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2.  The Australian Radio Communications Industry Association represents some 300 commercial entities including approximately 1500 industry professionals  Radio and specialist manufacturers  Two way radio dealers & installers  Spectrum consultants  Commercial and government industry professionals 2

3.  One of the principle reasons to change was the conversion from 25 KHz (wide band) to 12.5 KHz (Narrowband) bandwidth channels  Many end users took the opportunity to move to new digital technology. End users now have a choice of digital radio technologies including TETRA, P25 Phase II, DMR & dPMR all offering 6.25 KHz direct or 6.25 KHz equivalent (TDMA systems) bandwidth per channel  This is a 4 fold increase in efficiency over legacy 25 KHz analogue systems 3

4.  There are many Australian innovators and manufacturers in the market.  While we are technology takers there are companies manufacturing radio equipment (GME, Spectra Engineering, RF Technology), specialist filtering, antennas and rebroadcasting equipment, (RF Industries, Polar) and many other products for different user groups  Software applications is a growing market as new technologies allow the integration of GPS, Bluetooth, RFID and Wi-Fi into the radio network which are used to deliver new services. 4

5.  ARCIA would like to see the ACMA modernise the paper based licencing system  Make it easier for business to deal with ACMA licence database and financial systems by having an updated access portal for clients and/or their agents.  Find a better way to inform licence holders when licences are about to or have lapsed. Either by being able to identify on a licence record the spectrum managing agent or technology provider as opposed to the administration address of the licence holder. 5

6.  The 800-900 MHz review appears to have stopped  This has a major impact on radio users with the potential impact on LMR trunking band and the low capacity point to point link band.  Especially for regional areas with a lack of high capacity infrastructure, low capacity links provide a reliable way to connect systems over long paths. The ACMA does not provide any alternate bands with suitable antenna rules. The increased costs associated with moving to links above 4 GHz are holding up movement of PMR systems to meet the 400 MHz milestone 2 & 3 6

7.  Embargo 45 was set in 2006 to allow the ACMA future flexibility in broadcast planning for TV CH27. This 518-520 MHz and the paired 508-510 MHz spectrum is heavily utilised in HDA’s. Industry needs to be consulted on the future of this spectrum now that restacking has occurred  Embargo 56 is in place to assist with moving commercial users affected by the 400 MHz band plan, in particular 450- 470 MHz users. Does this Embargo still need to be in place and how does the ACMA intend to consult with industry on its retirement? 7

8.  ARCIA has identified through its work a number of areas where a public park spectrum model may be more suitable to access appropriate spectrum for some users  Currently UHF CB channels are used by many commercial organisations as a low cost commercial service.  This has lead to safety issues and certain precincts banning the use of CB radios for some operations.  Manufacturers are required to obtain additional ACMA approvals to sell commercial equipment into this band  Many users are not aware there special rules for the operation of equipment or are unaware they are using this band and may be in breach of ACMA regulations 8

9.  Some users have 5W low power licences allocated for local on site commercial services  Many users are not aware there are location based rules for the operation of this equipment and by moving to the next job may be in breach of ACMA regulations  The time and cost of reallocating the licence and then having the commercial equipment reprogrammed outweighs the potential risk. 9

10.  Setting up a commercial spectrum public park could benefit many groups including the construction and event industries  Faster access to commercial off the shelf products and lower cost of ownership  Ability to reset for new locations and obtain spectrum approval quickly via third party management  Lower barrier to entry for commercial equipment manufacturers, no special UHF CB type approvals necessary  Clear UHF CB channels of commercial traffic 10

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