Cats into the bag. Digital Dividend Consultation

Sponge Bob

Comreg are consulting ( this usually means 'pretending to listen' ) on the future uses of the 400-800mhz band after analog switch off in 2012 ? 2015 ? whatever .

No doubt many of the wise ones around here have a view on it and no doubt many have wildly divergent views ...hence my bag of cats analogy 8)

YOUR views must reach Comreg by the 7th of May , here is the consultation document .

http://www.comreg.ie/_fileupload/publications/ComReg0915.pdf

From what I can make out there is insufficient room for 6 DTT muxes in the spectrum that remains allocated to TV .

Back channel issues are no doubt of some importance given the lack of Broadband in Ireland . This spectrum is ideal for it.

Comreg say ( they are to an extent bound by emerging EU proposals)

ComReg believes that an approach, to which this consultation will contribute, which allows for a mix of broadcasting and non-broadcasting services to use the UHF frequency band will be central in allowing Ireland maximise the benefits from its digital dividend.

This so called mixed approach will allow the widest variety of
broadcasting services to be introduced while facilitating the greatest efficiency in the use of the digital dividend spectrum for new non-broadcasting services. .
Ireland’s digital dividend can boost Ireland’s digital economy and for this reason
ComReg believes it to be essential to optimise the amount of digital dividend
spectrum available to Ireland.

ComReg is conscious of the proposal at European level for a harmonised non-mandatory sub-band from channels 61 to 69 (“the 800 MHz sub-band”), for non-broadcasting applications and of the requirement under the 2007 Act to provide spectrum for the carriage of 6 multiplexes for digital terrestrial television (DTT) broadcasting. It intends, nevertheless, to explore the benefits for Ireland through the identification of an additional digital dividend sub-band(s). For instance, a sub-band within the UHF channel range 21 to 60. In particular,

ComReg wishes to explore what opportunities channels 36 and 38 might present for Ireland as these, along with channel 69, were identified in the Europe Economics report as possible additional digital dividend spectrum.

Please note one likely EU requirement in the higher bands

Draft CEPT Report in response to the 2nd EC Mandate to CEPT on Digital Dividend in respect of channelling arrangements for the 790-862 MHz band has been significantly advanced. The meeting confirmed that mixing FDD and TDD within the harmonised band plan should be avoided."

EU proposals are here ( largely in late draft at this stage )

http://www.ero.dk/E5FDB5F5-36C0-4DEF-9D55-75999AD5107E.W5Doc?frames=no

Finally, here are the 18 questions, you may answer one or all of them as you wish .

Appendix B – Consultation Questions
List of Questions

Q. 1. What would you consider to be the levels of value and benefits,
including any social value which may be produced for Irish consumers / citizens
and Ireland’s digital economy arising from non-broadcasting uses of the digital
dividend?.............................................................................................................................................13

Q. 2. How in your view could various industry sectors, for example transport,
healthcare, education or other public sector industries, benefit from utilising
digital dividend spectrum? Please include details of the potential spectrum
requirements of the industry in your answer. .....................................................................13

Q. 3. Please outline your views regarding (i) the types of applications and
services which you consider the digital dividend should be used for; (ii) possible
spectrum requirements of those applications; (iii) timeframes for making
available rights of use for digital dividend spectrum; and (iv) the potential levels
of competition which may result in existing or new products and services
markets. ..............................................................................................................................................14

Q. 4. Would you consider there to be other key issues which should be
considered in terms of gaining a deeper understanding of the spectrum
requirements of new applications and services? If so, what are they and please
elaborate.............................................................................................................................................14

Q. 5. What are your views regarding the level of demand for Ireland to
reserve UHF spectrum for innovation and experimentation? Please support your
views with consideration to the availability of UHF spectrum. .....................................15

Q. 6. In light of your views on non-broadcasting services, do you consider
that a mixed approach to spectrum allocation in the UHF spectrum band should
be adopted? Please provide reasons for your view...........................................................16

Q. 7. Do you agree with ComReg’s assessment regarding the initial mix
between broadcasting and non-broadcasting services? Please answer in terms of
your views regarding the initial mix between broadcasting and non-broadcasting
services and any other considerations that you consider relevant. ...........................17

Q. 8. Do you consider that, if the spectrum demand for the provision of DTT
services does not meet the level envisaged by the 2007 Act, a review of the
initial mix should be carried out following analogue switch-off of television
services in the UHF spectrum band? If so, please provide reasons for your view
and also indicate which stakeholder(s) should participate in such a review. If
not, please provide reasons for your view............................................................................17

Q. 9. Do you consider that the 800 MHz sub-band should be reserved for
services other than broadcasting? Please provide reasons for your view. ..............19

Q. 10. How do you consider that the current uses of channel 69 in Ireland, for
example Programming Making and Special Events (PMSE) uses, would be
impacted by reserving the 800 MHz band for non broadcasting services? Please
provide your view on how PMSE uses could be accommodated if such uses were
to be displaced from channel 69. ..............................................................................................19

Q. 11. Do you consider there to be merits in the identification of additional subband(
s)? If so, please provide details in terms of timing and any other details
which you consider relevant and reasons for your view. If not, please provide
details and reasons for your view.............................................................................................20

Q. 12. What type of channel configurations would you consider would deliver
most economies of scale in terms of availability of equipment and tuning /
roaming of equipment? Please explain in terms of an indicative channel plan of
frequencies, see for example Figure 2.0, and if you propose a channel
configuration please give details of how this might impact broadcasting use of
the band? ............................................................................................................................................20

Q. 13. Do you consider there to be merits in accelerating access to a digital
dividend sub-band in Ireland? If so, what considerations do you believe would
need to be taken into account and how would they impact accelerating access to
the digital dividend, for example (i) possible opportunity costs of delayed
access; (ii) time-table for analogue television switch-off; (iii) geographic location
of potential cleared spectrum bands; (iv) risk of fragmentation of digital
dividend; and (v) any other risk/benefits which would need to be considered....22

Q. 14. What would you consider to be an optimal time for holding awards for
digital dividend spectrum? Please refer to the considerations outlined in question
13 above.............................................................................................................................................22

Q. 15. Please qualify your answers to questions 13 and 14 in terms of what
benefits might accrue to Irish consumers and citizens and Ireland’s digital
economy if access to a sub-band could be made available as soon as possible..22

Q. 16. Please also provide views on the opportunity cost of delayed access to
cleared spectrum and the possibility of negotiating early access directly with
broadcasting spectrum users......................................................................................................22

Q. 17. Do you consider that service and technology neutrality should generally
be a key principle for spectrum rights of use arising from the digital dividend?
Please provide reasons for your view......................................................................................23

Q. 18. Do you consider that spectrum rights of use arising from the digital
dividend should exclude the ability to provide DTT services? Please provide

reasons for your view.....................................................................................................................

The Cush

Sponge Bob wrote: »

From what I can make out there is insufficient room for 6 DTT muxes in the spectrum that remains allocated to TV .

Ireland were assigned 9 muxes (layers) at GE06, at the moment almost all the main transmitters broadcast on 8 frequencies. Some replanning may have to be done if channels 61-69 are reallocated.
In Sweden where the Digital Dividend has already been allocated they plan to have a min. of 6 muxes in the UHF band and 1 in the VHF band.