7. List of questions

The questions posed on LPFM GUL requirements in this document may have alternative solutions to those discussed above.
Submissions that include reasons for disagreement with any analysis or proposals in this document and offer alternatives together with reasons for their choices are welcome. Provision of evidence and quantification that can improve the analysis is also welcome.

LPFM Band Transition Proposals

Question 1

Is the proposal to provide a GUSL for LPFM for the period to 2 April 2011 appropriate? If not, why not?

Question 2

Are there aspects of the transition plan you wish to change? What are they and how would they improve the plan?

Protection for Landmobile Services

Qustion 3 

During the LPFM transition period, should MED allow use of the 87.5 - 88.0 MHz band for LPFM services but prohibit transmissions on specific frequencies in specific geographic areas? 

Question 4 

Is the proposed 50 km transmitter minimum distance separation appropriate? If not, is there a better means of minimising the potential for LPFM to cause interference and what are its benefits?

Protection for Broadcast Services

Question 5 

Do you consider the 50 km and 400 kHz separation criteria appropriate for protection of broadcast services? What other criteria is appropriate? Please identify the specific concern and the additional safeguard sought?
If you consider the protection provided is excessive, please identify and explain the level of protection that you consider would be appropriate?

Protection for Aeronautical Services

Receiver Intermodulation

Question 6 

Do you agree with the proposed LPFM exclusion zones to protect aeronautical navigation services? If not, what specific measures do you consider appropriate?

Protection from Transmitter Intermodulation

Question 7 

Do you agree with MED’s proposal to mandate the use of transmitter–antenna isolation devices based on the following separation distances:

1. Everywhere; or
2. Within 100m of other LPFM transmitters; and
3. Within 100m of other transmitters operating pursuant to a radio licence in adjacent frequency bands (75 - 87.5 MHz and 108 - 137 MHz); and
4. Within 2000m of any licensed VHF-FM broadcast service?
    

General LPFM Transmitter Issues

Other Transmitter Unwanted Emissions

Question 8

Do you agree with the LPFM transmitter unwanted emission limits being repeated in the LPFM GURL?

Question 9 

Are there alternative options that will provide equivalent or better protection from the transmission of excessive unwanted emissions and prevent harmful interference to aeronautical COM and other services?
If so, what are those options and how are they better?

Transmitter Frequency Stability

Question 10 

What other changes should be implemented to improve the protection of adjacent band licensed services from transmitter frequency stability problems?

Mobile LPFM Transmitter Issues

Question 11 

Do you agree with the use of LPFM exclusion zones adjacent to airports and helipads for the protection of low flying aircraft, as identified in Attachment B – Proposed LPFM GURL and the Attachment C – Proposed LPFM GUSL?
Is there a better means of achieving the equivalent protection? If so what are they and how do they achieve the protection?

Question 12 

Do you agree with the proposal to prohibit LPFM transmissions from aircraft? If not, why not?