NZ Racing Board

RESPONSE TO RADIO FREQUENCY AUCTION AND TRANSITION PLAN FOR LICENCEES IN THE 2.3GHz - 2.5GHz BAND

Background

The NZ Racing Board owns and operates eight analogue Outside Broadcast Vans (OBV’s). These vans undertake filming of 950 race meetings per annum for NZRB’s television channel Trackside across 70 racetracks nationwide.

The race filming is undertaken using a mix of cabled cameras and wireless cameras operating off the “O” band. The wireless cameras operate from remote regions on the racetrack – camera towers up to 800m away from the OB and also the race start positions. There could be a maximum of 4 NZRB wireless cameras operating on a single raceday.

The NZRB is replacing its existing OB fleet with six new digital trucks currently under construction. These trucks will be commissioned over the period October 07 to Feb 08.

All trucks will be fitted with Thomson LDK 400 digital cameras. The deployment of cameras on raceday will again be a mix of cabled and wireless interconnectivity.

Across the country the OB fleet will be equipped with 20 wireless cameras all of which will operate on the “O” band. The NZRB has been aware of the MED’s proposed plans to auction the “O” band for future broadband and the consequential impact on users operating on the “O” band. The NZRB were also cognisant that the MED’s plans provided for the migration of “O” band users to move to secure spectrum on the “OX” band.

However the timing of NZRB’s OB build and the fact that the suppliers of cameras, Thomson Grass Valley, were not able to supply cameras capable of operating in the “OX” band has resulted in NZRB forced to commit to a purchase of 20 wireless “O” band capable cameras.

Thomson Grass Valley has provided an indication that they will be able to develop a retro fit for O band cameras to operate in the OX band, however this development is expected to take 18 months and will come at a cost of some $15,000-$18,000 per camera chain.

As a consequence the NZRB is keen to maximise its investment in the new camera technology.

Responses

For the most part the NZRB has little interest and therefore no comment to make in sections 3 to 6.

Section 7

Managed Spectrum Parks

NZRB is supportive of the concept of a Managed Spectrum Parks. However, given the nature of NZRB’s operation with 3-4 wireless camera links at any one of 70 locations nationwide it is thought that this type of configuration would most likely exceed the spectrum available within a MSP.

Section 8, Q9

Response on Transition Plan for Licensees in 2.5 GHz band

As stated above, the NZRB as part of its new OB Van build has purchased 20 Thomson Grass Valley wireless cameras that only operate on the “O” band.

Our contract for the build of our new OBV’s dates back to December 06. Understandably the design of the OBV’s meant that wherever possible TGV would install primary equipment that was TGV manufactured or branded, including cameras. Consistency of TGV equipment ensures a greater degree of “compatibility” across the technical design of the OBV.

Fundamentally NZRB was committed in December 06 to purchase 6 TGV wireless cameras. At this point in time however the Government’s plans around the auction of the 2.5GHz band was formative at best.

Notwithstanding the timing issue between entering into contract with TGV over the OBV build and the Government’s final decision on the 2.3-2.5GHz spectrum, the only choice NZRB had with its commitment to the initial purchase of TGV wireless cameras was a model that operated in the “O” band.

As a subset to the OBV build the NZRB had a need for a further 14 new digital wireless cameras for national use on racetracks. Despite some prior knowledge of the Government’s consultative plans around the 2.3GHz-2GHz bands TGV our contracted suppliers of cameras could only offer units that operated in the “O” band spectrum.

Furthermore our inquiries with TGV indicated that development of a wireless camera backs to operate on the “OX” band was at least an 18-24 month wait time given the commitments of its R & D department and the our niche requirement in the context of TGV’s global operation. Any development in this regard would also come at a cost estimated at $15,000-$18,000 per camera chain.

The option to purchase of an alternative camera brand that had “OX” band capability posed major technical and operational complexities across our OB operation with the incompatible mix of camera chains.

As a consequence a commitment was made to purchase 14 digital TGV wireless cameras in May 07.

Our investment in new digital wireless cameras is circa $2.2M.

Given NZRB’s significant investment in “O” band wireless cameras we consider a period of 5 years amortisation to be commercially practical.

In the consultation document there are references to 5 years being a considered and reasonable period for the effective life of newly purchased digital equipment.

Given this situation the NZRB would seek a sunset date for “O” band use of November 2012 rather than 2010 to be consistent with the statement of allowing 5 years operation of newly acquired equipment.