Response to "Proposals For The Licensing Of Radio Spectrum At 28 GHz" - Crown Castle UK Ltd

Dear Mr Mason

Proposals for the Licensing of Radio Spectrum (28GHz)

Following the above proposals issued on 10 April 2000, 1 am writing to comment on behalf of Crown Castle UK Limited. We are the world's leading independent wireless infrastructure group and as such we aim to serve telecommunications operators, both fixed and mobile, and to promote all types of wireless telecommunications. We have also carried out a study of the market for these services and of the economics of deploying such a network. In most respects we can understand and agree with the proposals. However we are concerned about that part of the proposals which states that

'Licences will be issued solelyfor the provision for BFWA services. This may include supporting the infrastructure ofBFWA services but will not extend to supporting other services or technologies.'

It is our view that allowing this spectrum to be used for infrastructure links, in particular to provide connectivity to other wireless sites (e.g. UNITS) will actually promote service availability over a wider geographic area by opening up additional revenue streams.

We understand, and have considered, the view that this might prevent the primary use which was envisaged for the spectrum, namely competition in the fixed access market. However we have concluded that in the urban and suburban areas where demand for these services will be greatest, this use will be predominate in any case on economic grounds. In the vast majority of the land mass however, where deployment for BFWA services alone can not be justified, allowing this additional use will promote wider deployment.

An alternative would be for the above restriction to apply only within metropolitan areas. We would be happy to expand on our views and look forward to your final proposals

Yours sincerely

Michael Schueppert
Director of Sales & Marketing

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