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Intercai Mondiale Ltd
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Dear Mr. Last
Subject: Comments of Intercai Mondiale Ltd On FWA Consultation Document
Intercai Mondiale is a leading UK based management consultancy focused on the telecoms industry - part of the Intercai group, an international organisation reaching across the information, communications and technology industries.
We offer strategic planning, implementation and business operations services in mobile telecoms, fixed telecoms, e-commerce, Internet, Intelligent Networks, satellite and cable services and have carried out a number of studies for Regulations and (potential) operators in the UK, Europe and North America. We have more recently been investigating the emerging business cases and technologies for providing high speed Internet access to residential and SME consumers, including the next generation of (fixed) wireless access, e-commerce and packet based services. Within this context we would offer the following comments and observations on the topics raised by the RA.
| 1. | Should the (ex Ionica) spectrum in question continue to be licensed for the FWA? |
| We believe the answer is yes. As a result of the pioneering work
done by the UK authorities, this band has now been adopted for harmonisation as an FWA
band targeted at residential and small business consumers by many countries worldwide, and
in particular by CITEL (in the Americas), Australia, Sri Lanka, Mexico, Brazil, Canada
etc, as well as the ETSI / European interests noted by the RA. This means that both the UK
and Global manufacturers are now able to optimise their developments around this band for
economical sale and the UK should continue to encourage, rather than discourage, this
trend. There are however some significant differences between the UK's restricted
allocation (as described) and the band plans now being harmonised elsewhere, and the RA
may wish to consider whether / how the UK situation could be brought more into line with
the Global harmonisation over time. We in turn would be happy to discuss this further with
the RA if appropriate.
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| 2. | Should the (voice) services allocation be retained? |
| In our experience there is insufficient commercial justification to
deploy a competitive overlay network based on residential and small business voice
services alone - especially as the usage charges for voice calls continue to decline as a
result of increased competition, and also as part of the incumbent copper loops become
available to competitive operators on reasonable terms. Apart from specific rural niches
the major commercial opportunities for wireless access to residential and small business
consumers lie in higher speed packet-based access to the Internet, corporate extranets,
VPN's and e-commerce portals. We therefore support the RA's proposals to specifically NOT
restrict the types of services to be offered. We note the bandwidth constraints, but are
also aware of emerging modulation technologies which might be able to overcome obstacles
(yet still be economically and practically deployable) in the next 1-2years. In any case
we believe that full quality, reliable single and multi-line voice service will be
deliverable over packet based access streams within the medium term, in addition to the
highly desired broadband data services.
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| 3. | Other Relevant Bands |
| We believe that the 10.5GHz and 28/40GHz bands mentioned will not
be generally suitable (for propogation and engineering reasons) to economically/reliably
provide wireless access to residential and small business consumers. A wireless access
operator would therefore also need licenses at lower frequencies (such as 3.4GHz) in order
to construct a feasible business case covering a viable mix of consumers. We therefore
urge the RA to keep an open mind on whether the 3.4GHz and 10.5, 28 and/or 40GHz licenses
should be kept together in some way in order to facilitate a more viable competitive
business case. We note that many European countries have chosen to "bundle"
their 28GHz and 3.4GHz licensing in some way.
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| 4. | Military Application |
In addition to the UK situation mentioned by the RA, we are aware the US Government has recently completed a very complex and extensive analysis of the potential interference and migration aspects of FWA and radiolocation systems for the 3400 - 3700MHz band, and that similar analysis is going on with respect to the Fixed Satellite Services (FSS) and FWA in this band. These results are being collected together within ITU Joint Rapporteur Group (JRG) 8A/9B, and are also being used to determine the licensing policy for this band in Mexico, Brazil, Canada and Australia, as well as the USA. We suggest that the RA review this new material with the UK Military authorities, and again we would be happy to discuss this further with the RA if appropriate. |
Conclusion
Intercai Mondiale Ltd commends the RA on its timely release of the FWA Consultation Paper and believe that viable business cases can be made for utilisation of the spectrum proposed, encompassing services required to meet growing and currently unmet needs of the SMW and residential sectors within the medium term.
Yours sincerely
Keith Gilbert
Managing Director
| 17 December 1999 |
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