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Motorola Ltd's Comments on the Radiocommunications Agency Strategy Document, "Mapping the Future of Convergence and Spectrum Management" |
Mr Laurence Green
Radiocommunications Agency
Strategy Unit
11B/20C, Wyndham House
189 Marsh Wall
London E14 9SX
Direct Line 01753-500003
Direct Fax 01753-534245
25th July 2000
Dear Mr Green,
Motorola was pleased to be invited to both participate in the workshop and also to make comments on the report. We consider the principles of the workshop to provide a benchmark for regulators all over the world and therefore congratulate the Radiocommunications Agency for undertaking this project.
In responding to this report we restrict our comments to matters of relevance to a major supplier of equipment for customers in a very wide range of markets. We believe our portfolio to be one of the more diverse in the industry and as such we must take a very broad view of the topics.
Motorola is a significant investor in the UK and had revenues and exports of £3.7Billion and £3.0Billion respectively in 1999. We were ranked number 7 for UK exports in 1998 (FT) and employ over 10,000 people, most of whom are in Scotland.
Yours sincerely
Tim Cull
Motorola Ltd.
CC: Mr. David Brown (Chairman, Motorola Ltd.)
The principle of the Radiocommunications Agency looking ten years into the future is thoroughly supported. The method of setting out four scenarios and then inviting representatives from various organisations related to the markets supported by the Agency to discuss and identify key factors supporting or detracting from the likelihood of each of these was excellent.
Motorola was pleased to participate in this activity.
The conclusions and recommendations laid out in the report are, in general, strongly supported. However, there are some points that could be amplified to provide greater clarity or to provide the basis for further analysis and policy decisions. This paper is restricted to laying out these points rather than commenting item by item through the entire report. Nevertheless, it is important to look at aspects of the Recommendations for Action.
The key messages of the need for flexibility and coherence in spectrum policies and processes together with a faster pace of re-allocation and re-farming is well established. It is worth repeating here that in the context of real convergence this takes on a greater importance than hitherto. Motorola would therefore wish to see these points made with even greater emphasis. The need for flexibility and coherence is a direct consequence of the enormous uncertainties surrounding the nature of the market changes (alluded to in the report). Regulatory policies will have to be reduced to avoid causing obstacles. We are concerned that the report could be taken to imply a recommendation for a regulatory regime that can be altered and modified as required to meet the various needs. We believe this idea to be problematic and perhaps even impossible to implement in reality. It is suggested that the only way of avoiding such difficulties is to modify the regulations such that they are simple and act horizontally, dealing only with the fundamental issues.
The increase in demand for spectrum over 2GHz is clear but is really only a sub-section of the overall picture (albeit very important to some). It is Motorola’s belief that demands will grow rapidly all across the spectrum and solutions will have to be applied generally.
The use of market mechanisms is supported for many applications but there will remain a significant number of instances where administration by the Regulatory Authority will be the most efficient means to manage the spectrum. In the light of the proposed Directives resulting from the 1999 Review we note the continued need for Individual Licences in carefully selected areas despite the increased need for the use of General Authorisations. Some implications of this are noted below.
The report proposes the funding of research into the future use of bands that are currently not well utilised. Motorola would extend this further by again pointing out that funds obtained by licensing in the UK should be, at least to an extent appropriate to achieve an improvement, re-invested in the industry to ensure that the users derive the most benefit from the spectrum.
Motorola endorses the concept in the report of convergence of allocation policy at CEPT and ITU level. There have been major efforts to create standards for systems and protocols with world-wide application. As a supplier, we can confirm that the user will not be given the full benefit of the economies of scale from such standards if the allocation and assignments are different and therefore difficult to implement and deliver.
We agree that the RA’s current licence allocation categories are not sustainable into the future. We note that the RA is currently examining this subject and therefore support this activity.
We consider that it will not be possible to categorise licensing in the converged market as all equipment is capable of providing a wide range of services. Therefore we would propose the Agency look at the management of the spectrum in terms of the allocation of spectrum resources to support certain services. The management task then becomes assuring technological co-existence in bands. This is completely different from the idea of reserving blocks of spectrum to technologies. Clearly this also has implications on coordination at CEPT and ITU levels.
Motorola notes the emphasis in the report on the release of spectrum to new users. We consider that the future radio users will expect to simply purchase appropriate equipment from a variety of outlets and then start using it without any other administrative steps being involved. Thus licensing according to the principles of General Authorisations will become the normal case. Allocations in the spectrum will have to reflect this.
Whilst we note the encouragement of dialogue with the military authorities to release spectrum we consider that it is unlikely that this can be done in an internationally coordinated fashion. However, such spectrum releases will be very beneficial for certain specific applications.
Motorola agrees that an inevitable consequence of the increased speed at which the market is moving is the need to introduce administrative measures to improve re-farming and the uptake of all opportunities to increase the utilisation of the spectrum such as through the publishing of planning and assignment databases. We consider that for practical reasons there may be a very strong case for the use of funds to speed up re-farming.
Motorola is of the view that all four scenarios chosen have characteristics that may survive the period. We therefore support the statement in the report that the scenarios are not mutually exclusive. However, they do each have certain distinct characteristics that may differentiate them in terms of the regulation.
It is therefore important to keep this work up to date by some efficient process to ensure that at least the most likely scenario (when viewed at the time) is supported. Motorola would be pleased to continue to support this process.
It is the belief of Motorola that the most important change likely to occur as a result of convergence is the introduction of a revised and much more effective re-farming policy.
Whilst it is clear that spectrum trading will assist it cannot possibly be the answer to all situations. Areas of the spectrum currently under terms of individual licences are likely to prove inappropriate for the employment of market strategies to achieve re-farming.
We propose a consultation group be established under the chairmanship of the Agency to look at all aspects of re-farming as a matter of some urgency.
As noted above, a major benefit to the user is the passing on of the economies of scale. Therefore re-farming should be undertaken in the International context. It is believed that this will represent a major challenge in practice.
This report proposes a large number of very significant and far-reaching changes in all areas. We further note that, due to the apparently unstoppable nature of convergence, changes of this nature would appear to be inevitable.
In recognition of this, Motorola requests that the Agency provides information at regular intervals on the actual concrete steps in progress in response to this report. Secondly, as these changes cannot be done in total isolation from the rest of the European Community it would therefore appear appropriate to have information on the progress of this subject in other Member States.
Many of these changes are likely to be best achieved with the active co-operation and assistance of many of the actors in the business we therefore assume an appropriate degree of participation will be expected by the Agency. In any event we presume that a series of consultations on a wide range of subjects will be undertaken as a consequence of this report.
In the interim we encourage the Agency to respond to the recommendations made in the report.
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Motorola Ltd. |
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