Pay Per Dish..Comreg introduce a Dish Tax of €0.50 a year

spongebob

You may wish to read page numbered 17 of the List of Charges Here first. 300k PDF

They also intend to tap Sky for 0.2% of Turnover in Ireland as well as the Dish Tax , see pages numbered 13 and 14 . This is for spectrum use....of course.

The consultation period is EXTREMELY Short, answers must be sent to the Comreg questions by Wednesday the 23/07/03 according to the front page.



M

Capt'n Midnight

€1,905 per MHz effectively rules out any community usage of the frequency since ~10 - 20MHz is needed for each channel. (Data or Picture)

I fear that is another of the stealth taxes and worry what they will target next.
(ATM Reciepts that could be solved by getting the banks to empty the containers or make them bigger or sponsoring a bin nearby.)

5.8GHz is free to use but registration is needed....
Will they try to tax satellite uplinks - will they now tax other data transmitters ??

Lots of questions - If I use a dish for data ??? - Can I say I watch SKY news FTA so they have to pay 50c - What if have two dishes (one with three LNB's) ....

Any charges imposed on broadcsters will be passed straight on
to the consumer...

I like the bit about not collecting amounts less than €1,000
methinks it might be interesting to have a 3.5GHz device using a 500MHz bandwidth (unfortunatly it don't work that way...)

spongebob

Originally posted by Capt'n Midnight
€1,905 per MHz effectively rules out any community usage of the frequency since ~10 - 20MHz is needed for each channel. (Data or Picture)

Lots of questions - If I use a dish for data ??? - Can I say I watch SKY news FTA so they have to pay 50c - What if have two dishes (one with three LNB's) ....

Any charges imposed on broadcsters will be passed straight on
to the consumer...

I like the bit about not collecting amounts less than €1,000
methinks it might be interesting to have a 3.5GHz device using a 500MHz bandwidth (unfortunatly it don't work that way...)

€1,905 per MHz is a national rate . What if you covered an area with 10000 people , thats 2.5% of the population

Therefore you would get 40Mhz for €1,905 a year. I think channels can be smaller too but all that is for another forum ....../me winks at the Captain knowingly here.

M

Lennoxschips

I assume the BBC will tell them to go get stuffed?

sceptre

Originally posted by Lennoxschips
I assume the BBC will tell them to go get stuffed?

I may be reading the document incorrectly (and doubtless Muck will tell me if I am) but the "voluntary" (hehe) charge will only kick in if individual satellite TV providers licensed in other jurisdictions want equal protection with Irish licensed services for protecting the spectrum they're using. The BBC don't care about Ireland for a start - in this case when they say we're getting the thing for free by accident they mean it. It's Sky they're talking about.

(though in effect, with pay channels running on Astra 2D as well the distinction is little of a muchness)

watty

It's Sky that pays any money, or indeed theortically BBC Prime, ABSat, Canal+ based on number of subscribers in Ireland.

Not based on number of LNBs or Dishes I have.

For Terrestrial Free To Air they want €100 per transmitter.

For Satellite FTA they aren't looking for anything as they wouldn't get it!

spongebob

the BBC turnover is not generated here in Ireland, it is a subvention from the UK licence fee and lots of wonga for exporting programs again paid in the UK
The BBC would therefore be exempt from turnover based payments save for BBC Prime subs as Watty pointed out. Nor do they supply branded receivers (yet?) or offer installation contracts.

Sky has a lot of turnover here and won't even pay VAT to the exchequer....and it does squat 'our' spectrum. If Sky feels it has no obligations to us then we may have to consider gthe compulsory (pilot scheme) licencing of every taxi in Ireland for Skangerintheback Cams with high output limits ....say 20w each.....and make it obligatory for the Taxi to broadcast the Skangerintheback live stream every evening after 6 and all day saturday and sunday. Then make sure that every time there is a premiership match on and yo uin the pub, you order a cab with a Skangerintheback Cam from the pub. You will probably be able tp guess when it arrives , actually that would be a feature not a bug. Take your time finishing the pint...in the national interest.

Naturally this would a pilot shceme to reduce insurance costs, the fact that they are using SKY spectrum around 11Ghz or whatever would be purely co-incidental.

M

BigEejit

heh ... skangerintheback cam .. I'd say there should be skangerinthedrivingseat cams as well ...

But seriously, if Sky did give the two fingers to comreg, would comreg even consider flooding that frequency with noise? (or skangerintheback cams)?

watty

Background:
Highly commended for project on Digital TV communication by Laser in 1971 "Young Scientist"
Licenced UK Radio Amatuer since 1971
Fully certified as BBC Communications Engineer in 1978
Former Consultant to Clare / Kerry based Deflector groups
Consultant and then R&D manager to former Swiss/US/Israeli Wireless/Information Technology Startup, "IIS" 1986..1990


Response
Q1: Yes
Q2: Not as proposed
Q3: Not as proposed
Q4: Not as proposed
Q5: Not as proposed
Q6: Not as proposed
Q7: Not relevent

Explaination of response.

Satellite:
Spectrum is not allocated nationally. An operator in Italy, France or Luxembourg can illuminate Irish homes and /or sell subscriptions to Irish customers.
Apart from Sky package, ABSat and BBC Enterprises (BBC Prime) sell direct to Ireland. Other legal viewing cards are available though in some cases the operator is not either advertising the fact they will sell to Irish customer or prefers not to. The EU recognises availablity of cross-national subscription as an effective method of reduing demand for pirate viewing cards.

There is no viable mechanisim to police, regulate or charge operators not based in Ireland any Satellite Free to Air transmission.

If an Irish based subscriber is involved then a contract to sell a product in Ireland exists (This may not involve EU or Irish Citizens, for example a Swiss citizen in Ireland can purchase a Swiss viewing card. In practice the broadcaster does not verify the applicant *IS* Swiss!). If TPS, ABSat, Canal+ etc sell to anyone in Ireland, by EU law they must sell to any EU citizen in Ireland. Of course they can elect to sell to no-one in Ireland.

Sky is the overwelming main operator selling to Ireland. I make the point that technically any Satellite operator could sell packages here and some others openly do so (SCT, ABSat, BBC Enterprises).

Note that the Sky Digibox ONLY works for Sky pay package and non-Sky Receivers with a CAM slot can use *ANY* pay provider other than SKY. This is not part of the current Comreg document's scope but a serious competiton issue.

Problem with a "per Dish" based subscriber charge:
A regular quad LNB on one dish can feed four separate Digiboxes owned by four different house partners. Any, all or none could have Sky subscriptions.

An apartment block or Hotel can have a "communal" system LNB on a single dish. Four coax cables feed all the flats and each flat has an adaptor that mimics a regular LNB to a Sky+ or Digibox. Any number of subscribers are possible.

Unlike cable a Digibox is owned by the viewer from day one of install. Despite Sky's claim to Irish customers cancelling ("You will only receive terrestrial channels") a Digibox with no subscription receives over 90 TV and over 50 Radio from 28.2E. A viewer can realign the dish for 19E or 13E and pick up a proprotion of FTA channels compatible with a Digibox. A single dish can have 3 LNBs for 28E, 19E and 13E and a Digibox with manual LNB switch or non-Digibox receiver can automatically switch to over 600TV and 500Radio Free to air.

It is SUBSCRIPTIONS in Ireland from ANY Satellite operator that should be counted and charged 0.50 Euro each, not dishes as counting dishes does not indicate how many use the dish or what purpose it is used for.

Operators should have to be licenced to sell in Ireland so that there is consumer protection (e.g. Sky's proven Psycholigical warfare against cancelling subscribers and misinformation regarding operation of the Digibox with no subscription. SCT or ABSat may have elements in their package that would otherwise never be allowed to be transmitted to Irish viewers).



Terrestrial:
Arguement against Simple charge for spectrum and charge per transmitter.

There should be NO charge per transmitter as in the long run this will be a dis-incentive to install "relays" for small communities. The same applies to Mobile phones etc. The more transmitters there are the better the service and lower the power (If there is a health risk, ironically more masts = safer)

Unlike Satellite spectrum in Ireland, Terrestrial use of spectrum is reusable.
It is *MORE* reusable
* The higher the frequency
* The lower the power
* The more directional the Antenna (Colinear Omnidirectional versus high gain dish)

An equitable principle (For RTE, Deflector operators, DTT, MMDS etc ) would thus be a formula:
( ERP) x (360 / beam angle) x (k/Frequency) x Bandwidth Megahertz x M x ASL

Since range is inverse square law on TX Power at Antenna, the ERP term penalises single higher power transmitters which are a throwback to 1950s BandI TV planning and does not penalise low power relays or Deflectors.

An omini (360 degrees) covers more area than a 2 degree dish or 18 degree yagi
k/Frequency takes accont that say UHF has more range than 5.6GHz band etc.

M is a Mode factor. This is 1 for FM, AM, SSB, NBFM. It might be a fraction for Spread Spectrum transmission techniques which reuse the same bandwidth for different logical channels. A variant of 802.11 exists for Metroplitan and rural fixed point transmission. Such a protocol allows shared bandwidth two way access for Interactive TV or Internet and one way Multicast of Data which would include DVB type or MPEG4 TV transmission. Such systems are replacing the Analog MMDS in over 70 countries.

ASL is hight above Sea Level. A very high site uses a higher proportion of the terrestrial spectrum in the sense that reuse is lowered.
RTE in the 1960s and 1970s had a policy of picking sites based on hieght more than usefull viewer population density and coverage. Maghera, Kippure and Mullaganish are wasteful of spectrum in this sense.


This more complex formula to charge for Spectrum will penalise single high power transmitters and aviod unfair charging of point to point or signals beamed at a Village. A formula needs to be devised to apply equally to any operator for spectrum usage acording to the actual real useage / re-use possible. Thus a BAND III 200KW ought to pay more for its 16MHz on VHF than its 16MHz on UHF and much more than the 32MHz used by Woodcockhill relay on UHF.

Terrestrial Spectrum is a limited but geographically reusable national resource. For TV and Radio the regulations and charges should encourage more efficent use of this in away to benefit the viewer. There is something wrong with a network that gives poor TV reception in Clonmel yet can be viewed in Cornwall and Wales.

Similar questions could be asked reguarding Boyne Valley versus Lagan Valley and Clermont Carn. Or Areas of Donegal or Mayo versus Derry and Strabane from Holywell Hill, Truskmore and Carn Hill.

I have no objection to the UK watching Irish TV, but my experience is that many Irish viewers have greater problems than RTE will agree. I believe TV3 coverage is worse.

Again it is beyond the scope of this current Comreg proposal the issues reguarding reception and use of DAB, DTT and Satellite in Ireland, but charges for regulation and Spectrum should encourage the broadcasters to provide a better more customer orientated service.


Thanks for having patience to read my somewhat rambling reply.

spongebob

"It is SUBSCRIPTIONS in Ireland from ANY Satellite operator that should be counted and charged 0.50 Euro each, not dishes as counting dishes does not indicate how many use the dish or what purpose it is used for"

and Comreg already charge you for the uplink portion of a 2 way VSAT link so they could end up taxing you twice on the one dish......

M

watty

Spectrum terrestrial is reused geographically,
More frequently: low power, higher frequency, more directional aerial or lower aerial.
Spectrum is allocated Internationally, but above 28 to 45 MHz ish the frequencies in an allcated band can be locally administrated. The LW, MW, SW frequecies (below 30MHz) allocated to local transmitters have to be Internationally agreed due to range.
Spectrum from 30MHz to 2GHz approx has to be co-ordinated with a neighbouring country after the band is internationally allocated as obviously Dundalk and Newry or Letterkenny & Derry can't get same DAB, DTT, Radio or TV channels allocatied.

Less frequently: high power, lower frequency, less directional aerial (omni) or higher aerial (big mountain top).


Spectrum from satellite is reused approximately every 3 degrees of arc.
About 120 degrees of arc is available easily on a dish = same spectrum for 40 different operators. Not just Sky. It is allocated Internationaly. So obvioulsy you can't block sky with blocking everything else. Logically you count subscribers.
(i.e. stations on 19E, 13E, 30W and 28E actually can use the exact same channel/frequency). A 90cm dish might only get 100 degrees of arc. The limit due to Earth Horizon noise for a really big dish is about 160 degrees.

This is why global geostationary coverage usually uses 3 satellites 120 degrees apart (often on C - Band).

As well as the well known 10.75 to 12.6 GHz band Sky is on, there are two other main satellite bands (L band , Worldspace) and (C-Band Cable head end feeds) receivable in Ireland.

There are 3 other bands that will be in use. Two are for "High Altitude Platform" HAP transmissions. An airship or aircraft perhaps 20 miles high. This spectrum is more reusable than the Satellite spectrum and has less trans-national overspill.
(Satellites are 22,500 miles high so will always overspill a lot).

watty

If you read the Comreg thing carefuly re Satellite:

The Comreg proposed Dish tax is:
Volentary
Only for Pay TV
Collected from Pay TV Operator, not dish user/owner

Can you see Sky paying an "optional" Tax?

Comreg proposes:
Deflector operators are not charged for spectrum. Just transmitter.

RTE is not charged per licence payer etc, but per transmitter, which will discourage installing relays (Look at how much the 42 Euro table on pavement tax has gone to in Dublin).


Alternatively:
Thats why I propose a Spectrum charge for terrestrial based on Area, frequency, power and channels used as this is fairer and can be wieghted in favour of relays as they reuse the same spectrum. Big 1/2 Megawatt masts on top on mountains don't.

Satellite you can't charge for spectrum at all, since 90% could be used for services not sold in Ireland and we have no local control over it. It is logical that ANYTHING (Apples to Zeppelins) sold, rented or provided as a service in Ireland ought to pay Irish VAT and be Irish regulated, for consumer protection and Irish Administration.

watty

If you make a reply to Comreg before wednesday:

* Reread the the Comreg Document (Download and print out is best)

* Put your full name and Address
* Explain why you are concerned / making a submission
* Answer the questions
* Explain logic to your answers

Really this Comreg document is aimed at Chorus, NTL, RTE, Deflector Operators and Sky rather than general public.

But if you do above points politely, I'm sure your opinion will at least be read. Make sure you don't complain about something the proposal doesn't say!

spongebob

Submissions by Tomorow Morning, see first post for link to document , email address on page one to which you send your thoughts.

Comreg have an easier time if you fit your answers to the questions they posit (there are 7 or 8) if you only have an opinion on 1 or 2 of them then fire away anyway

M