In a response to Ofcom that has been published today, the multiplex operators question the need to clear the band stating they were "not convinced".
Acknowledging that "consumer support for aerial installations" will be needed, they stated that "every effort should be taken to minimise aerial group changes".
Rejecting Ofcom's analysis on the clearance plan so far, the operators state "Ofcom may have significantly underestimated the extent and cost of aerial replacement works that are likely to be required as a result of 700 MHz clearance. DTT viewers should also not suffer from interference caused by new mobile services in 700 MHz spectrum – with the costs of interference (including filtering, guard bands and installation support) borne by the mobile operators or Government."
High or low frequency?
Ofcom maintains that the 700 MHz band is needed to create enough capacity for mobile data demand in the future. However, with higher frequencies also soon to be made available, including two frequency bands used by the MoD, the multiplex operators point out that "the higher frequencies would offer a similar benefit to mobile operators because we believe that congestion is likely to materialise in densely populated urban areas. The amount of spectrum available in 700 MHz would deliver insufficient capacity, and therefore other high frequency bands – with more bandwidth availability per operator – would be better suited for mobile broadband capacity purposes." They argue that high frequency capacity for local wi-fi networks should be utilised first. Other higher frequency bands could offer additional capacity targeted in locations where a lot of data is consumed and be used before the TV frequencies need to be cleared.
The operators also note that a clearance of the 700 MHz band would be very costly and would require equipment that has only just recently been installed at digital switchover to be replaced. They note that the following would need to be done:
- The construction of new transmission antenna systems at a number of high and medium power transmitting stations – where it would otherwise be impossible to meet coverage requirements using existing antenna systems.
- The potential construction of temporary (or permanent new) structures at a handful of transmitting stations to facilitate the re-engineering of existing antenna systems. There may also be a need for construction of new relay sites to preserve coverage – this was necessary at DSO and is under consideration for 800 MHz clearance.
- The replacement of combiner systems at the vast majority of the UK’s transmitting stations.
- The installation of temporary transmission systems to permit the re-channelling (re-tuning) of existing transmitters and the switchover to these frequency changed systems (and the subsequent removal and relocation of temporary systems) as part of a regionally phased switchover programme in order to ensure the continuity of DTT services throughout this complex transition.
Additionally, there would have to be "bi-lateral coordination of this detailed UK Digital Terrestrial Television (DTT) spectrum plan with spectrum regulators representing each of the UK’s closest neighbours.", with fears that there would not be enough frequencies in some areas to support a full digital terrestrial television service without "taking" frequencies from neighbouring countries.
Based on all the work that would need to be done both technically and in negotiations with other countries, Ofcom's date of 2018 for the changes to commence were deemed "too optimistic".
Interestingly, Ofcom appear to have been ignoring many of these concerns in pushing ahead with its now second UHF clearance plan. In turn, there are concerns that Ofcom is ignoring one of the multiplex operators - Arqiva - whom they turn to for spectrum planning advice and who also manage and operate mobile phone infrastructure, so uniquely can see both sides of the argument.