March 30th, 2007
Spectrum Planning Branch
Australian Communications and Media Authority
PO Box 78
Belconnen ACT 2616
Fax: 02 6219 5133
QUALCOMM Incorporated would like to thank the Australian Communications and Media Authority
(ACMA) for the opportunity to provide comments on the ACMA’s Strategies for Wireless Access Services:
Spectrum Access Options.
QUALCOMM is a leader and innovator in the development of digital wireless technologies including those
based on Code Division Multiple Access (CDMA), Orthogonal Frequency Division Multiplexing (OFDM)
and others. 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 is interested in the success of all the air interfaces that comprise the International
Telecommunication Union’s (ITU) IMT-2000 recommendations that use CDMA technologies, including
CDMA Multi-Carrier (CDMA2000), CDMA Direct Spread (WCDMA) and CDMA Time Division Duplex
(UMTS TDD), which share a common technology base.
QUALCOMM has also developed other technology solutions for wireless service providers including
MediaFLO™ 1 , 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
handsets. FLO (Forward-Link-Only) technology, a key component of the MediaFLO system, is a new
mobile broadcast air interface – based on coded orthogonal frequency division multiplexing (COFDM)
modulation – that is designed and optimized to increase capacity and coverage while reducing the cost of
multimedia content delivery to mobile handsets.
In addition, QUALCOMM is an Australian spectrum license holder. In 2001, QUALCOMM Incorporated,
via 3G Investments (Australia) Pty Ltd, paid $159 million Australian Dollars for 2x10 MHz of spectrum in
the 2.1 GHz band in the major Australian cities. This spectrum licence was awarded in 2002 and expires in
In this submission, QUALCOMM will focus its comments on the 2500 – 2690 MHz band, the 520 – 820
MHz band, and the new ‘private park’ licensing concept.
Suitability of candidate bands
Recognising the suitability of the identified bands for WAS, and their importance for incumbent
1. Should the 2500-2690 MHz band be made available (in whole or part) for WAS
applications? If it were, what would be implications (costs) be for ENG applications?
(also refer to section 5 ‘Band Segmentation Options”)
QC supports the ACMA’s proposal to release spectrum in the 2500 – 2690 MHz (“2.5 GHz”) band. This
band differs from some of the other frequency bands proposed for WAS (e.g., 3575 – 3710 MHz, 520 – 820
MHz) in that it has already been identified by the ITU for administrations wishing to implement IMT-2000.2
In this regard, it is targeted for 3G / IMT-2000 expansion and will be needed to sustain the fast market
growth of 3G services. With more than 448 million subscribers worldwide, including 115 million
WCDMA/HSDPA 3 and 333 million CDMA2000 4 , 3G technologies are currently providing advanced
broadband data and voice services throughout Australia, Asia, Europe and the Americas. As of February
2007, there were 97 HSDPA mobile broadband networks in operation in 51 countries with another 82
planned or being deployed.5
Moreover, 3G technologies are continuing to evolve towards higher data rate capabilities (such as HSPA+,
Long Term Evolution (LTE) & Ultra Mobile Broadband (UMB)) and will require additional spectrum, and
large channel bandwidths. For instance, QUALCOMM recently announced the sampling of HSPA+
chipsets in the 2.5 GHz band by the end of 2007. HSPA+, based on the 3GPP Release 7 standard, provides
data rates of up to 28 Mbps on the downlink and 11 Mbps on the uplink, significant increases in network
capacity, reduced latency and an enhanced user experience for many data-intensive applications. Access to
the relatively wide bandwidth available in 2.5 GHz will benefit this evolution. QUALCOMM, therefore,
believes the 2500-2690 MHz band is of great importance for the development of 3G technologies and their
As the ACMA is aware, this frequency band is the subject of significant controversy within the ITU
Radiocommunication Sector with regard to the co-existence between space and terrestrial services under
World Radio Conference 2007 (WRC-07) Agenda Item 1.9, “to review the technical, operational and
regulatory provisions applicable to the use of the band 2 500-2 690 MHz by space services in order to
facilitate sharing with current and future terrestrial services without placing undue constraint on the services
to which the band is allocated.” Australia has made significant contributions to the work of ITU-R Joint
Task Group 6-8-9 which was established to “…deal with the issues related to the use of the band
2500-2690 MHz by space services in order to facilitate sharing with current and future terrestrial services.”
Australia has been steadfast in its claim for appropriate power flux density (PFD) limits applied to satellite
emissions in the 2.5 GHz band in order to protect their terrestrial services and has proposed the adoption of
stringent PFD limits. Given that most of the satellite proponents in the 2500-2690 MHz band are planning
to operate, or are currently operating, satellite systems that will have service areas or inadvertent footprints
in ITU Region 3 countries, this international debate is relevant to the ACMA’s plans to release spectrum in
the band. In order to provide greater certainty to interested bidders, the ACMA may want to await the final
outcomes of WRC-07 on this issue before releasing spectrum in the band.
QUALCOMM believes that the IMT-2000 process established by the ITU is valuable as it enables global
collaboration taking into account the interests of administrations, operators and manufacturers in order to
reach harmonization and technical compatibility. QUALCOMM will therefore continue to support and
contribute to the IMT-2000 global spectrum harmonization that includes the 2.5 GHz band.
2. What are the implications if the 2500-2690 MHz band is not made available for WAS?
3. Should the 3575-3710 MHz band be made available (in whole or part) for WAS
applications? If it were, what would the implications (costs) be for fixed point-to-point
links and fixed-satellite services? (also refer to section 5 “Band Segmentation Options”)
4. What are the implications if the 3575-3710 MHz band is not made available for WAS?
See ITU Radio Regulations No. 5.384A and Resolution 223.
3G Americas and Wireless Intelligence, February 20, 2007.
www.3Gtoday.com as of February 28th, 2007.
GSA, February 2007 and 3G Americas, February 20th, 2007.
If the 2500-2690 MHz band were made available for WAS:
5. Which segmentation option would you prefer? Why? Respondents are welcome to
suggest alternative segmentation options.
QUALCOMM supports the band segmentation plan proposed as Option 2. This arrangement (i.e., 70 MHz
FDD / 50 MHz TDD / 70 MHz FDD) provides separate band segments for FDD and TDD operations,
maintains the 120 MHz duplex separation required by 3GPP/3GPP2 specifications and ITU-R
Recommendation M.1036, and would be consistent with the plan expected to be used by many other
countries for 2500-2690 MHz. We believe all of the other options, which entail a flexible FDD/TDD block
assignment scheme, would not provide the expected benefits to either paired or un-paired operations. 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.
Irrespective of what technologies or services may be deployed, a common and harmonized band plan
facilitates economies of scale, which in turn brings benefits to consumers. Options 1, 3, 4, 5, 6 would lead to
an inefficient use of spectrum due to the multiple guard bands that would be needed. Moreover, it will be
extremely difficult for an FDD handset to operate in differing band plans with one Transmit/Receive (Tx/Rx)
chain while protecting the unpaired spectrum from Tx interference. For example, an FDD terminal
operating in accordance with the European agreed ECC band plan 6 could have difficulty meeting the
protection requirements of a TDD handset operating in accordance with a different band plan. The FDD
terminal would have to use a set of duplexer filters different from the set used for the ECC band plan in
order to protect the unpaired spectrum. Requirements on the TDD terminal Tx would also be needed to
meet the FDD handset Rx band requirements. These requirements could be difficult to meet. Terminals
with roaming capabilities between countries that have adopted differing band plans will require more
complex implementation likely resulting in higher cost, higher power consumption, and shorter distance
coverage due to higher filter insertion loss.
Sharing studies conducted by QUALCOMM between FDD and TDD Base Stations show that the lowest
frequency block of a licensee’s unpaired spectrum is not viable for usage because of tight requirements on
Tx filtering (up to 74 dB filtering required for FDD vs. TDD or TDD vs. TDD and around 49 dB for TDD vs.
FDD, on top of ACLR values which have been specified for TDD and FDD). It is also highly questionable
whether the second lowest block of a licensee’s unpaired spectrum is viable for usage in the case of co-
located base stations (up to 100 dB filtering required for FDD vs. TDD or TDD vs. TDD and 75 dB for TDD
vs. FDD on top of ACLR values which have been specified for TDD and FDD). The efficiency of spectrum
use therefore will be considerably reduced.
Sharing studies between FDD and TDD mobile user terminals show that the lowest block of a licensee’s
unpaired spectrum is not viable for usage (for 5 m separation, the amount of Tx filtering that would be
required on top of the specified ACLR values for TDD and FDD is up to 40.3 dB for TDD vs. FDD and up
to 42.5 dB for FDD vs.TDD or TDD vs.TDD). The 2nd lowest block of a licensee’s unpaired spectrum is
also not viable for usage (for 5 m separation, the amount of Tx filtering that would be required on top of the
specified ACLR values is up to 22.3 dB for TDD vs. FDD and up to 32.5 dB for FDD vs. TDD or TDD vs.
TDD). The efficiency of spectrum use is considerably reduced in this case.
Although it could be envisaged that the risk of interference on the base stations could be lessened through
additional site engineering measures such as filtering, it would be nearly impossible to mitigate the impact
on user terminals while maintaining roaming capabilities within other countries which implement, for
example, the ECC band plan.
See “ECC Decision of 18 March 2005 on harmonised utilisation of spectrum for IMT-2000/UMTS systems
operating within the band 2500 – 2690 MHz.” This decision shows the frequency plan agreed upon within the
European Conference of Postal and Telecommunications Administrations (CEPT) Electronic Communications
Committee (ECC) to be 70 MHz FDD / 50 MHz TDD / 70 MHz FDD.
For these reasons, QUALCOMM urges the ACMA to adopt Option 2 and to work further with industry to
develop the technical requirements that would enable the expansion of 3G services and the evolution of 3G
technologies in the 2.5 GHz band.
6. What option(s) would you prefer for the management of incumbent services? Why?
QUALCOMM recognizes that the ACMA may need to manage incumbent services such as electronic
newsgathering and outside broadcast (ENG/OB) services. One possibility for accommodating these services
is to adopt a variant of Option 2 whereby the center 50 MHz would be used to support ENG/OB and the
outer 2 x 70 MHz would be designated for FDD operations. The advantages to this option are that it
accommodates ENG/OB albeit in a limited portion of spectrum, preserves Australian capability to use
handsets for roaming, avoids the technical complications and inefficiencies that are detailed in response to
Question 5 above, and would be consistent with the band segmentation plan agreed within Europe and
expected to be used by many other countries throughout the world. As the broadcasters transition from
analog to digital operations in Australia, over the long-term they will be able to use the spectrum more
efficiently. While the 50 MHz might not be sufficient to meet all the ENG/OB needs, it would ease the
migration to another band at some point in the future. The ACMA would also need to decide upon a date by
which this migration from the center gap would be complete, perhaps in about five years.
If the 3575-3710 MHz band were made available for WAS:
7. How much spectrum in the band should be made available? Why?
8. What option(s) would you prefer for the management of incumbent FSS earth stations?
Why? In particular, should FSS earth stations be “grandfathered”? If so, for how long?
In general, what arrangements should be considered for the protection of earth stations?
9. What option(s) would you prefer for the management of incumbent fixed point-to-point
10. Which licensing option(s) would you prefer for WAS in the 2500-2690 MHz band? Why?
QUALCOMM continues to believe the new “private park” licensing concept is virtually a “cousin” of the
class licensing or unlicensed concept. Our views on the new “private park” concept are, therefore,
consistent with our views conveyed to the ACMA in response to Proposal to Amend the
Radiocommunications Act of 1992 – To allow the authorization of devices under class licenses in spectrum
designated for spectrum licensing (section 36). In essence, QUALCOMM strongly believes that licensees
should have the exclusive right to transmit in the spectrum for which they hold a license.
QUALCOMM takes this position not out of any ill-will toward unlicensed technologies. QUALCOMM is
developing 802.11n unlicensed technology, and believes that unlicensed technologies have an important role
to play in local area, short range communications—such as inside buildings, in homes, and on campuses.
QUALCOMM also believes, however, that unlicensed technologies are simply not suited to wide area,
longer range communications. Only licensed services operating on spectrum dedicated exclusively to
licensed services can provide coverage over wide areas.
QUALCOMM does not believe that a “private park” licensee could start a wide area wireless business on
the basis of a non-exclusive license. This is because no operator will spend the large amounts of money
needed to build out a network without clear and undeniable protection from interference. Under the
ACMA’s proposal, it is very possible that the day after one licensee has turned on its network, another
licensee for the same spectrum and geographic area could turn on its network and cause interference.
ACMA notes this new framework has similar characteristics to the non-exclusive licensing provisions
outlined in FCC Report & Order 05-56. Importantly, we would like to emphasize that the FCC’s decision in
this proceeding has come under significant criticism from a number of companies in the wireless industry.
Like the ACMA, the FCC proposed to rely on dynamic frequency selection and contention-based protocols,
yet there has not been any showing that these technologies will actually work in this band as envisioned.
While adopted by the FCC for the 3650 – 3700 MHz band, this non-exclusive licensing concept has not yet
been implemented because the decision is subject to a large number of petitions for reconsideration.
For these reasons, QUALCOMM urges the ACMA to reconsider its proposal for a new “private park”
licensing concept and to adopt a “spectrum licensing” approach for the 2.5 GHz band.
11. What areas should the licences cover? (e.g. Australia-wide, capital cities, regional areas,
12. If the 2500-2690 MHz band was allocated for WAS, and a block of spectrum in the band
was preserved for ENG operation, how should the ENG spectrum be licensed? Why?
13. Which licensing option(s) would you prefer for WAS in the 3575-3710 MHz band? Why?
14. What areas should the licences cover? (e.g. Australia-wide, capital cities, regional areas,
General licensing issues
15. If WAS were authorized under a class licence or a private park (in either of these bands),
what should the maximum equivalent isotropically radiated power (EIRP) be? Why?
16. Is device registration necessary under a private park? If not, what other arrangements
could be used to allow coordination?
17. Should aggregation of spectrum lots be allowed? If so, how should lots be aggregated (low,
high or other)?
QUALCOMM agrees aggregation of spectrum lots should be allowed as it enables interested bidders to
acquire the amount of spectrum they believe is needed to build a viable network and would accommodate a
range of business plans. The ACMA may also want to consider further sub-dividing the spectrum lots into 5
MHz blocks and notes this topic will be handled in a future ACMA consultation.
18. What other issues should ACMA consider?
In considering the long term release of spectrum in the 520 – 820 MHz band for WAS, QUALCOMM urges
the ACMA to ensure that mobile broadcasting services, which have already been commercially deployed in
several countries around the world in the upper portion of this band, are also able to operate in the
band. Based on survey and focus group results, QUALCOMM believes there is significant demand for
mobile broadcast multimedia services in Australia and other countries around the world
As the WAS Consultation paper notes, parts of 520 – 820 MHz may become available following the switch-
off of analog television at which point there will be the opportunity to use the recovered spectrum for new
and innovative services, such as mobile broadcasting. QUALCOMM fully supports this digital switchover
plan as detailed in “Ready, Get Set, Go Digital – A Digital Action Plan for Australia,”7 and agrees this will
“…enable more efficient use of broadcasting spectrum which will, in turn, free up more spectrum for new
“Ready, Get Set, Go Digital – A Digital Action Plan for Australia,” Department of Communications, Information
Technology and the Arts, November 2006.
services.” This process could involve a re-allocation of services within the 520 – 820 MHz band. In this
regard, QUALCOMM urges the ACMA to identify and designate a harmonized sub-band within the ‘digital
dividend’ for new mobile broadcasting services. The benefits of UHF spectrum harmonization for mobile
broadcasting services include improved terminal performance, reduced network costs and improved
compatibility with fixed reception broadcasting. Similar efforts are underway in Europe where the European
Commission Radio Spectrum Policy Group (RSPG) adopted in February 2007 an “Opinion on EU Spectrum
Policy Implications of the Digital Dividend”8 which was followed by a European Commission mandate to
the CEPT / ECC Task Group 4 (TG4) to study the technical feasibility of a pan-European UHF sub-band
harmonized for multimedia services. The first TG4 Report will soon be available which will be followed by
an ECC Report outlining the technical guidelines for the implementation of mobile broadcast networks
conforming to such a spectrum configuration.
QUALCOMM notes that there are parallel spectrum activities on-going within the ACMA’s January 2007
Consultation on “Allocation of spectrum for new digital television services.” In this proceeding, Channel B
spectrum is proposed to be allocated for new and innovative digital services, such as mobile broadcasting, by
the end of 2007. We, therefore, urge the ACMA to ensure these parallel activities within the UHF band are
aligned and opportunities for mobile broadcasting services within Australia are made clear.
In conclusion, QUALCOMM believes that the band 2500-2690 MHz is of great importance for the
development of 3G technologies and their evolutions (such as HSPA+, LTE, UMB) due to its unique wide
bandwidth. 3G technologies are forecasted to comprise 95 percent of the world’s mobile Broadband
Wireless Access (BWA) subscriptions by the year 2010 whereas IEEE 802.16e, for example, is forecasted to
comprise 2.5 percent. 9 Strategy Analytics also projects there will be 518 million mobile BWA users
worldwide by 2010 and that HSPA and EV-DO will account for approximately 488 of those users. Further,
QUALCOMM supports the band segmentation plan proposed in Option 2 and believes that the other options
would not provide the expected benefits to either paired or un-paired operations. 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. QUALCOMM also proposes a possible alternative that accommodates
existing electronic newsgathering and outside broadcast services.
Should you have any questions, please contact me at +852 6348 6687 (mobile) or firstname.lastname@example.org.
Julie Garcia Welch
cc: Mr. Robert Hart, Director of Business Development, QUALCOMM Australia
See Document RSPG07-161at http://rspg.groups.eu.int/doc/documents/opinions/rspg07_161_final_op_digdiv.pdf.
Strategy Analytics “Beyond 3G: Looking for True Mobile Broadband,” November 2006.