Radio Spectrum: Accessibility or Entertainment?

Radio Spectrum Management have been circulating a consultation and discussion document, “Preparing for 5G in New Zealand – Technical Consultation”.  The “gotcha” in the fine print is that one option being considered is to move the IMT Band (Industrial & Medical Telemetry Band) as well as make some provision for 5G into the 600MHz Band.

That is the band that most churches who have just bought new wireless microphones will now occupy, having been pushed out of the 700MHz band a couple of years ago.

My company has made the following response to the Radio Spectrum Management discussion document.  It is based on a proforma response originating with WUNZ (Wireless Users NZ), but I hope I have managed to value add the thought that there is more to life, and value, than entertainment and sports events and that some of the people impacted by “minor” tinkering with the spectrum are the ones with least capacity to pay for the consequences, but who provide valuable services to society at large.

The discussion paper can be found here – https://www.rsm.govt.nz/projects-auctions/current-projects/preparing-for-5g-in-new-zealand-technical-consultation

Response: Preparing for 5G in NZ

From System Design & Communication Services.

This response relates particularly to the Discussion Document questions 1, 15 and 16. 

As a current user and supplier of radio microphones and in-ear monitors that operate in the 600MHz band, I would be an affected party if this frequency band is reallocated for IMT/5G usage.

Radio microphone users would lose 76MHz of nationally available spectrum from this 600MHz band. Currently, there are no other spectrum bands that appear to offer this same amount of spectrum as a contiguous available block nationally throughout New Zealand.

As a specialist supplier to the non-profit and religious sector, I would point out that this sector, in particular, is ill-equipped to make another forced “fork-lift upgrade”, and the response of many of my clients will be simply to do without such systems.  The immediate consequence of this will be an immediate degradation of service to the many hearing-impaired and disadvantaged persons to whom my clients provide social welfare services (and in extreme cases may even lead to cessation of service provision entirely). 

At another level, removing capacity to operate relevant equipment in the 600MHz range may cause some of my clients to lose their ability to comply with their obligations under the Building Code and Disabilities Code.  Compliance with these may involve providing Hearing Augmentation systems and the audio source for such systems will be a microphone.  In many cases, the functional and logistic requirements of the service being delivered dictate that this microphone should be a wireless device.  Loss of 600MHz systems may require not only replacement or modification of the microphone but may require replacement and/or modification of the entire Hearing Augmentation system, possibly requiring extensive associated building works.

The benefit of such social and potentially intangible services provided by the non-profit sector is not as easy to quantify as the glamour entertainment sectors of Music, Sport and the Arts.  However, the social and economic benefits of the sector are not inconsequential.

I request on behalf of my non-profit clients, that Radio Spectrum Management adopt the following recommendation as a guiding principle of re-planning NZ spectrum;

  • Ensure that sufficient usable spectrum, preferably in the existing 600MHz band, is preserved for radio microphone and in-ear monitor usage at the community level for educational, health-related and social good purposes by non-profit and religious entities.

I also request that Radio Spectrum Management carefully consider these comments and the following recommendations should you resolve to reallocate the 600MHz band and therefore require current radio microphone and in-ear monitor users to re-acquire or modify existing hardware to alternative frequency bands.

  • Provide monetary compensation to affected users who acquired or modified hardware in direct response to the 700MHz spectrum sell-off.

Ensure that sufficient usable spectrum is preserved for radio microphone and in-ear monitor use at large scale events, such as concerts, festivals, theatre productions, red carpet movie premiers, and sporting events.  This provision should make allowance for the fact that multiple users and/or suppliers are operating concurrently at some of these events types.

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