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BT's Comments on the Radiocommunications Agency Strategy Document, "Mapping the Future of Convergence and Spectrum Management" |
1. Introduction
BT would at this stage like to offer the following comments on the document submitted to the Radiocommunications Agency (RA) by Nervewire, Indepen Consulting and Intercai Mondiale following the workshop held by the RA in which we participated earlier this year. We have taken the view that this report opens the way to wider industry debate in which ours and other responses should be seen as a second phase, in the evolution of the tested scenarios.
In our view, the RA is to be congratulated for having taken this initiative. Certainly, the report’s aims are laudable: spectrum is key to the development of mobile commerce and a flexible and dynamic approach will be needed if we are to address the uncertainties of the future efficiently within a spectrum management framework. An essential element of this though is the need for the RA to develop a more coherent, and stable, longer term strategy, putting in place a framework and the tools which will permit account to be taken of developments in a potentially fast-moving marketplace. The context of this framework should be both International in outlook and support UK competitiveness.
Although the work undertaken so far forms only a preliminary scoping, with a great deal of further detail and analysis to be collected and undertaken; nevertheless, some important points have been highlighted and the scene has been set to open what may prove to become one of the most important debates in the telecommunications industry for the foreseeable future. Ultimately, if this work is to be seen as worthwhile, it is vital that the RA is empowered by Government, picks up the baton and takes the actions which we now need to agree to facilitate a true spectrum strategy for the UK, in a manner which will be reflected in Europe and indeed the world.
2. Background: the Technique
In the following comments it will be seen that we are broadly in support of the approach taken. The "future mapping technique", used to drive forward the report, is an interesting technique. Certainly, in the context of a perceived medium to long term period expected to be dominated by change, and with little or no consensus as to what those changes may be, this backward looking technique, rather than pure prediction or forecasting, would appear to have much to commend it. Inevitably with such a technique, the "endstates" are central to the outcomes. The RA and consultants clearly undertook some considerable preparatory work to arrive at the endstates which were the subject of the workshop, and there was considerable buy-in that the endstates had a reasonable measure of credibility as possible futures for 2010 (with the more probable outcome that there would be some mix of all the endstates over that time.) Nevertheless, while it seems difficult to conceive of a further, and totally different endstate, BT commentators on this report have agreed that it is also quite difficult to envisage many elements of some of those endstates taking even 10 years to arrive. There may be many reasons for this, but in view of the fact that one of the important outputs from the workshop itself is deemed to be the "signposts", it does seem to us that the technique itself may need to be employed again throughout the period of unwinding events, (perhaps building on the previous output every 2 years or so) in order to identify more "relevant signposts" as we progress. It is to be hoped that if this does happen the whole process will be very strongly supported by wide industry involvement, which may be expected to bring increasing levels of both credibility and buy-in to the outcomes. (Where "outcome" is used to refer to the validity of the signposts rather than finally predicted endstate, which is not the aim of the technique.)
If current expectations are proved correct, spectrum strategy may be recognised as important by a far greater sector of industry than is the case today. That widening section of views needs to be enabled to find a voice in this debate and to be brought on board in the decision making process as the future unfolds. If this way forward is accepted it will also go some way towards guarding against the uncomfortable feeling that there are likely to be new breaks in technology and services, which we haven't thought about, that can or could severely distort the future for us. As the report acknowledges; who would have predicted 10 years ago, the growth of mobile and the internet? Is there something of a similar ilk coming down the pipe that will take us all by surprise and completely change the telecom landscape. To what extent that would influence the need for additional spectrum we cannot know now, but it seems possible that a replay of the future mapping technique periodically would be more likely to catch such a phenomena coming over the horizon and permit of relevant reactions.
It is already clear since the workshop that research/development is already under way in areas such as 4th Generation, Personal Area Networks and Radio LAN’s all of which could loosely be covered in the Mobile scenario but which may have some key policy requirements not identified so far in the work.
3. The Report
The report is constructed in two halves; firstly, it contains a faithful representation of the workshop findings, and, since it does not claim to be right it cannot be declared wrong! What the report goes on to do well is to identify the possible ways forward in terms of options which could be pursued with respect to spectrum management and assignment methods. No conclusions are drawn, and the report does not lead us to expect this. Indeed, our view, as stated in the opening lines of these comments, is that the publication of the report paves the way to a wider debate. However, where we believe the report itself can benefit from further work, is in the identification, or perhaps more specifically, highlighting, of the "signposts" which we consider to be an important part of the output. Only once industry and the RA have agreed on the importance, interpretation and priority of these, can greater and stronger linkages be drawn between the scenarios, which form the backdrop to the first part of the report and the implications for strategy which may be drawn from the fairly comprehensive list of possibilities identified by the second part of the report.
4. Developing a UK Strategy for Spectrum Management
As we have hinted, the "open minded" approach of the report is very refreshing. The impression that it starts from something like a "blank sheet of paper" may do much to promote innovative thought. Nevertheless, there is clearly a history to this and the report also succeeds in trying to pull together ideas relating to convergence where previously it has been addressed from many different angles and resulted in a collection of random statements. Parallels can be seen with the early days of 3G mobile where 3G was so ill-defined it could mean all things to all people. The Commission's UMTS Task Force initiative did much to turn a wide variety of random ideas into a more coherent plan.
Outwith this report, Government, regulators and indeed the communications industry generally, have clearly recognised both the importance and uncertainty of convergence. The RA specifically has recognised the important role which it must expect to play in facilitating, co-ordinating and, where necessary, planning the spectrum aspects of this convergence, where spectrum itself is set for a centre stage position. By using four very different convergence scenarios to illustrate the breadth of the possibilities we might end up with and pulling together the threads which lead to the separate endstates, this report presents a view that convergence will develop on the basis of continuous technical development, principally in broadband digital communications and interactive services, driven in time and direction by market forces. It successfully sets out (by no means exhaustive) lists of technical, environmental, social and commercial influences that could condition the eventual nature of convergence. It does not, however, and cannot spell out the outcome of the convergence of industries or applications or customer equipment (e.g.IT/entertainment convergence). Hence there is a need for further debate to arrive at a possible solution to allow these developments to be fully catered for without artificial distortion, or inadvertent channelling.
It is perhaps unfortunate that the RA has not taken the opportunity to indicate more clearly what it would expect to get back from this current review of the report. This lack of focus may result in such a wide plethora of responses that there may be difficulties in crystallising out a consensus of "next steps". Although, given that the report itself is such a departure from the norm, this approach may result in the first instance, in a clearer view of the more fundamental concerns of industry; with the result that this will encourage a more vigorous debate of both the problems and the solutions.
In our view it is vital that this review of spectrum strategy is seen as an integrated and inseparable aspect of the wider Communications White Paper debate and we would like to see the (more clearly identified) "signposts" and scenarios incorporated and used as an intrinsic part of the Communications White Paper "next steps".
In particular, one of the aspects of the report which we find notable is the lack of discussion of the relative merits of the different "endstates". The impacts of various possible national government and EC actions are factored into the variability of the end-states, and at the workshop stage some considerable thought was given to the potential results of government and regulatory action. Government policy, at national, European or even global level, brought to bear on the issue of convergence, could radically constrain the possible end-states. Clearly the future is not entirely pre-ordained and organisations can seek to proactively create or influence the future. This is especially relevant to the development of the UK’s spectrum strategy, since by their action or inaction, regulators can impact on the evolution and relative degree of success of the different scenarios. There is then, a need to map out a vision for the future in co-ordination with wider Government policy objectives for communications, as the next stage of policy development. This would facilitate the evaluation of the different policy measures as set out in the report, and may help to suggest new ones.
It appears to us that one of three distinct roles, or policies, could be adopted by Government:
In general, BT would expect that government to favour the second of these approaches, at least in the first instance, whilst also urging greater movement towards the first approach, particularly as issues begin to become clearer. In any event, because of such considerations, BT feels strongly that these issues must be taken in the context of UK competitiveness and the wider Communications debate, and should be set alongside the current Communications White Paper discussions.
It is only once that more complete vision is considered that it is possible, or even perhaps relevant, to begin to take decisions and make choices with respect to the options and suggestions made within what appears to us to be the second and separable part of the report concerning assignment and allocation processes. Overall, it is becoming increasingly obvious that a clear and stable framework must be developed within which the UK can obtain a greater degree of certainty with respect to both its spectrum plans and objectives. Only thus will industry have the necessary confidence to invest fully in new communications products and services generally, and to make considered judgements regarding it's use of spectrum within this broader picture.
5. Europe
However this debate proceeds, it is important to ensure that the UK doesn’t act alone. The report itself is very UK centric and this may be seen by some to be a significant weakness. There are already various European and international constraints and in any event many of the benefits of good spectrum management can only be fully realised where policies are implemented on a wider scale. Much debate has already taken place through the EU's Green Paper on Spectrum Management and its "Next steps" statement. Separately, the RA has indicated its desire to stay within the general framework of European/global spectrum harmonisation as it moves towards convergence. BT would wholeheartedly endorse this stance for all the reasons discussed more fully in these other debates: For example low cost devices, content and terminals depend on global markets while the UK cannot afford to underestimate the growing and co-ordinated power of the manufacturers, who see convergence as the next major opportunity. It is essential to realise that the UK can only lead where others will follow. The UK will most successfully provide leadership if it concentrates on early recognition of the trends (directions and timescales) being set by European and indeed global consensus. This more international aspect of the requirement for a spectrum strategy needs to be fully explored in the future debates.
6. Spectrum
The report contains a great deal of detail of possible spectrum management scenarios and regimes and comprehensive shopping lists of things that could happen and could be done. These are all useful as they provide a comprehensive toolkit from which the right package could eventually be built. However, as indicated above a clear way forward cannot and should not be chosen in isolation but must be discussed as part of the wider Communications White Paper debate.
Nevertheless, time may be of the essence, because although convergence could be 3,5, 10, or more years out. If it is to be at the lower end of this range, (and BT fully believes that this should be the aim) what happens to spectrum now will be very important.
In our view track i) would require government to put in place now a spectrum allocation, spectrum trading and management framework that stimulates the widest range of possibilities. This may mean keeping the cost of spectrum down, as revenues from services and applications will be quite uncertain, especially from those which are innovative, and the levels of competition will be variable and largely unmanaged. The market should ultimately be allowed to decide and some experiments will fail, so flexibility (flexible service categories, secondary spectrum trading, etc) will be key, as it will be vital to permit swift change and re-allocation to guard against spectrum shortfalls.
Much of the spectrum material contained in the report is hinting at track ii) (see section 4. Above.) This may be because with the current state of knowledge and technology, a spectrum strategy which promotes track ii) may incidentally provide greater security than we can currently easily envisage with track i), against inadvertent sterilisation of important spectrum, simply because of assignments and allocations which have gone before, for which there is neither clear policy for altering nor method for accommodating.
There is evidence for suggesting that current spectrum activity could be considered in line with the promotion of track i) but that, as this has not been the subject of due consideration, the spectrum management tools have yet to be recognised or designed, much less put in place, to ensure that the spectrum can continue to be managed efficiently as services evolve and develop. Activity is currently at fever pitch with considerable attention being paid to auctioning or otherwise re-allocating 420 MHz, 700/800 MHz, 2GHz, 2.5GHz, 3.4GHz, 5GHz, 10GHz, 28GHz and 40GHz, with further possibilities in re-farming. All these events are being taken largely in isolation. Indeed when the government auctioned the 3G Mobile core bands there was no clear visibility to industry of how they will handle the extension and re-farming bands, and this remains the case even after the auction, as the licence holders begin to put their plans into action.
Furthermore, it is becoming clear that the balance of competition, and definitions within the communications market are rapidly changing. Spectrum management needs to be sufficiently stable to encourage investment and flexible enough to be able to take into consideration changes in the market, both customer and industry driven, and developments in technology in the next few years.
Under such circumstances one could envisage a scenario where, even with a "chaos rules" approach, the lack of a clear government policy will inadvertently condition the end-state because the relevant tools and framework have not been put in place.
7. Next steps
As implied in previous sections of this response, we are concerned that there should be wide industry involvement in this whole process. The benefits of such an approach have already been seen in the context of the UK3G auction and it is unlikely that potential players will be content with anything less in the future. However, as we have also suggested the impact of all this on UK industry generally, in the future, with
e-commerce already taking a very strong hold in it's thinking, is conceivably huge. For this reason it is vital that Government positively involves this wider section of the community in the Communications Legislation debate.
In the specific context of a Spectrum Strategy, in the first instance and at the top level the RA needs to debate with industry what mechanisms will be required to deliver the flexibility and speed of change which will become necessary. Mechanisms might include:
At what may be seen as a secondary level, the RA will need to:
8. Conclusions
BT feels very strongly that the time has come for the RA and Government to develop a true UK Spectrum Strategy that provides a useful framework for industry (both the communications industry and industry more generally) to plan its business and develop business cases against a stable and predictable backdrop. At the same time it needs to permit of the flexibility to adapt to changing circumstances and developing markets. Inevitably there will need to be a balance struck between the level of certainty achievable and the degree of flexibility which must be retained. This cannot be expected to be easy to achieve, and the task which the RA has set itself should not be underestimated and needs the involvement and support of industry, but the goal is surely worthwhile and is not inherently contradictory.
The need for this study was predicated on the key requirement of spectrum to the realisation of applications such as mobile-commerce and indeed to convergence more generally. In BT's view it is vital that spectrum strategy is fully integrated into the thinking behind and development of communications legislation more generally and as such needs to be fully included in the work surrounding the Communications White Paper. Only in this way can either the legislation or the strategy be deemed to have fully taken into account all relevant factors, and only thus can the complex and sophisticated communications requirements of UK industry and people generally have any chance of being fully and effectively provided for in the 21st Century.
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