TVNZ

13 September 2007

Ian Hutchings
Senior Policy Analyst
Ministry of Economic Development
PO Box 1437
WELLINGTON

Dear Ian,

RADIO FREQUENCY AUCTION - 2.3GHZ AND 2.5GHZ BANDS

Further to our recent discussions I confirm that TVNZ will be making a submission in respect of the above proposed auction however our submission will not be completed prior to the deadline of 14th September 2007, due to the absence of key technical staff overseas at this time.

The issues which will be raised in our submission will include;

1. Linking in the 2.5GHz'O'Band' 

The Ministry's discussion paper understates TVNZ's dependency on the "O Band" for linking purposes and implications to TVNZ of the proposed changes.  TVNZ has fourteen "O Band" transmitters which are all in use for linking purposes.

There are no plans to replace these transmitters which are extremely reliable.

The greatest utilisation is by TVNZ's News department which has 8 transmitters (Auckland 4, Wellington 2, and Christchurch 2) are either attached or installed in moble news gathering vehicles. They are in constant use on a 24/7 basis, and this use is expected to increase once TVNZ launches the digital channel TVNZ7 in March 2008.

In addition, TVNZ's Broadcast Services department (formerly Moving Pictures) uses six "O Band" transmitters to provide live, real-time coverage of sporting and major events (eg. Maori Queen Funeral). The nature of these productions require linking services over many hours or many days.

TVNZ's "O Band" linking typically uses a Kordia 'high-site' to relay the signal to the closest major TVNZ facility. Accordingly, any change in mobile itinerant linking must consider not only the direct impact on TVNZ but also the associated costs of Kordia reconfiguring their 'high-sites' to operate at different frequencies.

2. Cost implication to TVNZ

The Ministry's discussion paper proposed that Broadcasters should bear the cost of replacing fully depreciated equipment.

TVNZ does not accept this proposition and considers it groundless. TVNZ has no plans to invest in or replacing existing transmitters; therefore any cost forced upon TVNZ as a result of vacating the "O Band" is an incremental cost to TVNZ.

As indicted above, the cost to TVNZ maybe both direct and indirect, and include costs required to be incurred by Kordia to reconfigure their 'high-site' network to support itinerant linking in the 2.7GHz or 7 GHz band.

4. Time to Vacate 2.5 GHz band

The Ministry's discussion paper proposes that the existing licences in the 2.5GHz band expire on 31 December 2008 and 12 months is a suitable period to "modify any fixed plant and procure new transmitters and receivers".

TVNZ does not concur with this assessment and seeks a cancellation date of 31 December 2010. (This date is consistent with the proposed date for licenses associated with mobile operated cameras which transmit pictures to a fixed point).

TVNZ does not believe 12 months is sufficient time to identify, source and install alternative equipment. The 2.7GHz "OX Band" is reserved internationally for military use and there is no readily available equipment which can be purchased off the shelf for broadcast use. The 7GHz band is an existing commercial band for which equipment is available , however the transmission characteristics are markedly different and higher power transmission characteristics are markedly different and higher power transmitters would be required (with adverse implications of size and weight).

As indicated above TVNZ's News is a heavy user of "O Band" itinerant linking currently and this is expected to increase significantly in March 2008. A move to vacate the 2.5GHz by 31 December 2008 is highly disruptive and maybe prejudicial to the successful launch of the new digital service TVNZ7. We are consulting with the Office of the Minister of Broadcasting  to ensure they are fully briefed on this risk.

5. Mobile Camera Use

The Ministry's discussion paper proposes a timeline for transition for mobile camera use of the 2.5GHz band by December 2010.