towers in the 950MHz band and 877 in the 2100 band. In many cases both bands are utilized from the same tower – the total number of towers operated being 1528. At 950MHz, all towers are licensed for 15MHz channels. In the 2100MHz band, 226 towers are licensed for 5MHz, and the remainder at 15MHz. Vodafone uses HSPA+, which requires a minimum channel sizes of 5MHz, so it is likely that in most cases Vodafone are operating between one and three 5MHz cells per tower – or up to six 5MHz cells on dual-carrier towers.

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