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Mid Wales Partnership - Response to the Consultation Document: 3.4 and 10 GHz: Scenarios For Spectrum Packaging and Delivery

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Patricia Hewitt MP
Minister of State for Small Business and E-Commerce
Department of Trade and Industry
Room 865
1 Victoria Street
London, SW1H 0ET

25th January 2001

Dear Minister,

Re: Fixed Wireless Access - Rural Wales

I write on behalf of the Mid Wales Partnership (which consists of the organisations shown on the attached sheet) in response to your consultation paper on the Government's plans to make available spectrum license for FWA at 3.4 and 10GHz.s.

The Mid Wales Partnership (MWP) was encouraged and optimistic to read your announcement following the award of licences in the 28GHz and 40GHz spectra. You stated in November that…. "you will work with public and private sector stakeholders to pull together various broadband initiatives that are being pursued at national, regional and local level into an effective programme for getting broadband services to every part of the UK."

In a later press release in December, you also mentioned the use of public money to stimulate telecommunication investment to correct market failure, and gave an example of the Llwybr.Pathway Project in rural Wales using ERDF monies to upgrade 10 rural phone exchanges (in conjunction with BT and the Welsh Development Agency).

A further highly innovative roll out of a broadband telecommunications backbone (1.2Gb capacity) through the counties of Carmarthenshire, Ceredigion and Powys has just been completed utilising microwave technology. This project is again part of the Llwybr.Pathway ERDF funded Project and is known as MARAN (Multi Agency Rural Area Network) and is a partnership of the three unitary authorities and Llwybr.Pathway - a document explaining MARAN is attached. This network infrastructure has been completed by MLL Telecom, which has also invested substantially in the network's construction. The partners have purchased a managed network from MLL, something that was previously regarded as too expensive and unaffordable.

The recent completion of this broadband microwave network and planned future expansion into smaller settlements through seeking European Objective 1 and 2 funding means that up to 46% of the land mass of rural Wales will be well placed to make use of both Broadband and Public Fixed Wireless Access spectra by providing affordable bandwidth to micro enterprises, SME's and residential users which they otherwise would be unlikely to be able to access. Planned roll out of services such as ADSL through BT and local loop unbundling are likely to exclude vast geographical tracts such as rural areas. The opportunity of using wireless technology could close the digital divide in rural areas. There is also, of course, the educational aspect. Many of our rural primary schools are unable to receive ISDN services. We see the MARAN network as providing National Grid for Learning materials to our schools to ensure they are included.

As you will know no bids were received for the licence for Wales at 28 and 40GHz. We understand that discussions are taking place now with the Radiocommunications Agency on how best the licences at 3.4 and 10GHz can be awarded for the best advantage of all and in particular rural areas. It is this in mind that the MWP wishes you to respectfully consider such arrangements that would assist in the provision of affordable bandwidth and services to rural Wales.

The auction of such licences may be attractive in raising revenue for the Government however, any fees paid must be recouped by the licensee through higher user end costs. A rural area is already incurring higher costs to establish such networks and cannot afford to pay the additional costs associated with auctioned licences. We are of the opinion that for rural areas, licences should be awarded on a "first come first served basis". As stated above the backbone MARAN microwave network is already established in rural Wales. MLL Telecom is a carriers' carrier and their business case and strategy is based on building a network on which any operator or service provider can buy capacity. There is another matter that precludes roll out of microwave networks in rural areas and that is spectra licensing. We understand that each "hop" requires licensing. By definition a rural area requires many more hops to obtain geographical coverage and subsequently a network operator has to pay more fees. We consider that a review is needed on payment for spectra to ensure affordability to assist the roll out of microwave networks in rural areas.

We would be very pleased to discuss MARAN and how best it can be used to close the digital divide in rural Wales with you or your officials and in particular the best way that Broadband and Public Fixed Wireless Access in the various spectra could be utilised.

MEMBERS OF THE MID WALES PARTNERSHIP

CEREDIGION COUNTY COUNCIL
GWYNEDD COUNCIL
POWYS COUNTY COUNCIL

WELSH DEVELOPMENT AGENCY

MID WALES TEC

FFORWM

UNIVERSITY OF WALES, ABERYSTWYTH
UNIVERSITY OF WALES,

LAMPETER FARMERS UNION OF WALES

WALES TOURIST BOARD WALES COUNCIL FOR VOLUNTARY ACTION

WALES TUC

CBI (MID WALES)

MID WALES MANUFACTURING GROUP

THE EXPORT ASSOCIATION

THE EMPLOYMENT SERVICE (WALES)

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