|
KingComm Limited
|
KingComm Limited provides this response as an independent entity. Nigel King has been involved with the lonica technology since 1993. Much has been leamt since then about the economics and technology availability to support this frequency band for wide area access.
This response has been compiled from an essentially technical point of view which includes the best features of the lonica system to provide non-line-of-sight access to large percentages of communities and modem modulation and coding to provide larger data bandwidths and coverage.
The main points are:
 |
that the use of this band should be relaxed to allow a range of telecommunication services to supplied to business and residential subscribers. |
|
that the frequency duplex spacing should be adjusted to 100 MHz in order to standardise with the most common use in the world of these frequencies. |
| 1.2 | KingComm confirms that there is
much interest in the use of 3.4 GHz for fixed access purposes both inside and outside the
UK. Following your bold decision to supply these frequencies in 1993 much of the rest of
the world has standardised its use since, non-line-of-sight two way communication can be
supplied with high reliability and at low cost using these frequencies. |
|
| 3.1 | KingComm notes that you propose
to continue the current allocation of frequencies which use a 50 MHz duplex spacing.
KingComm believes that the opportunity to bring UK use in line with the majority of the
rest of the world1 should not be lost. The majority of other licenses in this
band in the world use 1 00 MHz duplex spacing. There are two reasons for considering a
change to 100 MHz duplex spacing; |
|
| (a) | Economies of scale in the equipment design
and manufacturing processes would benefit from a change. It would lead to lower cost
equipment being made available for the UK market. |
|
| (b) | Technology availability and cost forces the
Consumer Premises Equipment (CPE) to operate in a half duplex mode when the duplex spacing
is 50 MHz whereas, 1 00 MHz duplex spacing would allow full duplex operation at low cost.
Duplex operation will enable more efficient use of the spectrum and also allow the use of
some well established air interface protocols. |
|
| A movement of the upper
(downlink) band from 3475-3492 MHz to 3525-3542 Nffiz, swapping the use of these
frequencies with the occasional video services (ENG/OB) which operate in that band, would
be of great benefit.
|
||
| 4.1(i) The limited bandwidth and technology availability of 1993 only allowed the use of this band for narrowband voice services. Advances in processing power, modulation, coding and in the understanding of propagation at these frequencies makes the use of these frequencies for broadband services a real economic possibility. Furthermore, the most efficient way to use these frequencies is for bandwidth on demand services to Small Office Home Office (SOHO) and residential subscribers. | ||
| (a) | Favourable propagation and low cost components enable wide area coverage with a high probability of being able to service every location. |
|
| (b) | Many additional lines in the UK are required for internet access. From a usage perspective this is not provided very efficiently by circuit switched narrowband services. Typical internet access does not use as much bandwidth on average as voice services. The user experience however can be enhanced enormously by the provision of greater bandwidths being available for short bursts on demand and also by the provision of services that are always available to the user without large modem training times. | |
| 4.2 | KingComm Limited supports the view that the 3.4 GHz band should not be restricted to the provision of voice services. | |
SOHO Small Office Home Office
CPE Consumer Premises Equipment
1 Much of Europe, Mexico and South America have standardised on 100MHz duplex spacing particularly for new licenses
| 19 December 1999 |
|
