In a far-reaching ‘think piece’, the British Entertainment Industry Radio Group (BEIRG) reflects on the changing landscape for wireless systems and the many live issues surrounding regulation.
The digital developer’s dream
With all forms of property development there are inevitably winners and losers. The developer generally wins, while incumbents, or existing tenants tend to lose. Rarely have tenants of re-developed land come out of the deal in a better position than before the re-development took place. Often they are promised much before they move, only to be severely disappointed when they arrive at their new home. However, by that time it is too late to go back and the damage has been done. The world of UHF spectrum, bands IV and V (470 – 862 MHz…and beyond) would appear to be no different.
Tools of the trade
Live music production, live theatre, sports events, TV content production as well as broadcasting, conferencing… In fact, a multitude of entertainment industry applications rely on multiple UHF frequencies to make and deliver all manner of artistic, sporting, political and innovative content to the masses.
The tools used are multi-channel wireless microphone and wireless in-ear monitor systems. To perform these tasks, many MHz of interference free spectrum is required. The critical importance and sheer existence of these activities goes largely unnoticed not only by the general public, but they are also often ignored and dismissed by those who are looking to re-develop this sensitive and highly valuable area of spectrum.
The mobile developers – mobile network operators (MNO)
Who wishes to re-develop the use of UHF bands IV and V? There is little doubt that mobile network operators in conjunction with economists and regulators have done a great job in convincing Government in general and individual politicians, in particular, that the value to be derived from the re-deployment of these frequencies for new mobile broadband service delivery will be significant.
Much is made of the ‘immense value to society’ that the release of these frequencies will achieve. However, no open discussion is entered into as to just how much money these same MNO are predicting that they will earn once they have secured the frequencies, rolled out their new networks, and their marketing teams have got to work on selling us all shiny new 4G phone services.
As stated, no MNO revenue projections are offered. But, behind the caring exterior, these are premier league businesses that have the money and resources to commission whatever ‘study’ is needed, that will ‘prove’ that the best use of these frequencies is mobile broadband, despite the consequences. And for sure, the roll-out of these new services will have consequences.
MNO need dedicated blocks of spectrum in order that it can be assigned; the current trend is by an auction process, solely to the delivery of their services. Once assigned, no other radio frequency users are allowed to operate in these blocks on the basis that other users of the same frequencies would cause interference to the licensed user, ie. mobile broadband customers. 790 – 862 MHz is currently in the process of being assigned on as pan-European basis as possible in order that the MNO and handset manufacturers can benefit as much as possible from the economies of scale that result from pan-European frequency harmonisation.
This leaves, in the UK for example, 470 – 790 MHz left for broadcasting – the delivery of TV signals to the general public’s rooftop antennas – and Services Ancillary to broadcasting/programme making, or what is now more commonly called programme making and special events (PMSE – wireless microphones and in-ear monitor systems).
At present the only activities permitted within the 470 – 790 MHz frequency bands are broadcast and PMSE. However, it should be noted that at many large events, the demand for PMSE frequencies already outstrips supply (ie. the recent Royal Wedding of HRH William Windsor and Kate Middleton being a case in point). And this is before the 790 – 862 MHz band is rendered off-limits for PMSE use due to its re-allocation for mobile broadband. Much of the 800 MHz band was licensed for PMSE use at the Royal Wedding, but will be off-limits for this use at the end of 2012.
So, with the 800 MHz band scheduled for sell-off and Ofcom already looking to sell-off another uniquely UK chunk of UHF spectrum, commonly referred to as the ‘600 MHz band’ (550 – 606 MHz), it is obvious that, from a PMSE perspective, we are already experiencing a future with a critical lack of access to required spectrum. How are large events to be covered in the future? With PMSE demand expanding and new users hungry to exploit the same resource! What’s the answer?
The white space developers – white space devices (WSD)
MNO are spectrum hungry, but at least you know where they are feeding. Quantity of spectrum available is one thing; quality of available spectrum is quite another.
To compound the MNO situation, new technologies are being developed that claim to be able to share the same frequencies as PMSE equipment without causing harmful interference to licensed PMSE spectrum users. This is far from proven, but device development and the desire to implement these new technologies would appear to be running ahead of any serious pan-European testing regime.
Regulators – charged with making the most efficient use of finite resources (a limited amount of frequencies) – are understandably enthusiastic about a technology that, if proven to work without causing interference to others, could potentially increase efficiency of spectrum use. But at what cost to existing services?
Regulators must have the strength of character to accept that, if it is proven that WSD and PMSE equipment cannot co-exist, then WSD should not be permitted to be deployed into UK, or indeed EU white space. While lessons may be learned from how things develop in the USA, it must be remembered that the EU white space environment differs substantially from that of the USA. Much less white space is available in Europe, and far more citizens and consumers rely on receiving their television pictures through an antenna. Both WSD and the deployment of 4G networks will undoubtedly compromise the ability of citizens and consumers to receive interference-free TV pictures in some areas.
How will politicians react when voters start to complain that changes in spectrum use, sanctioned by them, has severely compromised something on which they, the general public, have come to take for granted.
In the UK, one of the prime movers behind WSD technology and largely responsible for laying down the framework for their implementation and deployment while at Ofcom now works directly for a developer of these devices.
The last consultation from Ofcom in relation to the implementation of these devices, entitled ‘Implementing Geolocation’, and in no small part authored by the same now ex-Ofcom employee, seriously underplayed the number of these devices that might eventually be released ‘into the wild’.
An uncharacteristically short response time was also offered for this consultation document. A cynic might suspect that obfuscation had been used in order to hide the true extent and size of the market that these new developers of technology might expect for these types of devices. Obfuscation: both in terms of its real-term fiscal size and the timescale for the market to reach maturity. And all marched through quietly and at a pace to boot. Certain parties were alive to the concerns and were given a slightly longer period to respond. However, despite serious concerns raised, Ofcom still seems extremely open to the implementation of these devices.
If extreme care is not taken, the remaining white space spectrum could become so polluted that it will, in effect, become unusable by PMSE devices. If this situation is permitted to happen, then this would have a devastating effect on the UK entertainment industry and well beyond.
Serious real world testing of these devices is required, with results scrutinised by a truly independent authority. Results of testing in the USA have been patchy at best with wireless microphone manufacturers claiming that they have experienced severe interference, while WSD developers have claimed that there have been no problems.
Where does the truth lie?
In the UK to date, despite trials of WSD being undertaken in the Cambridge area and on the Isle of Bute, (not noted for its use of PMSE equipment) little or no effort has been made to attempt to engage the PMSE community as a whole in the testing process.
Spectrum regulators: blind to existing services?
While it is important that regulators are pro-active and alive to new developments, they should be wary of their responsibilities to protect existing incumbent users of spectrum.
Idealism and the desire to be an ‘early adopter’ should not be permitted to compromise an existing, active and growing industry sector that supports the production of a greater whole. PMSE, on the whole unseeingly, enables the production of exciting programme content, concert footage, sports events etc, to an audio standard that the general public has come to expect as standard. Any compromise in industry’s ability to capture world-class audio content should be regarded as wholly unacceptable.
Part of the issue here is that PMSE is so invisible to the naked eye, that we really will not miss it until it is gone.
Result? High definition video, with immobile, low definition audio. Surely, this must not be permitted to happen?
Regulators and politicians are understandably very keen to see progress and development in the area of spectrum use. The perceived gains to citizens and consumers from the deployment of new services is an attractive message to deliver to the masses.
Nevertheless, it is an uncomfortable truth that these new services will have at best a negative impact, and at worst a terminal impact on existing spectrum users’ businesses with consequences acutely felt not just by consumers of the arts but way beyond.
As the options for re-development of this vital resource are considered, perhaps the question is: just because in theory we can, does that mean that in practice that we should? Do the risks of excessive harmful interference to existing services outweigh the perceived benefits to citizens and consumers derived from new services?
It could be argued that in their haste to be seen to be progressive, regulators have given inadequate consideration as to just how disruptive these new services will prove to be. In the UK Ofcom will no doubt argue that all the correct consultations and impact assessments have been carried out and that all will be fine.
However, when difficult responses to consultations and studies which show that new services will be disruptive to millions of households are ignored, perhaps we should be asking whether this is one re-development too far.
What might our new home look like?
Regardless of changes, the show will still go on, right?
Of course it will; nobody is suggesting that the increasing loss of spectrum access will mean the end of the show. But with reduced access to available spectrum, and with what we do have access to constantly disrupted by interference from unlicensed devices, sadly our new home will look very much like our old home; remember the one we used to have back in the early ‘70s, in the days before multi-channel wireless systems?
Yes, the show will go on, but how much money will fans want to pay to see a show that looks like it was produced over 30 years ago? How many other industries do you know that would just accept being pushed out of its home and forced to go back to the way it used to work? So why should we? What are you going to do to stop the digital developer’s dream becoming the entertainment industry’s nightmare?