INVESTIGATION INTO THE USE OF 400 KHZ CHANNEL SPACING IN THE FM BROADCAST BAND

Request For Proposals - June 2007

Context 1. The Ministry of Economic Development (the Ministry) is responsible for management of the radio spectrum. As part of this role, the Ministry wishes to investigate the technical feasibility of using 400 kHz channel spacing in the FM broadcast band (88 MHz to 108 MHz). Services and Deliverables 2. A brief outlining the services and deliverables is attached as Schedule 1 of this RFP. Matters to be addressed in the Proposal 3. Proposals should include details on: The proposed methodology for providing the services and deliverables; including a summary of how information will be sourced and how stakeholders will be engaged; the type of information that the Ministry will be expected to provide; the key personnel in your team and a short curriculum vitae of each member outlining their relevant experience and their respective contribution to the project; a short description of your organisation, its strengths and capabilities and identification of previous work undertaken similar to that being requested in this RFP; a proposed timeline; all fees and other costs that will be payable, including fees payable by an subcontractors or other advisors that will be used in undertaking this work; and any real or perceived conflicts of interest and how these are to be resolved.

4. Proposals must be brief and factual (i.e. no more than five pages, excluding information on key personnel and your organisation). Expertise Required 5. The successful respondent will have a strong background and experience in radio engineering. Knowledge of the New Zealand radio broadcasting environment (from an engineering perspective), New Zealand radiocommunications legislation including radio licensing and spectrum licence certification and the International Telecommunications Union would also be an advantage.

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Timeframe 6. The successful respondent is expected to commence work on the services and deliverables as soon as possible after appointment. An interim report on the proposed criteria for the application of 400 kHz channelling is to be delivered by 20 July 2007. A draft final report covering all the work undertaken, as detailed in Schedule 1, is to be delivered by 10 August 2007. A final report is to be delivered by 24 August 2007.

Charges 7. All charges in the proposal must be in New Zealand dollars and exclusive of goods and services tax. The Ministrys preference is for a fixed charge contract to provide the required outputs with payment on completion to the Ministrys satisfaction. 8. The Ministry has a preference for expenses (including fees for any sub-contractors and advisors) to be included in the fixed price, or where this is not feasible, to be subject to an overall cap and prior approval. Submissions of Proposals 9. Proposals should be supplied to the Ministry in electronic form no later than 5.00 pm on 15 June 2007 emailed to radiospectrum@med.govt.nz. A copy in written form should be sent to: Manager, Radio Spectrum Planning and Policy Energy and Communications Branch Ministry of Economic Development PO Box 1473 Wellington Phone: 04 472 0030 Fax: 04 499 0969 Evaluation of Proposals 10. The Ministry expects to appoint the successful respondent by 1 June 2007. Proposal evaluation is the Ministrys assessment of the proposal and the respondents ability to perform the prospective contract successfully. While price is an important consideration to the Ministry, other criteria may influence the Ministrys decision to accept or reject a proposal. The Ministry may use any criteria, and place any weight on criteria, it wishes in its evaluation of any proposal. 11. The Ministry is not obliged to accept the lowest or any proposal, to acquire any of the services included in a proposal, or to discuss the reason why any proposal was accepted or rejected and reserves the right to accept none or any of the proposals. 12. The Ministry reserves the unrestricted right to, at any time: change any date, time, timeframe or any other aspect of this RFP process; suspend or cancel this RFP;

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accept, reject or not consider any non-conforming proposal, including without limit, any late proposal; consider any alternative proposal; interview any personnel of any respondent or other person as part of the evaluation process; and do any other act or thing that it sees fit in relation to this RFP.

Conditions 13. No legal or other obligation will arise between any respondent and the Ministry in relation to the conduct or outcome of this RFP process. Legal or other obligations between the Ministry and the successful respondent will not arise unless or until the Ministry and the successful respondent have entered into a signed agreement under the Ministrys standard terms and conditions for services, a copy of which are attached as a separate document. 14. The Ministry will not be liable for any direct or indirect damage, loss or cost (including legal costs) to any respondent or other person in relation to the RFP process and, in particular, in relation to the preparation of a proposal. 15. The successful respondent will work with and be accountable to the Ministry. 16. All intellectual property rights in the deliverables and any intellectual property developed in performing the services and delivering the deliverables will be owned by the Ministry. 17. The successful respondent must agree to treat any information provided by the Ministry in strict confidence unless prior written permission has been obtained in respect of the disclosure of that information. 18. Each respondent authorises the Ministry to collect any information from the respondent and relevant third parties and to use that information in respect of the respondent. Where that information is known to the respondent, it may request the Ministry to update or correct that information.
19. The content of any proposal provided to the Ministry may be subject to release under the

Official Information Act 1982. The proposal should clearly indicate those parts of the proposal which the respondent regards as commercially sensitive and confidential. It is not acceptable that the entire proposal be marked as such. The Ministry will take into account such indications when responding to requests under the Official Information Act 1982.

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SCHEDULE 1

SERVICES AND DELIVERABLES

Introduction
The contract will be to investigate the technical feasibility of using 400 kHz channel spacing in the FM broadcasting band. The current Frequency Modulated Broadcast (FMBC) spectrum licences will expire in 2010. To optimize the utilization of the band a new band plan has been developed for the post 2010 licences. The Government has agreed to identify four new channels for specified uses. However this is not possible in some areas using the current allocation rules that are based on 800 kHz channel spacing. The Ministry of Economic Development (the Ministry) wishes to investigate the technical feasibility of using 400 kHz channel spacing to enable the allocation of the four nationwide reserve channels.

Background
The radio spectrum used for FM broadcasting is in high demand. As Manager, the Crown wishes to ensure that the spectrum utilisation is maximized while also protecting the rights of existing rightholders. The Government desires to identify four new nationwide channels for specified uses. This is not possible in some areas due to there being no spare channels in the existing 800 kHz plan, so the feasibility of adding additional channels with a narrower 400 kHz spacing is to be considered. There are a number of challenges associated with reducing the channel spacing from 800 kHz to 400 kHz, including the following. Transmitter feasibility. Introducing 400 kHz channel spacing at the current transmitter sites may involve additional complexity in combining the new transmitter outputs onto existing antenna arrays. The alternative of installing additional antennas at existing towers may also be difficult due to space limitations. Receiver performance. Receiver selectivity is determined by the ability of the receivers to discriminate between two transmissions on adjacent channels. With receivers meeting ITU recommendation BS 412 this is theoretically possible at 400 kHz channel separation. However there are a number of secondary variables such as relative transmitter powers, antenna radiation patterns, the effect of over modulation, and the ability of the domestic receivers to tune to channels 400 kHz apart, all of which require close scrutiny to ensure this is practical in practice. Compliance with ITU Recommendations. It is important that any solution complies with the international ITU Recommendations since this is a requirement of the Radiocommunications Act. Future Proofing. There are a number of new technologies either available now or in the near future which may be compromised by reduced channel spacing. These include Radio Data Systems (RDS) and digital broadcasting such as In-Band On-Channel (IBOC). A discussion paper on VHF-FM Broadcasting1 issued in September 2005 provides useful background material on these technical issues when considering 400 kHz separation. For convenience the relevant paragraphs 9 to 20 are reproduced in Appendix A.
1

VHF-FM Broadcasting: Frequency Availability and Allocation Discussion Paper - September 2005

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A wide variety of opinions on the proposal were received in submissions to the Discussion Paper on VHF-FM Broadcasting and these were summarized2 as: There is support for changes that will increase the number of broadcasting frequencies, as long as it does not impact on the rights of existing licence holders without their agreement. As a result of the discussion paper and the subsequent submissions a Cabinet Policy Committee decision dated 26 July 2006 noted3 that: the Radio Broadcasters' Association submission did not favour the use of narrower frequency separations for technical and economic reasons but that other submissions generally supported provision of additional new licences through use of narrower separations. In December 2006 the current interim policy was published4, inter alia, which states that: There will be no decisions on changes to the current policies for frequency separation until after the technical planning for additional FM licences is completed in early 2007. The technical planning for additional licences using 800 kHz channel spacing and based on the current allocation rules has now been completed. The Ministry now wishes to investigate more fully the technical criteria by which 400 kHz channels separation may be able to be used to provide additional channels. The purpose of this contract is to establish the technical criteria and, if feasible, apply them to specific areas where the four new reserve channels cannot be allocated under the current rules. Two trials have occurred using 400 kHz channel spacing. One with co-sited transmitters at Skytower in Auckland, and one in Wellington using different sites with partly overlapping coverage. These trials were commenced on the expectations that, provided they were considered successful (i.e. that reception was satisfactory and that protection of other licences could be achieved), long term licences would be considered by the Ministry under existing policies. These long term licences have now been issued. Further details of these tests are available in Appendix K (pages 142 to 146) of the RBA Submission5 to the Discussion Paper on VHF-FM Broadcasting: Frequency Availability and Allocation1.

http://www.rsm.govt.nz/spp/vhf-fm/discussion/index.html 2 VHF-FM Broadcasting: Frequency Availability and Allocation Summary of Submissions May 2006 http://www.rsm.govt.nz/spp/vhf-fm/submissions-summary/index.html 3 Cabinet Policy Committee - Minute of Decision 26 July 2006 http://www.rsm.govt.nz/spp/vhf-fm/cab-minute-20060726/index.html 4 Policies for Licensing VHF-FM Broadcasting Services http://www.rsm.govt.nz/spp/vhf-fm/policies/index.html 5 Response to MED Discussion Paper Submission from RBA December 2005 http://www.rsm.govt.nz/spp/vhf-fm/submissions/34/index.html

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Work to be done

1. Definition of the problem

The consultant is to confirm the definition of the problem. This is to include the aspects covered in the background section above, the identification of any international experience with similar band planning and any other relevant issues. The definition should identify the specific performance parameters to be considered including certification requirements under the Radiocommunications Act (harmful interference and technical compatibility) and any other relevant factors such as receiver tuning issues, risk of additional intermodulation products etc. The definition should be based on existing VHF-FM system standards as defined within ITU-R but should also consider any limitations that might occur due to adoption of HD Radio (IBOC) sub-carriers in a 400 kHz channel environment.

2. Review of standards and tools

There are a number of planning standards issued by ITU which should be taken into account in this investigation. They include: BS412-9 BS415-2 Planning standards for terrestrial FM sound broadcasting at VHF Minimum performance specifications for low-cost sound-broadcasting receivers Transmission standards for FM sound broadcasting at VHF Technical basis for planning of terrestrial digital sound broadcasting in the VHF band Terms and definitions used in frequency planning for sound broadcasting Characteristics of FM sound broadcasting reference receivers for planning purposes (In particular clause 2 which refers to Radio-frequency protection ratios)

BS450-3 BS1660

BS638 BS704

The following ITU reports may also be referred to: BS946-1 BS1065 Frequency-planning constraints of FM sound broadcasting in band 8 (VHF) The RF spectrum of frequency-modulation sound-broadcasting transmitters

Attention is also drawn to the New Zealand Public Information Bulletin PIB 396 which covers the rules under which licences in bands under Crown management are engineered. The proposed band plan for all FMBC channels to be made available after 2010, based on the rules provided in PIB 39, is referred to as FM Band Plan (Version 7) 7 This list of documents is not intended to be exclusive and the consultant is encouraged to use any other standards, references and tools which may assist with the investigation. In particular this should include any recent standards relating to operation of digital broadcasting in the band 88 to 108 MHz. These inputs should be fully referenced in the consultants report.

PIB 39: Spectrum Licence Engineering Rules for Crown Management Rights Issue 2, 5 May 2005 http://www.rsm.govt.nz/publications/pibs/pib39/index.html 7 FM Band Plan (Version 7) http://www.med.govt.nz/templates/MultipageDocumentTOC____25589.aspx

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3. Development and recording of criteria

The consultant is required to develop a set of criteria under which channels could be assigned with 400 kHz separation. These criteria are to be based on sound engineering principles and comply with international standards and recommendations where possible. The proposed engineering criteria needs to be in a form and manner that will ultimately allow an engineer to certify spectrum licences in accordance with the requirements of the Radiocommunications Act 1989 (section 25). This work is not required to take into account any economic or political implications associated with applying such criteria.

4. Application of the criteria

Planning to date shows that the four channels which the Government wish to be identified are able to be made available in most areas using the current planning criteria. However there are four exceptions where consideration of 400 kHz separation may be the only method of achieving this goal. These areas are: Region Auckland Waikato Manawatu Timaru Main Transmitter Site Skytower Te Aroha or Ruru Wharite Mt Studholme

The criteria which have been developed for 400 kHz are to be applied to these areas to illustrate their application and if possible, resolve the additional channel requirement. Full details of the engineering calculations are to be provided together with comment on any technical issues which arise. Also required is an assessment of the accuracy of the engineering calculations and a risk analysis on the possibility of interference arising in practice due to the tolerances in the engineering analysis.

5. Proposed amendments to the 2011 FM band plan

The 2011 FM channel plan should be amended to show the additional channels made available by using 400 kHz channel spacing. The consultant is only required to consider the accommodation of the four new channels.

Items to be delivered
The following items are to be delivered as outcomes from this work: 1. An interim report on the proposed criteria for the application of 400 kHz channelling. The purpose of this report is to enable the MED to confirm that all issues have been taken into account although it is acknowledged that it will be a preliminary version at this stage. 2. A draft final report covering all the work undertaken as detailed above. The purpose of this report will be to enable the MED to review the outcomes and, if considered relevant, have the report peer reviewed. 3. A final report. This report will consider the feedback from the Ministry as a result of the review of the draft report and any other inputs which have arisen in the course of completing this work.

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APPENDIX A

Reproduction of paragraphs 9 to 20 of the MED Discussion Paper entitled: VHF-FM Broadcasting: Frequency Availability and Allocation issued in September 2005. The complete paper is available at: http://www.rsm.govt.nz/spp/vhf-fm/discussion/index.html

Technical Standards
9. The number of licences technically available in any area is governed by the planning standards adopted. These standards need to recognise the practical performance of both transmission equipment and receivers. Initial services were implemented with a frequency separation of 1.6 MHz, primarily to allow lower cost transmitter combining equipment at main transmission sites. The present standard is a frequency separation of 0.8 MHz, although separations of 0.6 MHz have been used in some circumstances. 10. Investigations and field trials have shown that with appropriate technical parameters it is possible to operate licences with a frequency separation of 0.4 MHz. Two trials have occurred, one with cosited transmitters at Skytower in Auckland, and one in Wellington using different sites with partly overlapping coverage. These trials were commenced on the expectations that, provided they were considered successful (i.e. that reception was satisfactory and that protection of other licences could be achieved), long term licences would be considered by the Ministry under existing policies. These trials have not led to any significant issues being raised by listeners and therefore the question of the acceptance of narrower frequency separations needs to be considered more widely. This will also assist in resolving the future of the specific trial licences. The wider planning issues are discussed in the following sections of this document.

Receiver Selectivity
11. The primary issue is whether typical receivers have adequate selectivity to discriminate the wanted signal from the unwanted signal. ITU-R criteria (Recommendation BS412-9) suggest that this can be adequately achieved at 270 kHz separation if the signal levels are always exactly equal. At 400 kHz the unwanted signal should be no more than 20 dB stronger than the wanted signal. Frequency Separation 0 (co-channel) Protection ratio BS 412 Figure 1 45 dB (Stereo) 36 dB (Mono)

270 kHz 400 kHz 800 kHz

Comment Wanted must be 45 dB stronger than unwanted signal for stereo reception 0 dB (Stereo or Mono) Wanted and unwanted signals may be equal -20 dB (Stereo or Mono) Unwanted can be 20 dB stronger than wanted signal -40 (Stereo or Mono) Unwanted can be 40 dB stronger than wanted signal

Assuming single, steady state interference

Separation is beyond range of Figure 1. Value is derived from Annex 2.

12. The relative signal strength values refer to the signals present at the receiver and therefore the transmitter sites used and power levels would need to be selected to achieve these values in the majority of the common coverage area. This generally requires transmitters with a 400 kHz frequency separation to use the same transmission site (be co-sited) and to have similar transmitter powers. To allow for potential different transmitting antenna (with likely differences in radiation patterns and polarisations), and marginal differences in propagation to the receiver, a maximum licensed power difference of 10 dB is considered appropriate.

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13. The ITU-R Recommendations caution against excessive modulation of transmitters and that the protection ratios specified are based on the normal bandwidth of transmitted signals. This may be relevant because there has been a tendency for some licensees in New Zealand to operate the transmitter deviation at the maximum permitted, and sometimes beyond that limit, in order to make the resulting signal "sound louder". 14. The ITU-R criteria also warn against using transmitters with a frequency separation of 10.7 MHz (plus/minus 0.2 MHz) in a common coverage area. This is understood to relate to potential mixing of incoming signals in receivers (RF or mixer stages) and creating of a potential interference signal at 10.7 MHz in the IF stages. It seems likely that this relationship and mixing would, if present, affect reception of any FM signal in the coverage area, irrespective of the actual FM signal being received. The trials in Auckland involve a 10.8 MHz separation (93.8 and 104.6 MHz) and to date no reports of adverse effects from this issue have been reported. This suggests that, provided reasonably comparable signal levels are used (i.e. there are not situations where a weak signal is being received in the presence of a strong overloading signal), the use of a 10.8 MHz separation will not be a source of difficulty. It would be prudent to avoid an exact 10.7 MHz relationship however.

Transmit Antenna and Combining Costs

15. Use of a narrower separation at a particular site would require either a separate transmission antenna or a more costly combining system. These costs are likely to vary from site to site but in some cases these may be significant. In such cases a licence may be not desired by potential broadcasters because of the cost of implementation, or may attract a relatively low value if allocated competitively. There may also be pressure to permit a non co-sited, narrow separation, licence to avoid higher transmit antenna costs. However the cost of antenna/combining infrastructure may be able to be shared across several new services. 16. Whatever the actual level of costs that might be incurred at a given site, they are an issue that will need to be considered by intending broadcasters in setting their budgets. This would apply equally for commercial parties and groups seeking government funding in some way. This factor is not seen as a matter that should prevent an otherwise available licence from being considered for allocation.

Receiver Tuning
17. Some radio receivers, typically bedside or portable models, are difficult to tune when stations are close together on the dial. This is especially true if the receiver is overloaded by strong transmissions from nearby transmitters. Analogue models will always require careful tuning when there are a large number of signals present. Anecdotal comments suggest that cheaper priced receivers have poorer performance including greater difficulty in accurate tuning. There are no standards for ease of tuning of receivers, but consumers do have a wide choice of radio receivers to purchase. Statistics on the numbers of radio receivers used in New Zealand, and any information on the ease of tuning, are not available, but it is likely that there is a greater, and growing, proportion of digitally tuned models in use. It is not proposed to limit the availability of licences based on what are largely subjective performance factors of receivers such as the ease of tuning on particular models of receivers.

Future Flexibility
18. The use of a 0.4 MHz separation may limit the practicality of adding new sub-carrier type services in future. These may include digital modulations in addition to, or instead of, existing modulations. Whilst digital systems, for example the IBOC system available in the United States, are generally designed to be compatible with existing services, these services can sometimes use a wider bandwidth that permitted under present licences. The nature of potential other new technologies are not known, and whilst some may be able to be accommodated by adjustment of the relative levels of the main signal and any sub-carrier, others may not be as easily accommodated. The basic question remains as to whether to favour increased numbers of new broadcasting services immediately or to favour maintaining future flexibility to better accommodate potential future technologies.

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19. It is noted that despite the availability of suitable technology for sub-carrier use, here has been little demand for this in New Zealand although Radio New Zealand and others have recently introduced the Radio Data Service (RDS) technology to provide programme identification and receiver re-tuning facilities for suitably equipped receivers. 20. Given that future technologies and their market acceptance are not known, and the necessary technical parameters are similarly unknown, it is proposed to base any new licences on technical parameters that accommodate the standard VHF-FM transmission, including an allowance for RDS technology. It is always possible for licence holders to commercially negotiate licence purchases/changes to accommodate pressing needs should they arise in the future.

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