Summary of Responses for the Consultation Document Spectrum for Asset Tracking Mobile Data Networks

Summary of Responses for the Consultation Document "Spectrum for Asset Tracking Mobile Data Networks"

The RA is grateful to all those who took the time to respond. This document represents a summary of the comments received and the subsequent RA reaction.

Following representations from late respondents, the RA was able to extend the time-scales where appropriate, so as to give more time for detailed responses to be received by the revised cut off date on 26 June 1999. As a result eleven responses were received and are referred to below;

Nortel Networks, BT Networks and Systems, BT Paging, QNL (UK) Ltd, APD Comms, RAM Mobile Data, BT Cellnet, Nokia, Low Power Radio Association, FEI.

Of the eleven responses received, only two were potential bids. The other nine responses being in the nature of comments.

Of these;

	two were firm bids,
	two had concerns about the existing CT2 PABX market, using equipment located in the lower part of the band,
	two had concerns about Third Generation extension spectrum,
	two had concerns about Spectrum Pricing issues,
	one had concerns about the impact on Short Range Devices,
	one had comments about the existing Data network operators being able to serve this market,
	one had comments about existing paging operators being able to cater for this element of the asset tracking system.

Issues

	The time-scales for the consultation have been criticised, but 4-6 weeks is considered adequate for relatively ‘routine’ consultations and we have extended the period when requested.
	A consideration which we intend taking on board to assist with focus and clarity in future condocs, is the requirement to separate out the consultation and the bidding stages of the process.

In the past few years a number of companies have developed systems which could provide asset tracking services utilising spread spectrum techniques. Proponents of these systems argue that the market for relatively low cost asset tracking services is potentially huge and is a niche market not being adequately served by the existing mobile data network operators.

It was stipulated that written comments would be made publicly available except where respondents indicated that their response or parts of it were confidential. Respondents were requested to separate any confidential material into a clearly marked confidential annex. Unconditional permission was assumed unless the author expressly stated otherwise. Any copyright attached to responses was assumed to have been relinquished unless it was expressly reserved. See attached Annex for responses and contacts.

Three principal issues were raised:

	impact on CT2,
	3G expansion,
	effects on low powered devices.

The issues identified are:

i	CT2 - Nortel and BT Networks and Systems favour 868-870MHz. Clearly, as this band is recognised as the harmonised segmented band within Europe for SRDs and embodied within T/R 70-03, it was not a realistic option for the sharing of CDMA Asset Tracking Systems. It was felt that allocating the CDMA systems within the 2 MHz located at the top of the CT2 band would be more preferable than at the bottom, from both the SRD and CT2 perspectives
ii	Admin pricing. Based on the spectrum tariff unit of Ł1.65 /MHz/km², the fee for a single 2MHz of spectrum would be Ł792,000. 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. 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. Subject to the RA’s continuing investigation into the possibility of licensees being able to share a CDMA band, the basis for setting the licence fees for this technology may need to be reviewed in the future to take into account any appropriate modifiers.
iii	3G expansion - raised by BT Cellnet and Nokia. Nothing is certain on 3G expansion bands. Should the spectrum fall within the expansion bands there will be many applications which will need to be migrated and asset tracking is just one of them;
iv	European harmonisation - BT Cellnet think this would be a good thing but no overall market assessment has been done. A confidential response also said that we may simply encourage a proliferation of standards which would not be good. We are letting the market decide the standards to be used. At this time, there is no spectrum harmonisation and we do not expect any for some time. The RA is aware of the recent questionaire circulated by the ERO and the initiative within CEPT to address the issue of harmonised spectrum for Asset Tracking systems and intend to participate fully in these activities. The RA actively promotes the harmonisation of radio spectrum at the European level and participates in studies to this end. The accommodation of this service (by sharing this part of the 900 MHz spectrum) is unlikely to be an inhibitor to the longer-term development of the market in the event of harmonised spectrum for various data applications being designated by CEPT.
v	Why not an auction? - A point made by BT Cellnet. Given the applications received, we do not believe an auction is necessary. Only two applications were received, one of which was more developed than the other. We do not rule out the possibility, however, of in time licensing both applicants and maybe more;
vi	Other options - BT Cellnet referred to GSM, SatNav, mobile data and PMR providing alternative technologies. These systems are not focused on asset tracking and the more competition the better?

One of the responses comprised a firm and comprehensive bid with a second show of interest in principle. In view of the business case made, the RA has decided to award a WT Act licence for the provision of asset tracking mobile data to QNL (UK) Ltd. However, the RA believes that it may be technically feasible to accommodate both QNL and further operators in the available spectrum. Further testing will be required before this can be decided for certain. In view of this, the licence awarded to QNL will include a condition that would require the company to synchronise its network with that of other operators should it be found that this could be possible. A decision on a second application is likely, therefore, within 6 months. QNL will be able to begin its operations as soon as WT Act and Telecommunications Act licences have been issued to the company, which will likely happen during March 2000.

Two main options remain as favourites subsequent to the studies and consultations. These are:

863 - 865 MHz

This band is designated within CEPT Recommendation 70-03 for use by Wireless Audio applications and consumer radio microphones. CT2 cordless telephony products currently use the upper part of this band (864.1-865 MHz).

The RA has conducted sharing compatibility studies between spread spectrum CDMA systems and Wireless Audio devices. The spread spectrum characteristics of a representative asset-tracking network were used in these studies and the report concluded that sharing is acceptable, based on certain operational constraints and a defined user density per unit area.

866 - 868 MHz

This band is currently used by Cordless Telephony CT2. The future of CT2 has been recently reviewed and the RA is mindful to allocate 866-868 MHz for CDMA Asset Tracking Systems.

The RA has received responses to the consultative document representations from the Short Range Devices, CT2 and Paging sectors. FurthermoCT2 and Two Way Paging (TWP), In view of these responses and the further representations, the RA the RA has given further consideration to the options at hand and decided to locate the Asset Tracking service between 866-868 MHz.

Paging channel

A small number of paging channels are required by these systems unless the tracking network utilises existing paging networks. It has not been possible to identify any spectrum around 900MHz. Channels are available for this application around 200 MHz. The radiated power for these stations should be assumed to be limited to 25 watts, ERP.

The attached Annex A gives both the response and the RA reply. In the event where confidentiality was expressed, the author and contact number is given followed by the RA reply.

Consultation document Spectrum for Asset Tracking Mobile Data Networks using Spread Spectrum Techniques (June 1999)

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February 2000