Five-year spectrum outlook 2014-2018 The ACMA's spectrum demand analysis and strategic direction for the next five years

Motorola Solutions’ response to the ACMA’s paper:

Five-year spectrum outlook
2014-2018
The ACMA’s spectrum
demand analysis and strategic
direction for the next five years
SEPTEMBER 2014

Prepared by: Michael.Hill@motorolasolutions.com

AU Motorola Response to FYSO_2014-2018.docx

Context
Motorola Solutions designed and delivered technology solutions for some of Australia’s most critical
public safety and enterprise communication networks for more than four decades.

Within Australia and internationally, Motorola Solutions (Motorola) is a major supplier of
radiocommunications equipment and services to governments, emergency services organisations, the
mining and energy industries, manufacturing sectors, transportation, tourism, telecommunications
carriers and telecommunications service providers.

Today, we’re applying our strong heritage, technical capabilities and innovation leadership to help our
customers move into new areas including 4G LTE mobile broadband and sophisticated network
monitoring so they can get more out of their technology investments including higher safety and
productivity standards.

Motorola excels in the research and development, production, marketing and efficient operation of
communications equipment and systems all over the world and our brand is synonymous with high
quality communication products and services. As a global organisation with close operator and
customer links, our deep experience qualifies us to provide relevant and informed comment on this
discussion paper.

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Motorola has responded to the ACMA’s discussion topics and project descriptions which are related to
the following subjects and frequency bands:

(1/3.1.2) Broader government policy agenda......................................................................................... 4
(1/3.1.3) International ............................................................................................................................ 4
(2/5) Ensuring the national interest........................................................................................................ 4
(2/2.2) Flexible arrangements for spectrum access ............................................................................... 5
403-520 MHz implementation ................................................................................................................ 5
803-960 MHz band review ...................................................................................................................... 6
380-400 MHz implementation ................................................................................................................ 7
400 MHz regulatory assessment (opportunity cost pricing)................................................................... 7

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(1/3.1.2) Broader government policy agenda

On 23 May 2014, the Minister for Communications announced a review of the spectrum policy and
management framework. The purpose of the review is to examine what policy and regulatory changes
are needed to meet current challenges, and ensure the framework will serve Australia well into the
future.

Motorola is participating in the Department’s review and has provided responses to the Department’s
first consultation paper.

(1/3.1.3) International

AND

(2/5) Ensuring the national interest

Australia’s participation in the work of the International Telecommunications Union (ITU) and the Asia
Pacific Telecommunity (APT), enables Australia to participate in the global economy by supporting the
efficient operation of a myriad of international activities dependent on communications. This includes
the provision of international assistance during times of emergency, international travel and
international banking.

Australia’s positions on international radiocommunication, radiofrequency spectrum management
issues and ITU World Radio Conference (WRC) agenda items are arrived at through a process whereby
the ACMA engages in active ongoing consultation with stakeholders through a number of domestic
bodies including the Australian Radio Study Groups (ARSGs) and the ACMA Preparatory Group for the
WRC (PG WRC). The ARSGs mirror the ITU-R Study Groups and their Working Parties and make
recommendations to the ACMA to be considered at regional and international meetings. More often
than not, industry contributes the majority of Australian Delegation members attending regional and
international meetings providing an essential resource that assists and reinforces the ACMA’s
participation in such meetings.

This formal process of active ongoing industry consultation ensures that interested stakeholders can
help shape Australia’s international radiocommunication profile.

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Motorola considers this process to be very important to Australia’s ability to play a meaningful part in
the international radiocommunications community and influence regional and international decision
making that ultimately impacts every radiocommunications user in Australia. For this reason the process
described above needs to be maintained and resourced adequately to ensure on-going Government
participation and leadership either through the ACMA or other relevant government agencies in
regional and international meetings.

(2/2.2) Flexible arrangements for spectrum access

Flexible spectrum access arrangements can work when a cooperative arrangement exists between the
participants and there is a shared commitment to the allocation of resources, including appropriately
knowledgeable personnel.

The introduction of spectrum sharing or spectrum parks where users administer allocations within
geographic and frequency boundaries should be subject to lower spectrum access fees.

Motorola considers that the only measure of success is the extent that spectrum prices fall as the result
of implementing the scheme. Only falling prices would justify reduced spectrum access or the
implementation of a spectrum management scheme that, in essence, introduces an additional layer of
management. Any price rises that follow from the introduction of such a scheme would mean that the
scheme has failed and there have been no gains to the economy of spectrum management.

Band-by-band work program

403-520 MHz implementation

According to Schedule 1 of the “Five-year spectrum outlook 2014–18” the completion date of this
initiative is the end 2019. The original end date published in the “The way ahead: Timeframes and
implementation plans for the 400MHz band” was the 31st of December 2018.

Motorola understands and is sympathetic to the financial and resource constraints under which the
ACMA must operate. However, resulting project delays are having a negative impact on the ability of
industry to plan.

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Motorola is concerned that users are finding it difficult to comply with the milestone deadlines for the
new government and commercial sub-band arrangements. A lack of coordinated planning has resulted
in many government and commercial users who are ready and willing to relocate to their respective
new sub-bands but are unable to do so because there is insufficient spectrum available in their
destination segments.

Regulatory certainty is a must to enable industry to plan for such changes. Motorola therefore
encourages the ACMA to be realistic in setting timeframes for major changes so that users who have
planned to relocate in accordance with a published ACMA timeframe are not left on hold because of
the proposed timeframes have been pushed back.

803-960 MHz band review

The expected completion time frame, according to the “Five-year spectrum outlook 2014–18” is 2015.
The original review completion time frame was approximately Q2 2014 as stated in Figure 1.2 of “The
900 MHz band — Exploring new opportunities”; an ACMA discussion paper released in May 2011.

Motorola understands and is sympathetic to the financial and resource constraints under which the
ACMA must operate. However, the resulting project delays are having a negative impact on the ability
of industry to plan.

Motorola is looking forward to a speedy conclusion to the review of this band. The market for systems
and equipment in this band has been depressed since the commencement of the review in May 2011.
Users and potential users of this band are understandably reluctant to commit resources and
development funds to this band whilst the ACMA’s embargo 64 is in place and the band has an
uncertain future.

Motorola understands that the recently announced Productivity Commission cost benefit analysis of the
best way to provide broadband spectrum capability to public safety agencies will have an impact on
project timing and regrets that, in all likelihood, it will be another 12 to 18 months before any certainty
returns. While Motorola understands that this further delay is indirectly due to the change of policy
emphasis following the 2013 Federal Election, it remains hopeful that all government agencies with
responsibility in this area (the ACMA, Department of Communications and the Productivity Commission)
will move quickly to end the uncertainty for industry and State and Territory Public Safety Agencies.

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380-400 MHz implementation

The potential sharing arrangements for this band being negotiated between Defence and some federal
government departments is welcome. The arrangement may help to reduce spectrum pressure in the
crowded government spectrum allocations in the 403-470 MHz band provided by the ACMA as a part of
its 400 MHz band review.

Regulatory and service planning work programs

400 MHz regulatory assessment (opportunity cost
pricing)

On this subject Motorola agrees with the sentiment of the Australian Radio Communications Industry
Association (ARCIA) provided in its response to the ACMA Discussion Paper IFC25-2014 Progressing
Opportunity Cost Pricing in the 400 MHz band.

Motorola agrees with the ACMA’s finding that there has been a widespread small reduction in demand
since the introduction of the first OCP price increment.

Motorola does not agree with the assumption that the small reduction in demand is the result of the
OCP change alone.

In recent years the ACMA has introduced a number of changes to the 400 MHz band through the
ongoing implementation of the outcomes from the 400 MHz band review. As a result of this band
restructure many users have and are relocating to different band segments, some users have
consolidated channels or released some unused channels. The number of available channels has
increased due to a reduction in channel bandwidth in some band segments and the re-introduction of
apparatus licensing in the 500 MHz band segments.

Further studies into the demand for spectrum should be conducted before proceeding with the second
OCP increment.

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Table of abbreviations and terms
Abbreviation or term   Meaning
ACMA                   Australian Communications and Media Authority
APT                    Asia-Pacific Telecommunity
ARCIA                  Australian Radio Communications Industry Association
ARSG                   Australian Radiocommunications Study Group
ITU                    International Telecommunication Union
MHz                    Megahertz
OCP                    Opportunity Cost Pricing
WRC                    World Radiocommunication Conference

                                       End of response

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