Summary of comments and feedback

Submitter: Downer New Zealand

Section 1.3 of the draft document – notes an error in CTCSS definition.

This section contains an error for CTCSS: it should be "Coded" not "Control". (as is correctly stated in PIB 38, page 37).

This has been corrected.

Submitter: Tait Radio

Block and Group plan for TD band

Notes the block assignment for the TD band (page 174 in PIB 23, and referred to in PIB 58) is unworkable practically, since TX intermodulation products are designed to fall on the corresponding Rx frequencies. 

Transmitters evenly spaced in frequency can result in undesirable intermodulation products in any band (not just TD). The Ministry will consider reviewing the rules in PIB 38 to clarify that, while the block plan must be used, channels don’t have to be assigned in sequential order. 

Submitter: NZ Motorola

Pages 12-14, Table 3 – definition of ALL

Notes that a definition of the term "ALL" may be helpful.

A definition for the term ALL has been added.

Page 29, section 4.5 – punctuation error

Notes the last two sentences should be concatenated with a comma between them.

This correction has been made.

Submitter: Craig Molloy

Section 9.4.1 – Minimum distance separation between repeaters

Supports reducing the minimum distance allowed for PRS repeater distances to 5 km as indicated in the CB General User Licence Discussion Paper. Referring to experiences following the Christchurch earthquakes, notes a need for a change in the way PRS repeaters are licensed. They can provide for effective communication with friends and family while also easing the communication load on cellular networks during power outages.

Considers the current allocation of one PRS repeater per 20 km very restrictive in how radio communications can be set up. Having the ability to set up more sites to support PRS repeaters will greatly help in future natural disasters.

Section 9.4.1 PRS repeaters has been updated to reflect the outcomes of the consultation.

Submitter: ZL HAM

General comment about document

In principle, ZL Ham members agree with PIB 58, its purpose and objectives. It appears to cater for the interests of the Amateur Service and any future Licensing Agency needs it may have.

Submitter: Anonymous

Section 3.11 Mesh Networks – Disagreement with the operational policy on Mesh Networks

Considers that Mesh Networks are an efficient use of spectrum. Notes that there is not an alternative spectrum option for Mesh networks. Suggests providing 25 kHz, 12.5 kHz and 6.25 kHz channels in EE, JL and upper F bands, limit use to SCADA, limit EIRP to 14 dBW, engineer for TLA, license using LS1 / LS2 and require that systems must tolerate interference.

The Ministry has changed the wording from “inefficient” to “inappropriate”. However, mesh networks need to be appropriately licensed, and duplex repeater bands are not the appropriate category as mesh networks are not land mobile repeaters. These systems can be licensed as fixed services and there are many UHF bands available (listed in PIB 22 ‘Fixed Service Bands in New Zealand’). If these systems can tolerate interference, TT channels are available as well as bands in the General User Radio Licence for Short Range Devices.

3.14.2 Mobile Operating Area – Disagreement with the stated levels

Many operators rely on secondary coverage < –95 dBm for their rural communication needs.

PIB 38 refers to the primary coverage as being ‑95 dBm; anything outside that coverage is considered fortuitous. The coverage area within the ‑95 dBm contour is protected from signals greater than ‑106 dBm. This has been an accepted criteria in use since before 1980. Stray mobiles using fortuitous coverage can cause interference to other land mobile systems. The Ministry does not expect significant change from publishing this limit in PIB 38.

3.15.1 Shared simplex – ”land grab” mentality on simplex

Observed a “land grab” mentality with regard to “All NZ Simplex” assignments with some operators populating one head licence with multiple simplex channels.

Considers the policy needs to be clearer, and if necessary more prescriptive, with regard to “a reasonable number of channels”.

This section has been expanded and an example provided.  Shared simplex licensing arrangements are flexible and Approved Persons need to make some judgments. Approved Persons must follow the rules in this document and in PIB 38, noting that PIB 38 has a section on 'Efficient Use of the Spectrum Resource'. 

Disagreement with the annual fees structure

Considers that fees structure encourages poor licensing behaviour and is seriously flawed. Considers the current licence fee structure is distorted with regard to EIRP, bandwidth and operational area of use. These distortions are impacting on the future availability and opportunity to access spectrum. Recommends:

-New fees have a “Crown Resource Rental” component that factors in equitably the key elements of EIRP, Bandwidth and Operational Area components.

-Apportionment of other annual RSM costs would make up the balance of the net individual licence fee amount.

-GURL’s funded by a separate appropriation from the consolidated fund to remove any cross subsidy.

Fees are outside the scope of this document. Fees are set on a cost recovery basis. The next fees review is planned for 2015–2017.In addition, a project in 2012 will examine GURL's and the possibility of an appropriation.

3.15.3 Crane Control and Bush Winch - Disagreement with short term requirement for Bush Winch

Recommends that the forestry industry be exempted from the “Fixed Term” requirement and that conditions be added to each licence instead.

3.15.3 Crane Control and Bush Winch – recommends conditions for Bush Winch licences

A coded squelch system and/or CTCSS tone A12 (186.2 Hz) shall be used on all radio apparatus covered by this licence. Where CTCSS is not used due to a conflict with the operational needs of the licence there will be no protection from interference from external sources.

The equipment covered by this licence is to be used solely for the purposes of communications associated with "Forestry Bush Winch & Log Hauler" activities at the location or area shown on the licence.

Should the location be varied, “mandatory” re-engineering and modification of this licence is required.

The Ministry notes that the licence conditions to go on licences are specified in PIB 38, and that these sufficiently cover most of what is mentioned in the suggested conditions. Note that licence conditions can only restrict the terms of the licence and are not for providing information. The licence conditions specified in PIB 38 restrict the licence to Bush Winch only and give some requirements for CTCSS for licences covering analogue.

3.15.3 Crane Control and Bush Winch – suggested reduction in allowed EIRP

Suggests that the Ministry consider limiting the transmit EIRP to 6.9 dBW.

Approved Persons have flexibility to allocate less power to a licence where appropriate. Limiting the EIRP would be unnecessarily restrictive.

3.15.3 Crane Control and Bush Winch – other industries

Considers the document does not adequately provide for the following industries:

1. Port companies
2. Mobile cranes
3. Site specific cranes, eg Glenbrook Steel Mill.

Port companies and site specific industries that operate permanent cranes may only be approved by dispensation on a case-by-case basis. Mobile cranes may apply for a crane control simplex licence for a specific site where they are operating. There are also some Mobile Crane frequencies available in ‘Mobile Bands of New Zealand’ (PIB 23). These are are shared with other users so some level of degradation can be expected. 

3.12 PSRFMG group

Is concerned with that the PSRFMG approver has a conflict of interest. Suggests the task should be given to someone objective and impartial.

The PSFRMG is an organisation separate to the Ministry and it has responsibility for how it manages access to certain bands by its membership. Concerns about conflict of interest should be directed to the PSRFMG.

Submitter: Radio Broadcasters Association

4.2 Studio to Transmitter Links

Need for a planning policy

Acknowledges the need for a planning policy to limit any radio licence to appropriate and sensible use. Suggests that the PIB 38 rule on preserving site sense is adequate for this purpose.

The Radio Licence Certification Rules (PIB 38) Section 2.3.3 outlines a rule for ‘Onsite Compatibility’. This refers to preserving the current site sense but does not fully address the concerns about STL transmitters at sound broadcasting sites. For conventional fixed services, the first user on a site sets the site sense with the rest of the users having to follow that sense.

4.2 Studio to Transmitter Links

Criteria for STL denial inappropriate

Notes several members’ stations have obligations for civil defence. Considers STL’s are required for meet these obligations for reliability reasons.

Considers that traditional copper networks are becoming unavailable and unsupportable. Notes that while microwave linking is sometimes an alternative, it does not meet MED’s spectrum efficiency objectives.

In this context, the following rules are considered inappropriate:

3.    In a Defined Metropolitan Area (DMA), STL links must have the transmitter located at the broadcasting studio and the receiver located at the sound broadcasting transmission site. No intermediate links are permitted. "

Considers that prohibiting intermediate links in DMAs would deny legitimate use of STL bands by radio broadcasters.

Suggests the Ministry develop more appropriate criteria, and proposes some alternative rules (see below).

The Ministry notes that large broadcasters are operating nationwide radio networks and a variety of telecommunications systems are used for distribution. The Ministry is seeking to ensure that the STL bands, as one option, are used for their provided purpose, which is for transporting programmes from studios to broadcast transmitter sites. 

The use of STL transmitters at sound broadcasting sites results in spectrum denial for this purpose. The Ministry notes, however, that this is unlikely to be problematic at AM broadcasting sites. The use of STL transmitters at FM broadcasting sites is undesirable because of demand for STLs at these sites. However, in order to allow for rare cases where an alternative solution is difficult, the Ministry will permit STL transmitters to be located at FM broadcasting sites in the STL bands other than the 841 ‑ 851 MHz KL band, provided the agreement of the site manager or other site users can be obtained in accordance with section 2.3.3 “On Site compatibility” of the Radio Licence Certification Rules (PIB 38).  Note that a new rule has been added stating that all sound broadcasting sites will be considered as an STL receive sites.

The Ministry acknowledges that the hilly terrain in many areas means that a single-hop link between a studio and a broadcast transmitter may not be possible, and has therefore removed the restriction on no intermediate links. However, there is a need to ensure that the band provides as much utility as possible for its provided purpose, and it is therefore appropriate to ensure use for on-linking is justified, particularly in areas of high demand. The Ministry considers DMAs to be an appropriate proxy for areas where there is likely to be high demand for STLs. 

4.2 Studio to Transmitter Links

Proposes that at least one terminal (end) of an STL licence must have either the transmitter located at the broadcasting studio or the receiver located at a sound broadcasting transmission site. That is, not more than two hopes are permitted.

4.2 Studio to Transmitter Links

RBA proposed rule

Proposes that, if the proportion of STL licences with receive locations at sound broadcasting transmitter site is 80% or more of the total allocated STL channels available for linking into that site, then no further STL transmitters be licensed at that site.

These rules don’t fully address the problem where a single STL transmitter at a sound broadcasting site can sterilise the band or a large portion of it. The rule restricting location of STL transmitters has been limited to FMBC sites and the new KL (841‑851 MHz) band as it is recognised many of the existing bands are reasonably mature and could provide an option for on-linking from a FMBC transmit site where compatible. 

The Ministry agrees that variations to site sense should be in accordance with section 2.3.3 “On Site compatibility” of the Radio Licence Certification Rules (PIB 38), which requires a written agreement from the site owner or other site users.

4.2 Studio to Transmitter Links

Proposes that, in general, the site sense for STLs is to have the STL receive location at the site where radio broadcasting transmitter licences exist. Any variation to the nominal site sense would be by exception and would need to be justified in documentation including support from the site owner, noting the PIB 38 provisions that this documentation will be filed in the SMART licence record.

4.2 Studio to Transmitter Links

Finds definition of each DMA is not publicly available.

Definition of DMAs are in the current Radio Licence Certification Rules (PIB 38), Appendix B, table 19. Footnote 4, section 4.2 (Studio to Transmitter Links), page 28 gives the reference for DMAs.

4.2 Studio to Transmitter Links

RR regional restrictions not sufficiently described

Considers the majority of Radio Reporter licences have an area of operation specified. Recommends that MED ensures that these areas have a common publicly available definition. For example, Territorial Authority areas are commonly used. This complex polygon should be loaded into SMART (RFR) if it is to be used.

Additionally, MED should specify whether the Statistics New Zealand definitions are the ones being used or not.

Territorial and Regional Local Authorities are defined external to this Ministry. Maps of these local government boundaries are available at http://www.lgnz.co.nz/lg-sector/maps/. 

4.2 Studio to Transmitter Links

Unexpected change to 915 – 921 MHz amendment policy

Considers that crucial licence modifications in the 915 ‑ 921 MHz band should be able to be made, e.g. studio relocations. 

This wording has been changed to allow modification of existing licences on a case-by-case basis for situations such as a studio move.

Note that the band is closing with licences having to tolerate interference from December 2015. 

Submitter: Telecom New Zealand

4.2 Studio to Transmitter Links

Concern of interference from multi hop STLs particularly hill top sites

Notes that STLs are being used for multi-hop links rather than their purpose of transporting programmes directly between a studio and transmitter. This causes a noisier radio environment for hilltop cellular sites, and is of particular concern to Telecom with respect to its XT base station receivers using spectrum adjacent to the new 841-851 MHz band.   Placing STL transmitters at broadcast sites or other high sites in this band may increase interference risk to nearby Telecom XT base station receivers, which provide wide area coverage with less service overlap than an urban scenario. Such sites therefore require quieter environments. Notes that some hill top FMBC sites are close to Telecom XT base stations.

Limitations have been created to not allow new STL transmitters at FMBC (often high altitude) sites in the KL (841 ‑ 851 MHz) band. However, an additional hop will be permitted between studio and transmitter sites in light of difficulties caused by hilly terrain. This must be justified in DMAs. Certification and engineering rules that Approved Persons must follow when licensing STLs in the 841 ‑ 851 MHz band are to be incorporated into PIB 38. These rules will include specific technical requirements for the protection of Telecom cellular base stations in accordance with the agreed “Interface between cellular mobile service (825-840 MHz) and fixed links (841-849 MHz) - Coordination Guidelines’”.

Submitter: Tony Brown

1.8 Geographic Coordinates – Concern with NZTM

Considers that geographic coordinates should still be accepted in both NZMG as well as NZTM formats, as NZMG will continue to be used for some time given people still have the NZMG maps.

New Zealand has changed to the new geodetic datum GD2000 and has changed map series to NZTM. The Ministry is following this change along with the rest of government. http://www.rsm.govt.nz/smart-web/smart/page/-smart/domain/reference/MapReferenceConverter.wdk

2.4.1 LA Recommendation – Slow LA Response

Considers that the LA process works fine, except some LA's are very tardy in processing applications, which causes delays and requires chasing up..

Generally we have observed a response in a reasonable timeframe. To assist follow-up, the Ministry plans to publish contact details for LA’s in the approved persons section on the website.

4.2 Studio to Transmitter Links– use of downlinks

Considers downlinks should be allowed, but only for links to MFBC sites in the 400 MHz band. Notes that downlinks from a busy Tx site deprive adjacent uplinks up to this site where frequencies are scarce. Suggests as an alternative that MED provides a separate band for composite for this purpose.

The Ministry agrees that downlinks at transmitter sites results in spectrum denial for uplinks. The rule not allowing STL transmitters at broadcasting sites (downlinks) has been restricted to the KL band (841 ‑ 851 MHz) FMBC sites. In addition, all sound broadcasting sites are now considered as STL receive sites for the purposes section 2.3.3 “On Site compatibility” of the Radio Licence Certification Rules (PIB 38). To locate an STL transmitter at a sound broadcasting site a written agreement from the site manager or other site users must be obtained.