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Airspan Communications
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Harmonisation
In the Green Paper on Radio Spectrum Policy by the Commission of the European
Communities in 1998 the need for a "Consistent Community Radio Spectrum Policy"
was clearly highlighted.
This principle was further expanded to include the provision of coherent radio spectrum access at Community Level as a means to use the limited spectrum efficiently, to minimise future conflict in allocations, and to assist and improve market condition for both operators and vendors in an ever increasing Global market place.
The majority of European countries including Sweden, Germany, Ireland, France, Italy and Spain, who have also allocated the 3.4 GHz band to RFA, have based allocations on the channel plan with 100 MHz duplex spacing. This has allowed operators to provide a wide range of services
Further clarification is provided in response to paragraph 3.1 below.
Choice of Vendors
The choice of vendors who can provide equipment that operates in the 3.4 GHz plan
according to the lonica allocation is very limited. Re-allocation with a duplex of 100MHz
will allow potential operators a considerably greater choice of manufacturers.
Breadth of Services
Advances in technology now mean that services above beyond conventional POTs can be
offered to consumers using channel plans previously considered as 'narrowband
allocations". This advancement can only be passed to users by the use of appropriate
technology that generally is provided by equipment operating with 100MHZ duplex spacing.
Further clarification is provided in response to paragraph 3.1 below.
The following pages provide a detailed point by point response to the Consultation Document.
1.1
Radio Fixed Access (RFA) is the ideal method of increasing competition in the fixed
telecommunications market due to the advantages it offers in terms of cost effectiveness
and deployment time. For these reasons RFA or Radio in the Local Loop (RLL) has been used
worldwide to expand the choice of operators and hence services available to users.
Any change or allocation of available spectrum should ensure that it is carried out to maximise the opportunities for operators to deliver the widest possible range of services to the widest possible subscriber base.
1.2
There is tremendous demand from 'second" operators in the UK for the ability to
expand existing operations and services. This is most readily achieved by the use of RFA
and the advantages that can be gained through speed and flexibility of deployment offered.
However the lack of suitable spectrum is inhibiting the expansion of competition in these
areas. Reallocation of the 3.4 GHz band provides the ideal opportunity to address this
situation.
1.3
The comments in this document apply to the specific reallocation of the 3.4 GHz band
1.4
Noted
1.5
These comments are not provided in confidence and may be used by the Agency if
required.
2.1
If the Government is to ensure that both Residential and Business markets are provided
with the widest choice of services and operators, reallocation should be carried out in
such a fashion as to maximise the choice to potential operators in terms of equipment
available from the widest manufacturer base.
The existing Spectrum Allocation is only supported by a very small number of manufacturers. Thus any potential operators in this band will have a limited choice of equipment suppliers and by the nature of this equipment will only be able to provide a limited range of service to public. A fundamental change in the re allocation would allow a greater choice in terms of equipment manufacturers and hence services to the public. It is our recommendation and comment that the band 3.4 -3.6 be allocated to FWA access using a band plan with 1 00 MHz duplex spacing according to CEPT TR14-03 Annex 11.
3.1 3.4 GHz
As stated above the use of 50 MHz duplex limits the range of equipment available to
potential operators.
The majority of European countries including Sweden, Germany, Ireland, France, Italy and Spain, who have also allocated the 3.4 GHz band to RFA, have based allocations on TR 1403 with 100 MHz duplex spacing. This has allowed operators to provide a wide range of services above and beyond the conventional limit of Pots services including:
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Analogue telephony (POTS) at both 32 and 64 kbit/s |
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Voice-band Group 3 facsimile and data up to 56kbit/s |
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Payphones, including pulse metering |
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64kbit/s and n x 64kbit/s leased fine data services |
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Basic rate ISDN (2B + D) |
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Always-on TCP/IP connections |
The apparent constraints imposed by other users including the MoD can be overcome by systems employing appropriate technology.
Technologies such as CDMA are very resilient to external interference. Also through the use of Automatic Power Control (ATPC) and the use of minimum transmit powers, they do not contribute as much interference as other technologies (such as TDMA initially used for the lonica deployment). Co-ordination would be required but with correct network planning and established co-ordination interference limits mutual co existence could be achieved.
3.2 Equipment and Antenna Standards
Airspan Communications recognises the development of Standards as an essential part of
harmonisation not just within Europe but beyond as ETS] standards become more widely
accepted.
4.1
The market segmentation is becoming less defined as operators are seeking to widen the
range of services they can provide. As a result WFA manufactures are developing and
manufacturing ever more technically efficient equipment to meet these needs. Using Airspan
equipment it is possible for WFA operators to provide a full range of services in the 3.4
GHz band including 32 kbit/s and 64kbit/s telephony, ISDN, leased line data and shortly
packet data at speed of up to 512 kbit/s
4.2
Advances in technology permit operators to deploy networks that can now support all of the services detailed above in the 3.4 GHz band. However this can only be achieved by making spectrum available in bands where equipment capable of supporting such advanced services is available.
Airspan Communications agree that a single national licence will probably provide the best use of spectrum considering the potential co-ordination issues with existing MOD usage, and the need for guard bands or complex co-ordination limits that would need to be established with regional or multiple licensing.
Noted. These comments have been provided in direct response to the use of the 3.4 GHz plan although the principles of making maximum use of available spectrum in the most efficient manner to the maximum number of operators apply across all bands.
Noted. Airspan Communications is already conducting trials with a number of operators throughout Europe and as such would be prepared to fully support any trial deployments in the UK and would be pleased to work with the RA to establish co-ordination criteria to allow the most effective use of spectrum possible.
In the Green Paper on Radio Spectrum Policy by the Commission of the European Communities in 1998 the need for a 'Consistent Community Radio Spectrum Policy" was clearly highlighted.
This principle was further expanded to include the provision of coherent radio spectrum access at Community Level as a means to use the limited spectrum efficiently, to minimise future conflict in allocations, and to assist and improve market condition for both operators and vendors in an ever increasing Global market place.
Given the opportunity to re-allocate the 3.4 GHz Spectrum to FWA operators it is the opinion of Airspan Communications that this should be used as the chance to address the future harmonisation plans within CEPT, and to follow the lead set by the German and Irish regulators, who in providing spectrum for FWA did so using 100 MHz duplex spacing.
Therefore Airspan Communications believes that the 3.4 GHz spectrum should be reallocated on the basis of 100 MHz duplex according to TR14-03 Annex 11. Given the usage by the MOD and other services Airspan Communications would be pleased to discuss any issues arising from this reallocation Furthermore Airspan Communications would be pleased to take part in any Co-ordination exercise required including the provision of trial equipment to demonstrate the advantages that technologies such as DS CDMA has in situations where interference is a concern.
Airspan Communications is a leading supplier of high reliability, full service fixed access wireless local loop (WLL) solutions for telecom service providers throughout the world. Airspan's products provide the most comprehensive wireless alternative to a wired network infrastructure, with no compromises on available services or quality. Operators utilise Airspan equipment for the provision of voice, data, ISDN and Internet services to their customers. Airspan has implemented thousands of lines of wireless fixed access capacity with many of the world's leading telecommunications companies.
Originally a division of DSC Communications (now Alcatel), Airspan was formed in early 1998 and is now owned by a syndicate of major venture capital firms. Airspan is one of the world's largest wireless infrastructure companies, focused exclusively on the "final mile", with one of the most experienced and strongest CDMA engineering teams in the business.
Airspan designs and develops infrastructure products and services for both ETSI and ANSI markets with a focus on both circuit and packet 1 IP switched networks. The core Airspan CDMA technology has been well proven through the numerous deployments of networks worldwide. Airspan advocates open architectures for voice and data convergence and is introducing a family of wireless packet access products to augment the mature circuit switched product line
Airspan Communications
Cambridge House
Oxford Road
Uxbridge
UB8 1 UN
Middlesex
UK
Telephone +44 (0)1895 467100
Fax +44 (0)1895 467101
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