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Consultation & Review |
Responses to the Consultative document on Radio Based Telecommunications Services in the 2.4 GHz Band
Brian Last
Radiocommunications Agency Your ref:
11th Floor New Kings Beam House
22 Upper Ground
London SE1 9SA
30 September, 1998
Dear Brian
FUTURE LICENSING OF THE 2.4 GHZ BAND
It was with some dismay that I learnt on Friday that the Radiocommunications Agency had placed a Consultation Document concerning the Future Licensing of Radio Based Public telecommunications Services in the 2.4 GHz Band on August 11 for response by 1 October. While I accept that it was indeed in the public domain and that there had been a press release, I had thought that it had become accepted practice that the RA would at least draw to the attention of their regular contacts any new Consultations. Unfortunately - perhaps because of holidays but also because of the many and varied issues exercising the minds of those closely involved in radio matters neither I or any of my radio colleagues noted its existence until last Friday.
On reading the consultation I was further concerned that it was somewhat ambivalent on the matter of whether it was indeed a pure consultation or whether it combined a request for tenders. Paragraph 4 appears to be clearly the latter, and seeks somewhat detailed business case proposals. However, I would suggest that this does not sit too well with the indication in paragraph 1.5 that "Prior to issuing any further [licences]" this was a consultation "[to address] the conditions under which further licences may be issued." and certainly seeks more than paragraph 1.7s expression of interest.
In BT's view there is insufficient detailed information upon which to build the robust business case which is required and BT feels it is inappropriate to call for such a level of detail while acknowledging that if there is more than one candidate for any given region the RA will need to consider further the allocation method.
Parallels are drawn between this document and the competition for the 2GHz and 10GHz frequencies: In that case, there was a clear consultation period followed by a competition. There may indeed be no good reason for such a protracted procedure as was adopted there, but in BT's opinion, a consultation cannot usefully be run simultaneously with a competition, and particularly where the preparation of such a detailed business case would need to be predicated on clear information about the sharing difficulties (especially perhaps with MOD), and the relevant boundaries of the regional licences (upon which you are consulting.)
On the face of it BT would be concerned that widespread deployment may affect the use of private systems (see further detail below). It would therefore recommend that adequate sharing studies be performed and that, in any case of interference leading to a significant reduction in capacity or performance, preference should be given to the private systems. These private systems are of strategic importance to the future development and evolution of data terminal mobility services. They form the embryo for the development of converged services and therefore VMTS.
BT is unable to say categorically whether it is interested in "bidding" for use of this band, until it sees the outcome of sharing studies, BT is able to undertake some of these on its own behalf but has unfortunately not had the time to resource to do so since it became aware of this consultation. Furthermore, we believe that the RA itself should undertake some studies before any further licences are issued. Such sharing studies should concentrate on the following current and future systems :-
Wireless LANs (with various manufacturers) are already being used throughout the UK on a licence exempt basis, and are likely to proliferate in the future;
"Blue Tooth" is a proprietary system being developed co-operatively within the computer communications industry (IBM, Intel, Nokia, Toshiba and Ericsson are involved amongst others). This should be available before the end of 1999. It is anticipated that it will have a high profile launch, and will take a significant market share.
"Home RF" is a further proprietary system which is being developed for operation in this band.
In BT's opinion the RA should not close the door to further bids at the dose of this consultation, and would appreciate the opportunity to discuss further the possibilities for licensing, either bilaterally or in open forum. As an initial point for discussion it seems likely to us that any fixed radio access system which is licensed in this band will probably be targeted at urban areas (c.f. Atlantic Telecom's deployment in Glasgow and Edinburgh), which is where interference from wireless data products in this band are likely to be most significant. Rather than considering licensing on a regional basis - for which, with sharing difficulties, it could be difficult to mount a clear business case; it may be appropriate to consider licensing on an ad hoc basis to operators to address difficult niche markets in a given area, eg marinas, caravan parks and drop wire replacement in 'scenic' villages. Certainly with the current state of information, BT would like to explore the option to use the technology in such niche (and limited) applications, as may other existing fixed operators, and would thus recommend against a decision to award licences based on one operator per region at least until the outcome of sharing studies are known.
I hope you have found these comments helpful and look forward to further dialogue on this issue.
Yours sincerely
Lorraine Flawn
Senior Regulatory Adviser
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