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

25th January 2001

Dear Mr Jones,

We are responding to your formal request to comment on the scenarios for licensing of 3.4 GHz and 10 GHz spectrum that the Radiocommunications Agency recently published on its website.

PipingHot Networks is a supplier of 3.4 GHz network solutions for broadband wireless Internet access to markets throughout Europe. Founded in February 2000, the company is backed by significant venture capital funding from the Carlyle Group, Atlas Venture, The Convergence Group and Kennet Capital.

The company is a leading member of the Broadband Wireless Internet Forum (BWIF) with Cisco, Broadcom, Toshiba and Texas Instruments, the total membership now stands at 38 companies and all have committed programmes in development of the BWIF standard. BWIF has been established to promote an open standard for broadband internet access based on the DOCSIS cable modem standard and VOFDM; a technology that enables non-line-of-sight access to subscribers at high data rates.

PipingHot Networks has been impressed by the openness, efficiency and technical competency shown by the Agency and its advisors throughout the consultation period. The thoroughness of its technical and marketing analyses used as inputs to the business model presented at the meeting convened on 13 December 2000 in London is to be commended.

The conclusions of these studies confirm PipingHot Networks own business modelling in that they show that the limited bandwidth being proposed by Her Majesty's Government for licensing at 3.4 GHz and the costs of backhaul are impediments to the generation of a viable business case. PipingHot Networks, therefore, joins the calls of other members of the Broadband Wireless Association for the government to licence at duplex channels each of at least 25 to 30 MHz, as has been the practice of other European Union partner governments in the past 12-to18 months. Furthermore PipingHot Networks supports the need to change the duplex spacing from 50MHz to 100MHz, which will bring the UK in line with all but one of the other European countries. This would significantly reduce the cost of Customer Premise Equipment (CPE), a key enabler for business plans. The company also strongly suggest that the Government allows these frequencies to be used for backhaul in order to assist the business case for marginal and rural areas that might otherwise be excluded from the approaching broadband revolution.

PipingHot Networks believes that Scenario 5, in which licensing this spectrum is delayed until some undefined date, is not in the interests of small and medium sized businesses that are being denied the economic advantages of broadband access of larger city centre based corporations and their SME competitors in the rest of the European Union. It is our belief that this section of our economy requires an alternative to the residential market broadband solution of ADSL that is now being very gradually rolled out by the country's incumbent local loop operator. The only potential alternative small and medium sized businesses have is broadband wireless. PipingHot Networks encourages the government to make the licensing of this spectrum a high priority and to attempt to accomplish this before any general election that may be planned for this year.

The Radiocommunications Agency's own business modelling studies have shown that an auction for these frequencies, along the lines of the recent 28 GHz auction, is unlikely to encourage telecommunications companies to take up the spectrum; and on these grounds the 'beauty contest' systems adopted by our European partners is recommended.

PipingHot Networks proposes that the Government adopts a licence fee for the use of the spectrum, with an increased charge being imposed from year three onwards for areas covered by the licence that are not being served by the operator. We believe that two or three regional operators employing both the 3.4 GHz and 10 GHz spectrum allocations would provide the most advantageous model for the rapid deployment of broadband wireless access for SMEs, the general public and operators.

PipingHot Networks would like to thank the Radiocommunications Agency for this opportunity to comment on the options presented in its consultation document. We would be glad to provide any clarification on the observations contained in this letter and to explain the advantages of our 3.4 GHz broadband wireless access solution and the benefits of the emerging BWIF standard.

Yours sincerely,

Marcus Lovell Smith
Chief Executive Officer
PipingHot Networks