The Office of Electronic Communications President’s stance regarding the use of mobile TV frequencies (e.g. DVB-H / Digital Video Broadcasting-Handheld).
1. The subject of reservation
The subject of potential reservation may entail radio channels within a band designated for first priority broadcasting), excluding 8 of DVB-T (Digital Video Broadcasting-Terrestrial) layers and 3 of T-DAB (Terrestrial Digital Audio Broadcasting) layers specified in the Geneva 06 plan.
These frequencies do not form a nationwide network. Instead they enable local services in selected cities to be launched. In so called “football cities” (table below) it is feasible to activate additional frequencies, which form the second layer.
The National Frequency Allocation Table grants that these frequencies should be used for terrestrial broadcasting as well as mobile terrestrial service on second priority basis. This is why interested parties may apply for reservations in the first priority or second priority service.
Owing to the fact that subject radio channels remain unused in both of the aforementioned coverings (DVB-T &T-DAB) and bearing in mind the importance of their effective use, it is possible to dispense these frequencies through a tender (tenders).
Regardless of the service, it appears to be particularly useful to make the most of the frequencies with the aim of providing mobile transmission services with multimedia content without determining their operation technical standard.
Admitting a particular type of service determines the frequency reservation conditions as well as the extent of fees applicable for frequency operation. Frequency operation in mobile service is, however, considerably more costly since the regulations concerning frequency operation fees have not been readjusted. (see point 4)
Within the framework of consultations the President of the Office of Electronic Communications is interested in particular in opinions pertaining to the issue whether subject frequencies should be allocated to terrestrial broadcasting service or terrestrial mobile broadcasting service.
2. Reservation approval procedure
In the face of significant interest in subject frequencies, the President of the Office of Electronic Communication states that there is a premise of the lack of sufficient frequency resources. As a result, frequency reservation will be completed by means of a tender.
In the current legal situation the reservation approval procedure is determined in the context of goals, intentions and modes underlying the application for frequency operation.
Peculiarity of DVB-H standard mobile TV, especially the fact that it is predominantly watched on a small size screen and the fact that such sessions are of a one time nature, taking the form of clips rather than full TV programmes clearly indicate that the market will aim to create a customized offer, adjusted to the reception mode and based on contents used in traditional TV but modified differently.
As a result, it seems apparent that using these frequencies to broadcast radio or TV programmes as understood in the light of the Broadcasting Act should be excluded as in such a case these frequencies would be utilized to duplicate the channels already available in other forms.
The President of UKE would like to bring up for discussion the following thesis: in mobile TV services, provided with the use of frequencies indicated below, not contained in the Geneva-06 plan, a new programme offer should be proposed, properly adjusted to this standard as compared with the terrestrial offer available in the analogue standard or on digital platforms. Then, the frequencies should be used to broadcast TV or radio programmes.
Both solutions, that is to say granting reservations in the broadcasting service intended to broadcast TV and radio programmes or in the land mobile radiocommunication service meant to offer multimedia services, do not require a competition to be organized as understood by Article 116 (1) (1) of the Telecommunications Act since there is a very clear provision stating that a competition is held for radio and TV programme broadcasting purposes. In other cases a tender should be organized.
Granting reservations for frequencies meant to be used for digital terrestrial broadcasting of content requires additional elements to be included in the reservation granting decision (compared to the reservation for the purposes of mobile services). Namely, the Telecommunications Law, in this regard calls for:
1) a specification of TV or radio programmes, which form a unified digital signal (multiplex signal) broadcast by means of the frequency intended to be reserved;
2) an overview of arranged programmes contained in the multiple signal which are mentioned in point 1, referred to from now on as ‘audiovisual components of the multiplex signal’;
3) a proposal of planned share the audiovisual components should have in the multiplex signal;
4) an area over which the multiplex signal can be distributed to be specified;
5) the level of transmission systems capacity use to be specified.
The degree to which TV and radio programmes should be specified has not been clearly defined by the Telecommunications Act, allowing therefore for various solutions to be accepted.
It is in this context that the President of UKE wishes to collect opinions from interested parties regarding the mode to set the aforementioned parameters, in particular the level of details to be included (e.g. programme name specification or programme genre specification).
The President of UKE takes the position that the abovementioned points should remain in accordance with the content of tender offers.
In case of frequency reservation to be used in mobile service, the contents to be sent in the signal are not specified. It is possible, however, to clarify the frequency operation conditions and commitments undertaken in the tender in such a reservation.
The President of UKE would like to submit the following issue for consideration: whether the commitments requiring specified, open, non-discriminatory, based on equality basis, wholesale capacity channels availability for various transmission kinds (the acquisition of multiplex capacity part) should be included as obligatory or optional in the tenders referred to in this document.
3. The criteria of selection
Under the Act, the tender selection criteria should:
The President of UKE presents the viewpoint that among selection criteria, the crucial one should be the one providing for free competition. It is interpreted as accepting commitments toward sharing the capacity of a constructed network with multimedia suppliers and entities offering multimedia content services to their clients in an equal and non-discriminatory way. Finally, it is also assumed that the competition criterion stands for transparent rules regulating the selection procedure of broadcasting infrastructure operators.
In case a reservation is granted for mobile, digital signal transmission which is used for multimedia purposes, the fee will be charged according to appendix 1 point 1 table 1 of the fee ordinance. It means that the fee will depend on:
For DVB-H standard devices, one-frequency channel in the operation area would amount to 224-240 thousand PLN annually for a station placed not higher than 40 metres above the ground. For stations exceeding this height, the cost might increase even by 40 %. It should be noted that the network operation area is the sum of base stations’ operation areas which the network is composed of, provided the area remains uniform and coherent. In the case presented, separate network operation areas equal to separate reservation areas (so called allotments), indicated separately beneath the table below.
For comparison, the cost of frequency operation reserved to broadcast RTV programmes digitally, in the DVB-T/H standard varies from 400 to 2400 PLN annually, depending on transmitter power and antenna size.
Till the ordinance regulating the frequency operation fees is amended, the extent of frequency operation fees in the mobile terrestrial service is a considerable barrier against utilizing this service to provide multimedia local services. Within the framework of experimental frequencylicence, it is possible to lower this fee by 50%.
Local range frequency channel plan
The channels in the table above have been selected to avoid collision with GE06, the transition plan as well as analogue stations. Additional channels have been selected for ‘football’ cities”. It has been assumed that station powers will not exceed 1 KW (exceptionally 10 KW). Moreover, orthogonal polarization has been assumed for analogue stations operating in proximity, which in most cases is a vertical polarization. A low C/I rate (signal/interference rate) for DVB-H (approx. 20 dB) should facilitate construction of extensive SFN networks. This is why the same channel was admitted in neighbouring areas. It should be noted here that channel 39 – in Bydgoszcz and Toruń, 44 – in Chorzów and Katowice, 55 – in Szczecin and Gorzów Wielkopolski and 54 – in Poznań and Kalisz should be granted to the same entity.
International coordination will be required by those cases in which the summary interference level exceeds approx. 46 dBmV/m on the border of the co-channel allotment DVB-T and 31 dBmV/m on the border of an analogue station’s reach with compatible polarization and 47 dBmV/m with orthogonal polarization. It appears that once the network is reasonably designed and limited to city agglomerations, fulfilling abovementioned conditions is by all means feasible. The channels which are currently used by armed forces of post-soviet countries should not pose a problem either since they have been planned only in the western part of the country. Unfortunately, probably it won’t be possible to add DVB-H stations to GE06 plan and so it will be impossible to use them as a pretext to reject the coordination of newly planned foreign stations. This dilemma is not dangerous since the usage level of these stations is so high that possible interference from foreign stations is improbable.
Invitation to consultations
The President of the Office of Electronic Communications invites all interested parties to forward their comments and opinions regarding the above standpoint till 29 February 2008.
Urząd Komunikacji Elektronicznej
Departament Zarządzania Zasobami Częstotliwości
ul. Kasprzaka 18/20