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Consultation & Review |
1 October 1998
Mr. Brian Last
Radiocommunications Agency
11th Floor
New Kings Bearn House
22 Upper Ground
London SE1 9SA
Subject: RA Consultative Document on the Future of Radio Based Public Telecommunications Services in the 2.4 GHz Band ("Consultative Document")
Dear Mr. Last:
The Boeing Company ("Boeing"), by its attorneys, herein comments on the Consultative Document issued by the Radiocommunications Agency ("RA") on spectrum allocation issues for the Radio Fixed Access ("RFA") service. The Consultative Document raises the possibility that spectrum in the 2.4 GHz unlicensed band could be considered for further licensing of RFA services.
Boeing urges the RA to formally conclude that it would be inappropriate to license RFA services in the 2.4 GHz band. This spectrum is internationally recognized as an unlicensed band and is actively utilized in the United Kingdom for important unlicensed communication and data services.
Specifically, Boeing, SITA, Penny & Giles, and Rochwell Collins operate a Crew Information System (" CIS" ) pilot programme at Heathrow Airport in the 2.4 GHz band. This programme, which is supported by British Airways and other International Carriers, has the potential to increase the efficiency and reliability of aircraft pre- and post-flight operations. The system uses unlicensed, low power, equipment in the 2.4 GHz band to automatically transfer important aircraft operations and flight information data between aircraft and airport facilities. Prior to the development of this capability, information had to be hand carried onto each aircraft daily and downloaded to and from aircraft computers using floppy disks. The use of this system enables airline carriers to access flight and safety data at each gate stop, and thereby catch potential safety problems before flight turnarounds.
Boeing expects that, following the successful completion of the pilot programme, additional facilities will be built at commercial airports around the world, including airports in the United Kingdom. This worldwide air transport infrastructure improvement should increase productivity and safety and benefit the world's airline travelers. The success of this programme, however, depends on the availability and co-equal protection of unlicensed spectrum as allocated by the International Telecommunication Union (" ITU" ) on a worldwide basis at 2.4 GHz. It is for this reason that Boeing believes that it would be inappropriate to open the 2.4 GHz band for any licensed or auctioned RFA services.
Instead, all users of the 2.4 GHz band should be required to operate at low power, in keeping with the ITU allocation of the band. Although the proposal is not entirely clear, it appears that the RFA providers contemplated by the Consultative Document would not be required to fit the power model of wireless/radio Local Area Networks ("LANs"). Boeing urges the RA to reject the licensing of cellular voice-type services with large cells and high power, and to remain true to the small cell and low power outputs of the Radio LANs or Personal Area Networks ("PANs") that have been the focus of the ISO 8802-11 2.4 GHz wireless LAN standard.
If the RA determines that it must grant regional RFA licenses in the 2.4 GHz band, then the RA should give RFA service providers no greater power or spectrum rights than are assigned to all existing and future unlicensed users. The CIS application can be viable in an unlicensed environment of equals but will be at risk if administrations grant, by policy, licensed priority to some operators. Additionally, if regional licenses and special privileges are granted to RFA providers, the RA should prohibit coverage and operations by such licensees within an appropriate area surrounding commercial airports.
Finally, if the RA decides to continue to license RFA systems in the 2.4 GHz band, Boeing urges that the licenses be issued pursuant to a "beauty contest" rather than an "auction."' Boeing believes that the use of a beauty contest furthers the public interest by permitting the RA to consider the impact that a RFA licensee might have on important unlicensed services in the 2.4 GHz band, such as the CIS programme. A licensing process that mixes public interest considerations with the profit motive of an auction may be detrimental to important public services.
For these reasons, Boeing urges the RA to reject any proposal to license RFA systems in the 2.4 GHz band in conflict with the international ITU-recognized unlicensed allocation. However, if such licenses are issued, RFA licensees should be required to protect the operations of existing and future unlicensed operations in the 2.4 GHz band.
Finally, we ask that Boeing's interest in this matter be noted, and that we be kept appraised of developments in the RA's consultation process.
Sincerely yours,
Joseph P Markoski
Counsel to The Boeing Company
cc: Alan Proud
Department of Trade & Communications
& Industries Directorate
151 Buckingham Palace Road
London SW1A 9SS
'Consultative Document at 4.7.
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