This document provides a submission from Mississippi Consulting Pty Ltd in response to the Australian Communications and Media Authority's discussion paper on spectrum management strategy to address growth in mobile broadband capacity beyond 2020. The submission provides background on Mississippi Consulting and their expertise. It then summarizes key points from the ACMA discussion paper and provides comments, focusing on the need to consider 5G technologies and spectrum above 6 GHz to plan for future mobile broadband needs.

1. MISSISSIPPI CONSULTING PTY LTD
Submission to:
Australian Communications and Media Authority
Beyond 2020— A spectrum management strategy to address the
growth in mobile broadband capacity
Discussion Paper
23 October 2015
Document ID: MC2015/2

2. Mississippi Consulting Pty Ltd
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INTRODUCTION
Mississippi Consulting Pty Ltd welcomes the opportunity to respond to the
ACMA’s Beyond 2020—A spectrum management strategy to address the growth
in mobile broadband capacity Discussion Paper1
. Mississippi Consulting is a new
company established to offer technology consultancy services to organisations in
the broadcasting, media and telecommunications industries. The comments
made in our submission primarily address technology and spectrum matters
raised and questions posed in the ACMA’s Assumptions, Proposed Strategies and
related Work Program sections of the discussion paper.
About Mississippi Consulting
The Director of Mississippi Consulting has nearly three decades of experience in
the broadcasting industry in Australia and US. He has recently been with Foxtel
and AUSTAR, and previously with the United Nations in New York. He started his
career in broadcasting at SBS. Over the three decades, he has worked on the
design and building of television and radio production facilities, program
distribution networks, satellite and terrestrial program transmission, and
participated in the development of broadcasting and telecommunications
technical policy and regulation. He has contributed to Foxtel, the Australian
Subscription Television and Radio Association (ASTRA), AUSTAR and
Communications Alliance submissions responding to a large number of ACMA
discussion and consultation papers. Up until recently, he was the Chair of
ASTRA’s Technical and Planning Committee, which provides the ASTRA CEO and
Board with advice on technology matters affecting members. He is currently a
member of Australian Radio Study Group 4, the Communications Alliance’
Customer Equipment and Cabling Reference Panel and Satellite Services Working
Group. He has been a member of a number of Standards Australia Committees.
In addition, he is a member of two professional engineering societies, the
Institute of Electrical and Electronic Engineers (IEEE) and the Society of Motion
Picture and Television Engineers (SMPTE).
COMMENTS ON THE BEYOND 2020─ DISCUSSION PAPER
By way of further introduction, Mississippi Consulting would like to make some
general comments addressing why it thinks the ACMA should be more active in
giving consideration to 5G, in particular its likely demands on spectrum above 6
GHz.
The Beyond 2020 discussion paper explores in detail matters relevant to mobile
broadband spectrum management up to 2020 but less so beyond 2020. The
1
ACMA. “Beyond 2020—A spectrum management strategy to address the growth in mobile
broadband capacity” Discussion paper. September 2015.

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ACMA’s assumptions, proposed strategies and related work program relevant to
making sufficient spectrum available for mobile broadband into the near term
future are very well laid out. However, we feel the paper does not deal
adequately with the changes to the mobile broadband landscape that are likely,
if one was to be speculative or, could occur, if one was to be more circumspect.
The discussion paper refers to 5G in four separate sections. Firstly, in Mobile
broadband—Context where it is mentioned, under ‘Strategies to address mobile
broadband capacity growth internationally’, in the context of recent Ofcom, UK,
and FCC, US, publications which explore use of spectrum above 6 GHz.
Secondly, in Addressing mobile broadband capacity growth where states “there
is no set consensus on a definition of 5G”2
. Thirdly, in Proposed work program,
where, under Stage 0: Monitoring, the use of spectrum above 6 GHz for 5G
purposes is described as a subject the ACMA will continue to closely monitor.
And finally, in Appendix B—Mobile broadband terminology where the term IMT-
2020 first appears but interestingly is not used in the discussion paper.
In relation to developing technologies, these are addressed in Addressing mobile
broadband capacity growth where, under Advances in technology, matters such
as MIMO3
antennae related technology; techniques for improving spectral
efficiency and network densification are outlined. In this section, the ACMA
includes many good references to related research documents from a wide range
of organisations. This discussion in the paper is primarily aimed at highlighting
potential improvements in current 3G and 4G mobile broadband deployments.
Mississippi Consulting is of the view that a consensus is emerging on the
technologies that will comprise a 5G standard, and the spectrum that is likely to
be favoured. Moreover, because of this the ACMA needs to move beyond
monitoring 5G’s emergence and start considering potential spectrum options for
its deployment in Australia. The principal stakeholder industries in Australia, the
satellite and mobile broadband industries, need to be afforded an early
opportunity to learn of the ACMA’s thinking on 5G, even if that thinking is
initially speculative and develops over time into something more concrete; a
plan.
ACMA ASSUMPTIONS
Under Proposed mobile broadband strategies and work program ten assumptions
are listed upon which the ACMA intends to base a guide to review its mobile
broadband strategy. Of the ten, we have identified four that affect the subjects
we have chosen to focus on.
2
. Ibid, page 29.
3
Multiple Input, Multiple Output

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Firstly, assumption 3
3. Demand for mobile broadband services (and therefore capacity) will continue to increase
for the foreseeable future, though the rate of this increase is difficult to determine.
In Drivers for mobile broadband growth, the AMCA draws attention to the growth
in types of devices that will connect to a mobile broadband network. Many of
which may not be ‘mobile’ but fixed. Internet of Things (IoT) technology and its
more fundamental Machine-to-Machine (M2M) technology are included in the
applications, which the ACMA correctly states will help increase demand for
mobile broadband capacity. In relation to 5G, the discussion paper does not
mention Device-to-Device (D2D) technology. D2D is a technology that allows 5G
devices, as opposed to machines, to effectively form a mesh network. It may be
that such a network could be used to act in a way similar to Wi-Fi networks by
allowing some offload of capacity or certain OTT applications. For instance, if a
mobile device user wanted to send a message to another mobile device, and the
receiving device happened to be in the same mesh network, the message could
be sent over the network formed using D2D technology. A similar scenario is
outlined in the paper, “Cellular Traffic Offloading through Opportunistic
Communications: A Case Study.” 4
Using D2D in this way would help reduce
congestion in mobile broadband networks and therefore reduce demand for
capacity in the same way Wi-Fi does.
Secondly, assumption 4,
4. Australia currently has adequate spectrum available for mobile broadband purposes in the
short to medium term, but it is likely that in the medium to long term, additional spectrum
will be necessary.
In Currently available spectrum suitable for mobile broadband the ACMA
concludes that Australia has sufficient spectrum to meet the short to medium
term requirements of mobile broadband, and is very well placed regarding this
metric compared to other nations. Just one pointer to this is the outcome of the
2013 spectrum licence auctions for the 700 MHz and 2.5 GHz spectrum, which
resulted in the all the 2.5 GHz band being sold but three lots of 2x5 MHz in the
700 MHz band remaining unsold. Another pointer is mobile broadband cell
densification, according to an ACMA analysis referred to in Network
infrastructure and topology and Appendix C the density of mobile broadband
cells across all operators and spectrum bands has not increased greatly since
2007. The only exception being cells using the 1800 MHz band but there are
reasons for this outlined in the discussion paper. If there were pressure on
spectrum, it would be expected that operators would be expanding their
infrastructure but this does not seem to happening. This does not appear to be
the experience internationally where networks have decreased in size.
4
B. Han et al., “Cellular Traffic Offloading through Opportunistic Communications – A Case Study,”
Proc.5th ACM Wksp. Challenged Networks, 2010

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Consequently, the evidence appears to support the ACMA’s assumption that, at
present, mobile broadband spectrum is adequately provided for in Australia.
At its October 2014 meeting, the Communications Alliance Satellite Services
Working Group discussed the emergence of reports regarding the use of Ku and
Ka band spectrum for mobile broadband. One such report mentioned at the
meeting was an article in the September 2014 issue of the IEEE Spectrum
magazine5
. This article was on work that started in August 2011 on propagation
of, what is termed, millimetre-waves (mmW)6
in a number of metropolitan cities.
The conclusion from the studies was that use of Ku and/or Ka band spectrum
was viable for small cells using sophisticated beam forming and steering antenna
systems. Since the appearance of this article there have been several similar
studies supporting the same conclusion, viz. that spectrum previously once
considered unsuitable for mobile broadband use, because of difficulties with
propagation, is now thought suitable.
Under Strategies to address mobile broadband capacity growth internationally,
the discussion paper refers to the work of Ofcom in the United Kingdom and the
FCC in the USA in addressing the demand for mobile broadband spectrum.
In April of this year, Ofcom published its response to its Call for Input (CFI)
regarding use of spectrum above 6 GHz for 5G. In April, it published an overview
of the responses to the CFI along with some additional material7
. Further, Ofcom
commissioned Quotient Associates to study the potential suitability of bands
above 6 GHz for 5G mobile broadband systems. The Quotient Associates report8
,
published in April, identifies five potentially suitable bands: 66 – 71 GHz; 45.5 –
48.9 GHz; 40.5 – 43.5 GHz; 71 – 76 and 81 – 86 GHz; and 57 – 66 GHz. While
there were a range of criteria in arriving at these bands, one of the principal
ones was the need to allow for around 1 GHz of contiguous spectrum. In relation
to this, the report states, “there is good industry agreement that of the order of
1 GHz bandwidth will be needed with maybe as low as 500 MHz considered if
necessary” 9
. Based on information in the technical literature and related articles,
it does appear that the present target for above 6 GHz spectrum requirement for
5G is a contiguous 1 GHz per operator.
5
Rappaport, T.; Roh, W.; Kyungwhoon Cheun. Mobile's millimeter-wave makeover. IEEE
Spectrum. Volume 51, Issue 9. September 2014.
6
The article uses this term to refer to spectrum in the range 10 GHz t 300 GHz.
7
Ofcom. “Laying the foundations for next generation mobile services: Update on bands above 6
GHz”. 20 April 2015.
8
Quotient Associates. “5G Candidate Band Study on the suitability of Potential Candidate
Frequency Bands above 6 GHz for Future 5G Mobile Broadband Systems”. Final Report to Ofcom,
March 2015.
9
Ibid, Executive Summary, page iv.

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Almost in parallel with the Ofcom process, the US FCC, in October 2014,
released a Notice of Inquiry that is described as the beginning of an examination
into the potential for bands above 24 GHz to be used for mobile broadband10
.
The bands identified include: the 24 GHz bands (24.25–24.45 GHz and 25.05–
25.25 GHz), 27.5–28.35 GHz, 29.1–29.25 GHz, and 31–31.3 GHz, the 39 GHz
band (38.6–40 GHz), the 37/42 GHz bands (37.0–38.6 GHz and 42.0–42.5
GHz), the 60 GHz bands (57–64 GHz and 64–71 GHz), and the 70/80 GHz bands
(71–76 GHz, 81–86 GHz). Some of the bands are currently assigned for other
uses, e.g. the 27.5–28.35 GHz band is currently assigned for Local Multipoint
Distribution System (LMDS) a 1990s rooftop-to-rooftop-wireless cable
distribution system that is little utilised in the US.
Comparing the Ofcom and FCC bands there is some common bands, the 60, 70
and 80 GHz. In the lower bands referred to in the FCC Notice of Inquiry, i.e. the
24 GHz band to 39 GHz band, the amount of spectrum is all less than 1GHz. It
appears the FCC may not have used the 1 GHz target in its considerations.
Consequently, it might be reasonable to assume that reaching international
agreement on candidate bands when the matter reaches WRC-19 may be a
matter of some contention.
In May 2015, the ITU-T formed an IMT-2020 Focus Group to commence
development of 5G network standards. It aims to align its priorities with those of
the ITU-R. Within ITU-R, Study Group 5, Working Party 5D, a recommendation11
has been finalised as a result of its IMT Vision effort which sets outs a plan for
the ITU-R to “complete its work for standardization of IMT-2020 no later than
the year 2020 to support IMT-2020 deployment by ITU members expected
from the year 2020 onwards”12
. In addition, a report has been prepared on the
technical feasibility of using spectrum above 6 GHz for IMT-202013
. This report
refers to the work of the Rappaport team that was the subject of the IEEE
Spectrum article referred to above, albeit in considerably more detail.
The work done in the UK by Ofcom, in the US by the FCC and by WP5D on the
use of spectrum above 6 GHz for 5G/IMT-2020 perhaps draws into question the
basis of Assumption 4. We feel that in stating, “in the medium to long term,
additional spectrum will be necessary”, the ACMA should have drawn attention to
the international work on above 6 GHz spectrum.
10
. FCC. “Use of Spectrum Bands above 24 GHz for Mobile Radio Services.” Notice of Inquiry
October 17, 2014.
11
ITU-R Recommendation M.2083-0. “IMT Vision – “Framework and Overall Objectives of the
Future Development of IMT for 2020 and Beyond.” September 2015.
12
Ibid, page 17.
13
ITU-R Report M.2376-0, “The Technical Feasibility of IMT in the Bands Above 6 GHz,” June
2015.

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Thirdly, assumption 7,
7. The use of technology flexible technical frameworks and provision of sufficient tenure will
remain fundamental when designing spectrum arrangements including for mobile
broadband services.
In Tenure and technology flexibility, the ACMA effectively states that in relation
to spectrum use planning, it may need to optimise the band of spectrum for a
particular mobile broadband technology. However, what appears to be part of
the emerging specification for 5G/IMT-2020 is a target data rate of somewhere
between 1 and 10 Gbps, and a very low latency (less than 1 mS) aimed at M2M
use for the IoT applications. However, because the high speed and low latency
require wide bandwidths, achieving both of these appears to be only feasible if
above 6 GHz spectrum is used. Further, in our view, based on the technical
literature, 5G/IMT-2020 is emerging as an inflection point in the development of
mobile broadband technology. 3G and 4G technologies follow a more
evolutionary path than what 5G may follow. These days one often sees
references to disruptive digital technologies, and this appears to be as true for
5G as any other disruptive technology14
.
Fourthly, assumption 10,
10. Increases in mobile broadband capacity will continue to be met through a combination of
additional spectrum, improved technologies providing increased spectral efficiency;
increased network infrastructure and new network topologies.
The discussion in Conclusions regarding factors to address mobile broadband
capacity growth focuses too much on the tools utilised to provide the growth in
mobile broadband capacity, and here we understand capacity to mean the
number of devices times the data rate to each device. It does not address other
aspects such as the growth in types of equipment connected to the network to
fulfil a more diversified functionality. For example, 5G/IMT-2020 is emerging as
a mobile broadband technology supporting a much more diversified set of
devices. In fact, 5G/IMT-2020 is often referred to as more device oriented
compared to current 3G and 4G mobile broadband, this is evidenced by D2D
technology. It is our view that assumption four is too limiting, and it is so
because the ACMA has virtually not addressed the potential impact 5G/IMT-2020
may have on its ability to adequately plan for and manage spectrum for its
introduction in a 2020 timeframe.
ADVANCES IN TECHNOLOGY
Advances in technology is one of the four sections in the discussion paper where
the ACMA does refer to 5G specifically but here it is only to describe it as “a
combination of mobile technologies that support the throughput, latency and
14
F, Boccardi, R. W. Heath, Jr., A. Lozano, T. L. Marzetta and P. Popovoski. “Five Disruptive
Technology Directions for 5G”. IEEE Communications Magazine. February 2014.

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scalability requirements of next generation applications.” 15
It further states that,
“5G technologies are expected to exploit advanced MIMO technology with wider
bandwidths and higher frequency bands.” 16
Given the amount of attention given
to 5G by the UK and US spectrum regulators, and the efforts of ITU-R
SG5/WP5D, this seems to give short shrift to what we see as an important
emerging mobile broadband technology.
Earlier in the same section, the discussion paper briefly addresses Advanced
antenna techniques, i.e. MIMO technology. It is not clear to us how feasible it is
to use MIMO on mobile devices, in particular smartphones, in spectrum below 3
GHz. MIMO requires spatial diversity of the antennas on the receiving device. It
is, however, no problem when spectrum around, say, 30 GHz is used.
PROPOSED STRATEGIES
Strategy 1: Holistic approach to mobile broadband capacity growth
We are supportive of this strategy, except its focus is too narrow. The strategy
should refer to developing mobile broadband services, not just to catering for a
growth in capacity, but for a growth in applications, not all of which are mobile.
At this point, we would like to raise another emerging aspect of 5G, energy
efficiency17
. Implementing energy efficient 5G networks is gaining much
attention. While the relationship between spectral efficiency and energy
efficiency appears to be complex, so that the most spectrally efficient networks
may not also be the most energy efficient, the goal with 5G is to achieve both.
The D2D technology referred to above is seen as energy efficiency enhancing,
potentially as is massive MIMO.
Strategy 2: Transparent spectrum management planning process
In addressing Strategy 2, the only comment we would make is that, in saying
the ACMA seeks “to provide the right spectrum at the right time to address the
growth in demand for mobile broadband capacity” 18
, it again has not included
spectrum above 6 GHz in its consideration. Mississippi Consulting believe the
ACMA should be considering spectrum above 6 GHz as potentially being included
in the right spectrum for 5G, and now is the right time to do so. Such an
approach would be consistent with the ACMA’s intention “to develop a
15
ACMA. “Beyond 2020—”. Page 29.
16
Ibid, page 29.
17
Expressed simply, energy efficiency measures the bits transmitted per joule of energy
consumed.
18
ACMA. “Beyond 2020—”. Page 40.

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contingency plan by identifying a pool of potential spectrum options available for
mobile broadband at various stages in the process.” 19
Also included in the discussion under Strategy 2 is a Stages and consideration
for band re-farming section. This section outlines, in some detail, the process by
which any band, whether it is already used for mobile broadband or not, may be
re-farmed. Re-farming is a process, which results in a change of use of the
spectrum, and is only undertaken to ensure the spectrum is achieving its highest
value use. In relation to spectrum currently used for 2G and 3G mobile
broadband, it is perhaps likely that some may be re-farmed over the short to
medium term for 4G. We believe a question arises as regards the likelihood of
bands below 6 GHz being used or 5G. Not that 5G cannot be used in these
bands, but in order for the key performance parameters, i.e. low latency and
high speed, to be realised it appears that this can only be achieved by using
spectrum above 6 GHz, where bandwidths of around 1 GHz are potentially
available. Spectrum aggregation while included in the 5G feature set, the
technical literature suggests it may be impractical to aggregate many small
bands to achieve the necessary total spectrum.
PROPOSED WORK PROGRAM
Under Stage 0: Monitoring the ACMA states that the “use of spectrum above 6
GHz is being considered internationally for 5G services. This is being pursued as
a new agenda item for the WRC-19. The ACMA will continue to closely monitor
this issue and engage with stakeholders via the international preparatory
process”. 20
It is our view that the ACMA should, given the amount of attention
that the use of spectrum above 6 GHz has received in the UK by Ofcom, in the
US by the FCC, and in ITU-R SG5/WP5D, perhaps the ACMA should have started
looking at what options exist for Australia for use of above 6 GHz spectrum. It
would have been useful and reassuring for the industry to gain some insight into
the ACMA’s thinking, even if it were speculative in nature, as is the Ofcom and
FCC thinking, on what bands are potential candidate bands.
Departing from the 5G focus briefly, under Stage 1: Initial investigation the
ACMA discusses individual bands, in addition to those currently used, being
investigated for mobile broadband use. These consist of the 1.5 GHz band, the 2
GHz MSS bands (1980─2010 MHz and 2170─2200 MHz) and 3575─3700 MHz.
Licenses are currently being issued in the 2 GHz MSS bands for TVOB use. We
support the continued use of these bands for TVOB use, as there appear to be
few options for alternative bands to be used. If the 2 GHz MSS bands were to be
19
Ibid, page 41.
20
Ibid, page 49.

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used for mobile broadband, it is not clear what options the ACMA is proposing for
TVOB purposes.
The potential use of the 3575─3700 MHz band, immediately below the C-band
downlink band, has been a contentious issue between the ACMA and satellite
industry in the period leading up to WRC-15.
Moreover, the question arises, what is to be gained in examining the above
bands for potential mobile broadband use if Australia already has sufficient
spectrum to meet the short to medium term requirements of mobile broadband.
CONCLUSION
In this submission Mississippi Consulting has focused on the extent to which the
Beyond 2020 discussion paper addresses the potential spectrum for 5G mobile
broadband. By drawing attention to the international 5G work undertaken over
the last several years, Mississippi Consulting hopes the ACMA will consider
devoting increased effort to examining potential candidate band options for a 5G
deployment in Australia. In doing so, it hopes the ACMA will provide sufficient
time for consultation with the relevant industry sectors, when it does ultimately
propose any internationally harmonised candidate band options.
Again, Mississippi Consulting appreciates this opportunity to comment on the
ACMA’s Beyond 2020─ A spectrum management strategy to address the growth
in mobile broadband capacity. Mississippi Consulting would welcome the
opportunity to discuss the issues raised in this submission with the ACMA.
Please contact:
Terence Smith
Director
P: +61 (0)402 868 288
E: terence.smith@mississippiconsulting.com.au