|
Spectrum for Asset Tracking Mobile Data Networks using Spread Spectrum Techniques - Annex A |
Response #1 - Nortel Networks
Response #2 - BT Networks and Systems
Response #3 - BT Paging
Response #4 - QNL
Response #5 - APD Communications
Response #6 - RAM Mobile Data
Response #7 - BT Cellnet
Response #8 - Nokia
Response #9 - Low Power Radio
Association
Response #10 - Federation of the Electronics Industry
NORTEL NETWORKS
Mr D.Clark (01628-432487)
Consultative Document on Spectrum Allocation for Tracking Systems
I have consulted with colleagues in my company and I should like to make the following comments on your document.
| 1) | Nortel Networks are still selling CT2 systems and have no plans to stop selling it; sales in the UK have actually been higher this year than the equivalent period last year. This reflects increased demand for mobility products of all types. |
| 2) | Nortel Networks will be launching our CT2 mobility on a new PBX (Meridian Norstar Compact Plus) later this year in response to demand from major retail chains. This product will be sold nationwide through BT. It is not economically viable to change this to an alternative mobility system (DECT) and there is no end-user pull to do so. |
| 3) | Whilst it is true that CT2 is not as heavily used as was once predicted, it cannot be considered to be "lightly used" |
| 4) | Nortel Networks products make full use of the total channel capacity of the CT2 spectrum to allow a high density of users and high user traffic in any given area. The dynamic channel allocation of CT2 is used to permit the high density of users. Any interfering signals could disrupt communications by only allowing a lower density of users when the interference is present. Modelling of this effect does not appear to have been done by the RA - apparently only a simple single channel voice link has been examined or tested. |
| 5) | CT2 is used in hospitals and the nuclear industry where failure of communications could have serious consequences |
It seems to my colleagues and me, that to avoid potential conflicts with CT2, the best choice of the RA's four proposals is 868 - 870 MHz.
The above comments have been produced quickly in order to meet the very short time scale allowed for this consultation. My company reserves the right to offer more detailed comments, when a fuller examination of your consultative document is possible.
RA Response to #1
The tests carried out indicate that an Asset Tracking System using CDMA technology
sharing with Wireless Audio Devices (and CT2) is feasible assuming one operational system.
The loss of CT2 channels would be limited therefore to those already
impacted by Wireless Audio Devices.
Moreover, the point raised in 4) is incorrect. As the Wireless Audio Devices become more widely used, the "total channel capacity of the CT2 spectrum" would be progressively reduced from the theoretical maximum of 40 channels to around 28 available channels. Therefore, the CT2 channel capacity will be reduced even if the Asset Tracking System is not approved.
The point in 5) is not valid as there at least 28 channels (under worst case conditions) available for these CT2 services.
BT Networks and Systems (Commercial in
Confidence)
For information on the response, see the author, Mr Chris Cheeseman
(01473-6745458)
RA Response to #2
See RA Response to #1.Opting for the 863-865 MHz allocation would mean
that the loss of CT2 channels would be limited to those already impacted by
Wireless Audio Devices. The CT2 channel capacity will be reduced (when coexisting with
Wireless Audio Devices) even if the Asset Tracking System is not approved. As these devices become more widely used, the
"total channel capacity of the CT2 spectrum" would be progressively reduced from
the theoretical maximum of 40 channels to around 28 available channels.
BT Paging
Mr David Neale (01132-768 799)
Subject: Comments upon 'Spectrum for Asset Tracking Mobile Data Networks using Spread Spectrum Techniques
Thank you for the opportunity to comment upon this paper. Unfortunately, we have only recently been made aware of it, and have been unable to gain clarification from the Agency of the way in which it is envisaged that paging will form part of this proposal.
However, it is widely acknowledged that paging networks form a useful and spectrally efficient method for sending data at low cost. It therefore makes good sense to fully utilise existing paging networks, in order to maximise spectrum efficiency, and minimise unnecessary aerial installations.
If the case is established for licensing additional spectrum for an Asset Tracking system, maximum opportunity should be taken to ensure that the use of existing paging networks is built into this proposal.
Yours Sincerely
Dave Neale
Head of Regulation and Strategy
(0113-276-8799)
RA Response to #3.
As it is envisaged that either existing paging spectrum would be utilised or
specific 25 watt channels set aside and no allocation of paging spectrum in the band in
question being envisaged, the RA agree with the BT comments relating to spectrum
efficiencies and aerial installations.
QNL
23rd June 1999
Dear Sirs,
RE: RA Consultative Document on Spectrum for Asset Tracking Mobile Data Networks
We refer to the above Consultative Document, issued on May 28th1999, in response to which we enclose our Application for authorisations to operate wireless telegraphy apparatus to provide a QuikTrak network throughout mainland UK, for which we require spectrum allocations from the Radiocommunications Agency ("RA") and operating licences from CII Division of the DTI. Details of the spectrum frequencies requested are contained in Part 4 of the Application.
With further regard to the Consultative Document, we have a number of points/observations to make which, in particular having regard to the more than 2 years that have elapsed since our original application, we are covering in this letter outside the body of the current Application.
| 1) | Since we began discussions with the RA, our parent company has both acquired QuikTrak Technologies Pty Ltd of Adelaide. Australia, owners and licensors of the QuikTrak technology, in its entirety and is nearing completion of extension of the Australian network to include Melbourne and Adelaide (both to be operational late 1999/very early 2000). | ||
| 2) | Our Australian parent is commercially, technically and financially prepared to begin active development of the UK project once licences are issued. | ||
| 3) | As it is now 3 years since we completed our initial QuikTrak Business Plan ("QBP") inputs to which we have reviewed and updated inter alia to enable us to maintain external interest (i.e. City, potential operating partner, potential clients etc.) we are reassured that the RA/DTI are now moving rapidly to a decision on licensing the use of spread spectrum technology in the UK, for an asset tracking mobile data network. We are confident that QNL are the appropriate company to receive these licences, as our technology is developed and commercially proven in the areas we seek to offer to in the UK and we have developed credible business and financial plans. | ||
| 4) | With regard to Licence Fees, however, we have major issues with what is proposed in the Consultative Document; and would like to meet with you urgently to discuss these. In particular | ||
| 4.1 | Whilst it may be appropriate to utilise, in assessing an appropriate licence fee for a QT spread spectrum system, a base STU rate of £1.65/MHz/k2 of area sterilised, it is very clearly incorrect to begin with a base cost for the UK of £0.792 million per annum. | ||
| 4.2 | We make this critical point because a spread spectrum system does not sterilise the spectrum it occupies; as we have shown in our operations elsewhere in the world and demonstrated with the STG at Whyteleafe, we can co-exist with others on the 2MHz bands and, therefore, in no way can we be deemed to be "sterilising" them. | ||
| 4.3 | We also believe that, in addition to agreeing an appropriate base cost for the 2MHz sought, various modifiers will need to have regard to the following: | ||
| 4.3.1 | We are not aware how/if the present occupants bear or will incur any initial or ongoing charge and, to the extent that a sharing factor is appropriate, this needs to be taken into account. | ||
| 4.3.2 | The previous CT2 frequencies are becoming redundant and to contemplate a base cost that is widely in excess of what, for instance, a much larger system (e.g. cellular) would be charged, for sought after and congested bands, is inequitable. | ||
| 4.3.3 | It will take up to 2 years before a spread spectrum system receives any income from its use of the licensed spectrum and it is inequitable and liable to stifle innovation to propose charging substantive fees until income begins to flow in from the operation. | ||
| 4.3.4 | Whatever operational constraints, (as indicated by the Consultative Document as being required for specific bands), are agreed may well have a significant bearing on assessment of the appropriate fee structure. | ||
| 4.3.5 | The "amount of use" modifiers need to be understood by us, and reflected in the fee structure, if relevant. Also the Quality of Service and Technology Choice; | ||
| 4.3.6 | We are aware that the spectrum fees charged in other EU countries for spread spectrum systems are of a different magnitude (downwards) to those being considered in the UK and do, we believe, represent an acceptance that, inter alia, they do not sterilise the spectrum operated in. | ||
| In summary, we suggest that the fee structure indicated in the Consultative Document is both inappropriate and consequently excessive and needs total review. The levels indicated would very severely adversely impact the economics of introducing the essential services that we wish to offer, and which are not currently available to the markets we seek to address. | |||
| 5) | We would emphasise that whilst, in respect of the wide band allocation options (Item 3.1of the Consultative Document), we have indicated our preference, we can, in fact, develop the QuikTrak Network within any of these allocations. | ||
| 6) | With particular regard to your focus on 863-865 kHz bands, we refer to the RTCG Report No 485, on work conducted at Whyteleafe - we were, of course, the subject of those compatibility evaluations and have reached agreement with you on the conclusions. We have discussed and agreed with you your wish to include certain operational constraints and a defined density per unit area; but we do need, of course, to discuss and agree to specific constraints and mechanisms prior to award of licences. We are confident that mutually acceptable criteria and procedures can be accepted and operated. | ||
| 7) | Since we first submitted a detailed Application to you in March 1997, we have improved the technical efficiency of our apparatus, developed a smaller and even lower cost TEK, and reduced the capital costs of the QuikTrak Network in the UK. Much of the capital equipment could be supplied from the UK. | ||
| 8) | As you know, we have conducted network evaluation etc with Vodapage Ltd, a wholly owned subsidiary of the Vodafone Group Plc. In this respect, capital costs and roll-out time are beneficially impacted by the timing of a project of this type and thus issue of licences in the next 3 months or so (as envisaged in previous discussion and correspondence with you), leading to sanctioning network construction early in 2000 is important. Timing has a direct impact on roll-out implications. | ||
| 9) | We believe that QUIKTRAK NETWORKS (UK) LTD are the only spread spectrum technology operator to have conducted successfully full financial, technical, construction and marketing/sales/organisational evaluation of a spread spectrum based network in the UK. We have been in dialogue with you for many years and believe that it is, therefore, time for a positive decision to be taken in our favour. | ||
| 10) | With regard to disclosure of any of the contents of our Application and covering letter/supporting evidence, we will be entering a market in which competitors have been operating (albeit modestly by the business plans we have prepared) for several years, and would wish no more than is essential - to your legal obligations in awarding licences to QNL - to be available publicly. Certainly, our market plans, price intentions and business/financial plan details are commercially valuable (in the hands of our competitors) and must be regarded as strictly confidential and highly sensitive. We would wish to agree separately with you whatever you need to disclose, but have clearly indicated in our application and supporting data those items that are not to be disclosed. The Appendix to this letter summarises the non-disclosure elements. | ||
Yours faithfully
Roy Allen
Annex not disclosed.
RA Response to #4
In point 6, the choice of this sub band as the favoured option was to minimise the
impact on the (already depleted) CT2 spectrum by yet another sharer.
The issue in Point 8 relates also to that raised by BT Paging and is addressed in RA Response to #3.
Based on the spectrum tariff unit of £1.65 /MHz/sq.km., the fee for a single 2MHz of spectrum would be £792,000 (point 4.1). The consultation indicated that an administrative pricing formula would be used and, even though the figure suggested in the consultation was incorrect, indicated that fees in the early years would be discounted to reflect rollout practicalities (point 4.3.3). However several points have been raised by the consultation, from the calculation of the rate itself to whether modifiers or reductions would be appropriate due to sharing and other factors. It is therefore likely that in responding to the consultation replies, the basis for setting the licence fees will need to be reviewed.
Other points which will require fresh consideration is the overlay factor of a spread spectrum system sharing with other users, and what proportion of the value of a (theoretical) exclusive channel might be appropriate. The Agency will announce fresh pricing proposals prior to the licensing of any system.
APD Communications
For information on the response, see the author, Mr David Britland (01296-435831)
RA Response to #5
On sharing issues, further work is being carried out within the RA on sharing
by at least two operators within the 2MHz allocation. When these results are known
decisions can then be made on the total number of sharers that can be accomodated whilst
maintaining an appropriate noise floor.
On pricing, the answers to #4 apply, and in addition the application of a weighting factor for sharing implications is worthy of further consideration.
RAM Mobile Data
For information on the response, see the author, Mr Jon Bental (0181-990-9090)
RA Response to #6
Work is continuing within the RA to identify an appropriate harmonised European
Standard.
BT Cellnet
Graham Kersting, General Manager, Regulation (01753-565409)
The response from Graham Kersting of BT Cellnet raised the procedural issue that although the Press Release appeared on 26th May, their copy was not received until 14th June and the (RA) web version was not published until 15th June. It continued;
BT Cellnet has read the consultation paper from the Radiocommunications Agency ("RA') entitled "Spectrum for Asset Tracking Mobile Data Networks using Spread spectrum Techniques' ("the paper') with interest. Comments are below.
| 1) | The introduction suggests that the market for low cost asset Tracking services is both niche and huge; these are contradictory statements - niche markets are unlikely to be huge. |
| 2) | It is alleged that this market is not being adequately served by the existing mobile data network operators, but no evidence is provided to support this allegation. |
| 3) | A lack of consistent allocation on a European basis is likely to be an inhibitor to the longer term development of the market. Even though the RA says it will promote harmonisation at a European level, the starting point should surely be an overall market assessment, which is missing here. |
| 4) | The paper states that several companies have approached the RA with systems which could provide asset tracking services utilising spread spectrum techniques. However no explanation is given as to why this is the preferred technology for use here, rather than a technologically neutral approach being adopted with candidates proposing their preferred technology. |
| 5) | The presumption being made is that asset tracking is a separate market, which may already be covered by other spectrum assignments. Mobile Data Association operators already offer this type of service, but perhaps as an adjunct to other data or indeed voice services. The presumption that location of assets needs special tracking separately from the location of people or vehicles is not explained. Regarding the market definition, the asset tracking options available on GSM, satellite, mobile data (e.g. RAM), and PMR licensees are not adequately considered. |
| 6) | The possibility of a combination of technologies should also be more encouraged than is the case in paragraph 1. 1. |
| 7) | Against a current base of 16 million UK cellular customers, asset tracking is not likely to be seen as a big business - but this does not mean it is being ignored by the operators or their value added service providers. The totals for paging and mobile data customers are currently 1.6 and 1.7 million respectively - these seem a notable omission from paragraph 1.2. |
| 8) | The current competition for asset tracking is also not well covered in paragraph l.2. For example, no reference is made to satellite or the future competition from DAB, GPRS or UMTS. It presumes that an alleged lack of effort by existing operators justifies the release of new spectrum (an acknowledged scarce resource) to a special technology, without a proper competition analysis or a full market assessment. Whilst it is noted in the paper, that data is currently a "small" percentage of today’s total traffic for cellular GSM / TETRA and PAMR, it is growing fast - particularly in the messaging arena. (Note that this is not the situation on the fixed networks where data volumes are substantial.) The 65,000 customers cited significantly understates the true customer base since other technologies such as GSM Short Message Services are ignored. |
| 9) | The basis for the policy adopted for the assignment of this spectrum - a competitive process rather then an auction - does not seem to be explained. The apparent situation here -a single operational system to be licensed (para 5(2)) combined with (presumably unsolicited) interest from a number of parties (para 1.1) - would seem to have the ideal characteristics for an auction. |
| 10) | The spectrum requirement should be matched to the realistic demand taking into account the possibility of supplying the service by other means. |
| 11) | The spectrum plans are all in the bands within 863-870MHz which, whilst not part of the current cellular allocation in the UK, might, in the longer term, be considered as candidate bands for extending the UMTS service (see Report No. 7 from the UMTS Forum). It would be unfortunate if the longer-term view of spectrum for public mobile radio telephony and data was to be comprised. |
| 12) | In terms of interference management it does not appear to be logical to attempt to control interference by user density and geographical distribution parameters "agreed at the time of issue of the licence" because the transponders are in the assets being tracked – which are mobile. |
| 13) | Assessments of interference appear highly subjective in many cases, e.g. "is considered acceptable" and "considered such that is it unlikely to be noticed" and give little comfort at this level of explanation of the data. Other areas of interference are noted as not having been investigated at all. |
In conclusion, if the decision to provide spectrum for asset tracking services using spread spectrum techniques is to be confirmed, then BT Cellnet would support an approach where this application shared spectrum with other low power short range devices. However on the basis of this consultation, BT Cellnet does not believe that a valid case has been made for the proposal in principle or the assignment process in particular.
BT Cellnet
June 1999
RA Response to #7
With regard to point4, CDMA was not necessarily the preferred technology, but
merely one which affords high efficiency in terms of spectrum and throughput and
furthermore, one which has been tested under controlled conditions to be able to allow
sharing of this valuable part of the spectrum.
The point raised in 11 implies that this spectrum, recognised as one of the suitable candidate bands for extending the UMTS service (see Report No. 7 from the UMTS Forum), may be unduly inhibited by the use of this part of the spectrum for an asset tracking system. It should be noted that this is a long term viewpoint and takes little account of other services in the short term. The existing services using the spectrum will have to be migrated in time anyway and if this new (shared) allocation fits in within those timescales no further restriction is introduced. It is true that the spectrum options are all in the bands within 863-870MHz, and it is this spectrum that lends itself to refarming in the short term.
Timing
The response drafted by Graham Kersting from BT Cellnet raised the procedural issue
that although the Press Release appeared on 26th May, their copy (they say) was
not received until 14th June and the (RA) web version was not published until
15th June.
In fact a copy of the Consultative Document was lodged with the RA library (available by fax / mail) at the same time as the press release. In addition, the Press Notice (which accompanied the consultation document) was redrafted by Press Office on Friday 14th May and put before Mr Wills on the evening of Monday May 17th.
Nokia
James Page (01252-865284) for Nokia UK Ltd.
The response from Nokia stated that they had not had time to make a detailed study (being available on the RA website on the 15 June), but made the following observations.
| 1) | We believe this band has only recently been allocated Europe-wide for cordless audio and it would be wrong to introduce potentially interfering low duty-cycle systems. Cordless audio is particularly vulnerable to bursty and transient (mobile) interferers. |
| 2) | Long term the band could be a candidate for 3G extension: we feel this possibility ought not be jeopardised at this stage. |
| 3) | Further information on the RA tests are required before it would be possible to determine the acceptability of the interference, in particular at what distance is the interference audible? If the tracking devices have a power density of 50mW/MHz then it is likely that the interference range could go beyond the boundary of a house/flat, and certainly a vehicle. The consultation paper states that agreed population densities should not be exceeded, acknowledging that there will be some significant interference. The population density & interference level are clearly crucial to the acceptability, as are any ‘operational constraints’. Paragraph 1.4 mentions ‘home security’ which may not be a compatible application with CAD. |
| 4) | If such systems could be shown not to cause problems, then for competition reasons, more than one licence should be awarded, since it is likely that the spectrum could be shared by two such spread-spectrum systems. At least there should be competition at the service level. Perhaps the base stations could be jointly owned/managed. |
| 5) | It is assumed that in accordance with Directive 99/5 (RTTE) the interface specifications would be published in advance by the operators, to provide competition in the terminal/transponder supply. |
| 6) | We note that paragraph 1.3 states the proposed spread spectrum systems are expected to be lower cost, but no specific reason is given for this. Sharing with narrow band systems is possible, as stated, but this may cause interference to the narrowband system. |
RA Response to #8
The point raised in 2 implies that this spectrum - recognised as one of the suitable
candidate bands for extending the UMTS service (see Report No. 7 from the UMTS
Forum), may be jeopardised by the use of this part of the spectrum for an asset tracking
system. It should be noted that this is a long term viewpoint and takes little account of
other services in the short term.
The existing services using the spectrum will have to be migrated in time anyway and if this new (shared) allocation fits in within those timescales no further restriction is introduced. However, it is accepted that significant customer penetration of a technology can have practical and consumer demand / cost / inconvenience implications when clearing a band
It is true (point 1) that the band has recently been opened up for Cordless Audio as a result of a decision made by CEPT WG-FM. The reason for this decision is that the harmonised CT2 band is little used by this technology in the rest of Europe and there is significant pressure to use the band for other services such as SRD s, Cordless Audio Devices etc.
The proposal to allocate 863-865 MHz to Cordless Audio Devices (sharing with CT2) was based upon adjacent band compatibility studies carried out within CEPT PT-SE7. The work included results and conclusions from some authoritative work carried out by RTCG on behalf of CEPT SE7.
Further tests, carried out by RTCG, indicate that an Asset Tracking System using CDMA technology sharing with Wireless Audio Devices (and CT2) is feasible assuming one operational system. The loss of CT2 channels would be limited therefore to those already impacted by Wireless Audio Devices.
As the Wireless Audio Devices become more widely used, the "total channel capacity of the CT2 spectrum" would be progressively reduced from the theoretical maximum of 40 channels to around 28 available channels. Therefore, the CT2 channel capacity will be reduced even if the Asset Tracking System is not approved.
Low Power Radio Association
For information on the response, see the author, Mr Brian M Back (01422 88 64 63)
RA Response to #9
The harmonised band has recently been opened up for Cordless Audio as a result of a
decision made by CEPT WG-FM. The reason for this decision is that the harmonised CT2 band
is little used by this technology in the rest of Europe and there is significant pressure
to use the band for other services such as SRD s, Cordless Audio Devices etc.
This decision to allocate 863-865 MHz to Cordless Audio Devices (sharing with CT2) was based upon adjacent band compatibility studies carried out within CEPT PT-SE7. The work included results and conclusions from some authoritative work carried out by RTCG on behalf of SE7.
Further tests, carried out by RTCG, indicate that an Asset Tracking System using CDMA technology sharing with Wireless Audio Devices (and CT2) is feasible assuming one operational system. The loss of CT2 channels would be limited therefore to those already impacted by Wireless Audio Devices.
As the Wireless Audio Devices become more widely used, the "total channel capacity of the CT2 spectrum" would be progressively reduced from the theoretical maximum of 40 channels to around 28 available channels. Therefore, the CT2 channel capacity will be reduced even if the Asset Tracking System is not approved.
The Radiocommunications Agency has the right to allocate spectrum within the UK as it sees fit. This decision, once made will be based upon, amongst other things, proven engineering principles on exactly the same basis as the original work proving that CAD’s could co-exist with CT2.
| FEI 99/464 Mr Brian Last Cc: Nick Williams, CII Division, DTI 15th July 1999
|
Russell Square House Tel: +44 (0) 171 331 2000 Email: feedback@fei.org.uk Web Site: http://www.fei.org.uk/fei |
Dear Brian,
FEI Comments on the RA
Consultation
"Spectrum for Asset Tracking Mobile Data Networks"
June 1999
Apologies for the late submission of comments from FEI, which have taken some time to assimilate from our wide Membership.
FEI is recognised by the DTI as the lead trade association for the UK Electronics Industry, representing the Information and Communications Technology, Defence, Components and Office Technology sectors.
I have kept our comments (attached) as concise as possible, but would like to highlight the following key points:
I trust that you will be able to incorporate our views into your assessment of the responses given. If you require further information, please do not hesitate to call.
Yours sincerely,
Simon Wilson (signed by PC)
Simon Wilson
Senior Executive, Radio
| February 2000 |
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