July 28th, 2008
Policy and Research Section
Spectrum Planning Branch
Australian Communications and Media Authority
PO Box 78
Belconnen ACT 2626
Fax: (02) 6219 5256
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:
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
• 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
• 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
ITU-R Radio Regulations No. 5.313A and No. 5.317A, Final Acts of WRC-07.
“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
“Allocation of spectrum for new digital television services.” In particular, the AMCA
• “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
• 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
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)
FDD 3 BANDS A A
• 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
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.
ACMA Consultation Paper on “Allocation of spectrum for new digital television services,” page 23.
• 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
• 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
• 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.
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.
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
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 .
Wireless Intelligence as of March 2008.
Sources: CDMA2000 & WCDMA: Average of Informa, Strategy Analytics, Wireless Intelligence and
Yankee Group subscriber forecasts.
Please refer to Qualcomm’s WAS submission for further technical background , note 6 supra.
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.
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
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