Marconi plc - Response to the Consultation Document: 3.4 and 10 GHz: Scenarios For Spectrum Packaging and Delivery

Dear Mr Jones

Consultation on 3.4 & 10 GHz: Scenarios for Spectrum Packaging & Delivery

Marconi has pleasure in submitting the following comments with regard to the Radiocommunications Agency consultation on "3.4 and 10 GHz: Scenarios For Spectrum Packaging And Delivery."

General comments

Marconi believes that limiting the spectrum allocation to 2 X 17 MHz in the 3.4 GHz band or 2 X 30 MHz in the 10 GHz band is very restrictive due to the following reasons:

Only one operator will be able to deploy a multipoint network in a given geographical region. This means that inadequate competition between Fixed Wireless Access (FWA) operators will lead to limited geographical coverage, limited services and unattractive prices offered to the end user. Thus there will be an insufficient pressure on an operator to extend his network due to competition e.g. from suburban to rural areas at least in his region.

The available bandwidth, particularly at 3.4 GHz is not sufficient to offer a wide range of telecom services other than basic telephony services and low data rates up to 2 X ISDN rates. This immediately hinders the ability of FWA operators to compete with the incumbent on the basis of ADSL, xDSL or e.g. 2 Mbit/s leased line services.

An extension of the systems transport capacity, possibly necessary due to the demand for higher bandwidth from existing customers or due to the increasing number customers in a given service area is not possible because no further spectrum (channel) is available. Thus the restructuring of the physical network by adding more central stations (base stations) is mandatory which results in a significant amount of cell planning, logistics and very importantly, new site acquisition. More bandwidth (say, a further channel) would provide a low cost solution to this problem. Only additional equipment at the existing site would need to be installed.

The useful business cases in the above mentioned bands (but in higher frequency bands as well) as has been stated by the Advisory Group, lay in the connection of Small and Medium Enterprises (SME), Small Office and Home Office (SOHO) and High End residential users, by what ever means. However all of these end user categories will require an increasing amount if bandwidth which could not (or at least only partly) be provided by the above-mentioned bandwidth available in each band. Thus it is very questionable as to the profitable return of investment to the operators.

In the report presented by the Advisory Group (13th December 2000) there was mention of the strong dependency of the business cases on the usage of microwave links to interconnect the central (base) stations to the network nodes. In our opinion it is very important that operators receive licences that gives them the possibility of installing their own microwave links for infrastructure support. This means that additional spectrum has to be available for FWA operators in other bands, not only in the long haul bands, (e.g. 6.2 GHz, 6.8 GHz or 7.5 GHz) but also in the medium haul bands (such as 13 GHz, 15 GHz and 18 GHz) and in the short haul bands above 18 GHz.

It should be noted that the channel plan in the 10 GHz band does not comply with the plan which was effective in 1997 and that the new plan is not consistent with the CEPT/ERC Recommendation 12-05

Taking into account the comments made above and the fact that an extension of the number of channels in the bands under consideration seems not be possible, it is Marconi's opinion that:

A national licence in the 10 GHz band is preferable

The 3.4 GHz band could be used for additional regional licences given to different operators or as a separate national licence.

Both licences should include a requirement to ensure coverage of rural areas on the basis that the operator could access a minimum number of possible customers per square km. This, we think, is a way to ensure that rural areas are also served by FWA.

To achieve an effective and efficient use of the spectrum, and to prevent spectrum sterilisation, the licensed FWA operator shall be required to prove after a given period of time that there is sufficient use of the spectrum resources to which they have access. This could be achieved through requiring that there are FWA central stations deployed in at least, for example, 25% of the given service areas characterised by suburban, urban and rural nature.

If an operator does not achieve the coverage requirement then they shall be required to give back the spectrum without refund.

The technology used by the operators in the 3.4 GHz and the 10 GHz bands should have to comply with radio parameters ensuring the efficient use of the spectrum. These parameters could be found in the relevant ETSI EN applying at least the medium stringent requirements stated.

The type of services that the operator is allowed to transport via the network is vital for the business case. Thus, in principle, there should be no restriction in respect of the services transported.

FWA is generally considered as the interconnection of the end user to the network via microwave links of all types (point- to-point, point-to-multipoint and multipoint-to-multipoint systems). However, for the business case of a FWA operator to be successful, it is of great importance whether he is allowed to transport with the same system, in the same frequency band, from the same site, not only information to end user categories as discussed above but also information to a network terminating point ( in the FWA network to "end user") owned by an other network operator, e.g. Mobile operator. Even if the Mobile operators are not allowed to offer FWA services to the end user through their Mobile infrastructure network, the FWA operator should still, in our opinion, be permitted (as terms of their licence) to connect Mobile base stations with their FWA network. This would enhance the business case of the FWA operator and would also support the desire that FWA operators provide services to the end user especially in rural areas. In this case the density of the FWA customers of interest is limited and the investment only pays off if the FWA network could transport a basic traffic load, such as by acting as a Mobile infrastructure support link.

In a number of discussions with Mobile operators, FWA operators, Service providers and investment groups this opinion was supported. Some of them expressed the view that this is the only way to create useful business cases for "FWA" operators.

With a licensing regime of the nature discussed above, Marconi believes that FWA can be successful.

Please do no hesitate to contact me if you have any questions or wish to receive clarification regarding any of the above points.

Yours sincerely,

Claire Thwaites
Government Relations Manager