Qualcomm - ACMA IFC 04/2008
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Qualcomm - ACMA IFC 04/2008






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Qualcomm - ACMA IFC 04/2008 Qualcomm - ACMA IFC 04/2008 Document Transcript

  • July 28th, 2008 Manager Policy and Research Section Spectrum Planning Branch Australian Communications and Media Authority PO Box 78 Belconnen ACT 2626 Fax: (02) 6219 5256 Email: spectrum.outlook@acma.gov.au Qualcomm Incorporated would like to thank the Australian Communications and Media Authority (ACMA) for the opportunity to provide comments on its Five-year Spectrum Outlook: 2009 – 2014. As the ACMA may already be aware, Qualcomm is a leader and innovator in the development of digital wireless technologies including those based on Code Division Multiple Access (CDMA) and Orthogonal Frequency Division Multiplexing (OFDM). These solutions are available today for a number of communications applications, including mobile cellular, fixed wireless access, broadband wireless access, trunking and satellite services. Qualcomm broadly licenses its technologies to over 150 device, infrastructure, application-specific integrated circuit (ASIC) and test equipment vendors around the world and is interested in the success of all the air interfaces that use CDMA technologies, including CDMA Multi-Carrier (CDMA2000), CDMA Direct Spread (WCDMA/HSPA) and CDMA Time Division Duplex (UTRA TDD & TD-SCDMA). Qualcomm is also at the forefront of mobile multimedia broadcast technology development and has been instrumental in the developing of MediaFLO™, an end-to-end solution that enables broadcasting of high-quality video streams, audio channels, as well as other multimedia applications (video clips, IP datacasting applications, etc.) to mobile devices. 1 FLO™ (Forward-Link-Only) technology, a key component of the MediaFLO system, is a mobile broadcast air interface standard based on coded OFDM modulation. Qualcomm applauds the ACMA’s efforts to provide industry stakeholders an assessment of Australia’s five-year spectrum outlook. We are pleased to share our views on the following frequency bands and issues: 1) 403 – 520 MHz, 2) 520 – 820 MHz and the Digital Dividend, 3) 2500 – 2690 MHz, and 4) 1452 – 1492 MHz. 1) 403 – 520 MHz Qualcomm supports the ACMA’s proposal to make spectrum in the 450 – 470 MHz band available for wireless access services and filed a brief submission dated 25 July 2008 outlining this support in response to the ACMA’s Spectrum Options: 403 – 520 MHz Consultation paper. 2) 520 – 820 MHz and the Digital Dividend: 1 www.qualcomm.com/mediaflo
  • The ACMA is seeking views on the approach Australia should take to the ‘digital dividend’ – the UHF spectrum that will be freed up after the switch-off of analog television services. The ACMA will assist the Minister and his department in the consideration of the issues. Qualcomm believes that it is of utmost importance that the mobile and audiovisual industries are given new opportunities arising from the availability of new radio frequencies, particularly in the UHF band, provided public service and interference requirements are respected. We look forward to contributing in detail to the Government and/or the ACMA’s expected consultation on this subject. In the meantime, we wish to offer the following views: • The digital dividend, resulting from analogue to digital TV switch over and analogue switch off, will enable the cost efficient deployment of a range of innovative and convergent audiovisual and telecoms services, such as multimedia transmission services (e.g., Mobile TV), wireless broadband (e.g. 3G and future LTE), and others (e.g., public safety). • The decisions on the digital dividend are not just related to technical considerations but profoundly related to political, industrial and economic considerations as well. • The upper part of the UHF spectrum, in the 700 MHz range, is the ‘sweet spot’ for the deployment of mobile applications, taking into account handset design constraints and performance. • Taking into account the decisions that have been made in various countries globally, a digital dividend of around 100 to 150 MHz is a realistic target for Australia and will bring significant economic and social benefits to Australia. • WRC-07 identified the 790 – 806 MHz band for IMT in Region 3 and nine Region 3 countries (Bangladesh, China, Korea (Rep.of), India, Japan, New Zealand, Papua New Guinea, Philippines and Singapore) extended that IMT identification to 698 – 806 MHz. 2 In general, 806 – 960 MHz had already been identified to IMT-2000 prior to WRC-07. Australia may, therefore, wish to look at 698 – 806 MHz for possible regional harmonization of the digital dividend. • UHF Band segmentation based on service clusters, such as proposed by the European Commission in its Communication on the Digital Dividend (November 2007), 3 enables the most efficient use of spectrum, innovation and encourages investment – all benefits for the Australian consumer. • To allow for spectrum segmentation by type of service, as described in the European Commission Communication, and similar to the approach taken in the US whereby traditional high powered broadcast operations have been placed below 698 MHz, Australia should consider re-stacking its digital television services. This would enable contiguous blocks of spectrum for new services while minimizing the potential for interference to existing and future digital TV services. This frequency re-organization approach has previously been recognized by the ACMA in its Consultation on 2 ITU-R Radio Regulations No. 5.313A and No. 5.317A, Final Acts of WRC-07. 3 “Reaping the full benefits of the digital dividend in Europe: A common approach to the use of the spectrum released by the digital switchover;” See http://ec.europa.eu/information_society/policy/ecomm/doc/library/proposals/com_dd_en.pdf. 2
  • “Allocation of spectrum for new digital television services.” In particular, the AMCA stated: • “The reorganised spectrum could have greater utility if contiguous blocks of channels can be made available. This could be done via ‘restacking’ the channels instead of a ‘Swiss cheese’ approach of re-allocating the relatively small spectrum blocks vacated by analog television services which are interspersed by digital television services.” 4 • Qualcomm undertook an analysis on the impact of a fragmented digital dividend on handset technical design and cost. Our conclusion is that the harmonization of the digital dividend at some level is a must in order to reap the full benefits of this valuable spectrum and to achieve the required economies of scale. As an example, Figure 1 shows the cost implications arising from the adoption of three different digital dividend band plans compared to the adoption of a single harmonized band plan on handset design and cost. Power Driver A A D P FDD 1 BAND • Band usage: 6DL/6UL carriers Tx SAW is required due to narrow / • Relative PA peak power requirement: +2dB Tx • Relative FE Rx link budget: -2.5 dB • BOM cost: $0.81 (duplexer/filters/switch) L N A Low Noise FDD 3 BANDS A A P D • Band usage – 3DL/3UL carriers – 6DL/6UL carriers Tx SAW is required due to narrow / – 10DL/10UL carriers Tx • Relative PA peak power requirement: +2.6dB • Relative FE Rx link budget: -3.1 dB • BOM cost: $3.22 (duplexer/filters/switch) L N A Figure 1: Impact of spectrum harmonization on the mobile terminal design and cost. Source: Qualcomm • The digital dividend mobile broadband band plan which will support 3G and LTE should be harmonized to the greatest extent possible and should be based on FDD (Frequency Division Duplexing) or HD-FDD (Half Duplex FDD). The TDD (Time Division Duplexing) option does not enable the deployment of cost efficient wide area / large coverage mobile networks and would therefore not be suitable for the UHF digital dividend. 4 ACMA Consultation Paper on “Allocation of spectrum for new digital television services,” page 23. 3
  • • Australia should seek to complete its digital dividend spectrum planning and schedule the spectrum auction within the 2010/2011 timeframe in order to allow new networks to be built prior to January 1, 2014 and services launched on January 1, 2014. As the ACMA has pointed out, prior to completion of digital switchover, the only remaining vacant UHF spectrum is currently comprised of Channel A and Channel B. Channel B is authorized to provide new and innovative services such as mobile TV. Notwithstanding our views on digital dividend planning in Australia, Qualcomm believes Channel B provides a unique opportunity to introduce new and innovative services, such as mobile broadcast multimedia, to Australian consumers in the near term. Some flexibility is needed, however, to improve the current Channel B planning. In the longer term, provided clarity and certainty are given to the Channel B licensee in the Government’s digital dividend re-planning process (e.g., Government proceeds with digital television re-stacking and includes Channel B in the re-planning), Channel B also represents a long term opportunity for introducing cost effective and compelling applications and services to Australian consumers. Demand for new mobile broadcast multimedia services has been demonstrated via trials, consumer research, and analyst forecasts. 5 The benefits to the early introduction of new mobile broadcast services in Channel B include the following: • Ability to offer new mobile broadcast services to Australian consumers via innovative delivery methods (e.g. Clipcast, IP Datacast). These new services include mobile multimedia services such as news, sports, movies, music, etc. and valuable e- learning, e-health, e-government and time-sensitive (emergency, safety) information; • As a complementary service, mobile broadcast will spur faster take-up of 3G while increasing ARPU and fostering demand for new multimedia and innovative services in Australia; • Allow mobile operators to off-load capacity intensive rich multimedia services from their wireless 3G network; • Create new revenue opportunities for the content industry as Mobile TV represents a new media outlet benefiting from a growing ecosystem (interactive applications, production of new audiovisual programs, promoting quality brands, reaching new audiences, etc.); • Demonstrate to industry the benefits in accelerating the digital transition and embracing new convergent services. For example, in the United States the early FCC auction of Channels 54, 55, and 59 was instrumental in accelerating or keeping the digital transition on schedule and sensitizing the industry and the Government to the value of new digital wireless services. To this end, we encourage the Government and the ACMA to proceed with the Channel B spectrum auction and to make any needed adjustments to Channel B prior to auction so that it is optimized for mobile TV usage, particularly in heavily populated areas such as Sydney and the Gold Coast. We also encourage the Government and the ACMA to ensure that Channel B is included in the Government’s longer term re-stacking process, thereby leading to the most efficient use of the valuable digital dividend spectrum resource. 5 For example, ABI Research estimates that there will be 250 million mobile video users worldwide by 2010 and the Yankee Group estimates the market for mobile TV/video to be $11 billion by 2010. Allied Business Intelligence Inc., June 2006; “Mobile Video/Broadcast TV Market Assessment: Will Operators Get the Picture Right,” Yankee Group, November 2006. 4
  • 3) 2500 – 2690 MHz As stated previously in Qualcomm’s response to the ACMA’s WAS consultation, 6 Qualcomm strongly believes that the 2500 – 2690 MHz band (“2.6 GHz”), and in particular 2500 – 2570 MHz paired with 2620 – 2690 MHz, will be needed to sustain the fast market growth of 3G services and future 4G services. Importantly, 3G technologies are continuing to evolve towards higher data rate capabilities (such as HSPA+ and Long Term Evolution – LTE) that will benefit from the 2.6 GHz spectrum which offers the unique opportunity of wider bandwidths up to 20 MHz. 3G wireless is currently providing advanced broadband data and voice services to more than 625 million subscribers worldwide. 7 We believe the 3G industry and eco-system will increasingly play a leading role in the provision of fixed and mobile 3G broadband services to the citizens of Australia and other countries worldwide. Subscriber forecasts for 3G/IMT in the coming years are staggering, with industry analysts projecting that by 2011 there will be more than 1.4 billion 3G subscribers globally. 8 Qualcomm plans to integrate support for the 2.6 GHz band into its entire HSPA/HSPA+ chipset portfolio, and has already announced three chipset solutions that support HSPA/HSPA+ devices at 2.6GHz: the Mobile Data Modem™ (MDM™) MDM8200™, Qualcomm Single Chip™ (QSC™) QSC7230™ and QSC7630™. The MDM8200, primarily targeted for data cards and USB modems, and the QSC7230 and QSC7630, targeted for mass market smartphones, will support the 2.6 GHz band as well as existing HSPA/HSPA+ bands. Qualcomm’s OEM customers are expected to launch end-user devices based on these solutions starting in the second half of 2009. Operator trials of 2.6 GHz OEM devices may start earlier in 2009. Irrespective of what technologies or services may be deployed, a common and harmonized band plan reduces the risks of interference and facilitates economies of scale, which in turn brings benefits to consumers. Qualcomm’s WAS submission supported, therefore, two possible band segmentation plans, both of which support the use of the outer 70 MHz of the 2.6 GHz band for FDD: 1. 70 MHz FDD / 50 MHz TDD / 70 MHz FDD 2. 70 MHz FDD / 50 MHz ENG OB / 70 MHz FDD The advantages to these band segmentation plans are that they provide separate band segments for FDD and TDD operations, maintain the 120 MHz duplex separation required by 3GPP/3GPP2 specifications and ITU-R Recommendation M.1036, and would be consistent with the 2.6 GHz plan expected to be used by many other countries around the world. Other options, which entail a flexible FDD/TDD block assignment scheme, would not provide the expected benefits to either paired or un-paired operations. 9 This will impact Australian consumers as it may lead to Australia-specific handsets which will be difficult, if not impossible, to be used to roam with other countries. A number of other countries, such as Sweden and Germany, recently acknowledged these benefits and decided to adopt the European Electronic Communications Committee’s ECC(05)05 harmonized band plan for the 2.6 GHz band, i.e., 70 MHz FDD / 50 MHz TDD / 70 MHz FDD . 6 See http://www.acma.gov.au/WEB/STANDARD/pc=PC_100536. 7 Wireless Intelligence as of March 2008. 8 Sources: CDMA2000 & WCDMA: Average of Informa, Strategy Analytics, Wireless Intelligence and Yankee Group subscriber forecasts. 9 Please refer to Qualcomm’s WAS submission for further technical background , note 6 supra. 5
  • In the context of the three year review of the ECC(05)05, the ECC plenary confirmed with an overwhelming majority the current ECC(05)05 band plan and decided that it was inappropriate to introduce any flexibility in the ECC(05)05 band plan. This decision provides clarity to the stakeholders and a clear path forward in the 2500-2690MHz band: the ECC(05)05 band plan. This commitment from the ECC plenary will allow the industry to continue product development for commercial availability in due time when the spectrum auctions take place. 4) 1452 – 1492 MHz The ACMA is considering use of this band by digital radio (T-DAB) for in-fill transmissions and regional coverage and may revise the 1.5 GHz Band Plan accordingly. Qualcomm would like to point out that other services such as mobile multimedia broadcast could also be deployed in this spectrum and other countries are considering such usage. Conclusion In conclusion, Qualcomm appreciates this opportunity to provide comments on the ACMA’s Five- year Spectrum Outlook: 2009 – 2014 and looks forward to providing the ACMA with greater detail on the above mentioned spectrum matters. Should you have any questions or comments on this submission, please do not hesitate to contact me at +852 6348 6687 (mobile) or juliewelch@qualcomm.com. Sincerely, Julie Garcia Welch Director, Government Affairs Southeast Asia & Pacific cc: Robert Hart, Qualcomm Senior Director of Business Development and Country Manager for New Zealand and Australia 6