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Utility
Radio Networks
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Utility Radio Networks (URN) are pleased to respond to the Consultation Document on the best way to utilise the spectrum available at 3.4 GHz to provide competitive communications services within the United Kingdom.
Respectfully, but contrary to the view expressed in the Consultation Document, URN believe that the two 17 MHz channels on offer can provide significant broadband services across the country to the business community, provided that use is made of state-of-the-art radio systems which utilise multipoint network topologies, rather than conventional cellular architectures.
Furthermore, these broadband business services can be provided on a local basis addressing the structure and needs of local industry and commerce, as well as local conununity services, in a way that is presently not provided for by current service suppliers.
Such services could include fractional and multiple El links, intersite data at Ethernet speeds, video conferencing and remote teaching systems, surveillance, telephony and high speed Intemet access.
Likewise, URN believe that the 10 GHz band will allow further extension of such services with an even larger community of service providers and demographic coverage.
Utility Radio Networks (URN)
This organisation has been formed to promote and develop the concept of local area networking, that can be provided by a multiplicity of independent local service providers, utilising radio equipment which provides broadband access and local network infrastructure.
The radio systems that will be deployed create "mesh" networks, although the ITU term "multipoint" will be used in this submission in preference to mesh. The unique characteristics and benefits of such network topologies are described briefly in Technology Innovation section following.
The overall business concept of URN is illustrated in Appendix A.
Competition and New Services
URN believe that UK competitive policy, market innovation and user's best interests are better served by not allocating the 3.4 GHz band to yet further POTS services. It is submitted that this is a market area that is already over-subscribed, not only by British Telecom, but by the many new telephony service companies as well as by cable TV companies who are offering telephony. The former tend to address the city-centre business market, the latter the residential market.
We believe that the business strategy adopted by lonica was implicitly bound to founder from the start in that it addressed the very low profit residential market and tried to compete on price with a capital-intensive radio system. The fact that this system was untried and suffered the inevitable development problems compounded the difficulties, and, unfortunately, failure followed.
URN
By contrast, we draw attention to Atlantic Telecom, who have built most successfully upon an existing market presence and who have developed their fixed wireless access business on a "parochial" basis.
The URN market concept is to promote a multitude of local radio network operators who provide broadband communications services as described above, by means of multipoint radio systems that only require a limited bandwidth.
Consequently, we favour a new concept: that of provincial or "parish" licences, rather than national or regional licences. These would be granted to small, but viable, independent companies seeking to supply local services of all sorts.
Appendix B gives a further analysis of the benefits consistent with the competition policies of HM Government as well as EU policy.
Technology Innovation
URN intend to utilise the latest radio technology to supply local broadband services. This technology uses multipoint network architecture to create broadband networks that can re-use the available radio channels almost indefinitely.
A key characteristic of such systems is that they use narrow radio beams between stations which can be switched in direction and time. The consequence is that the available frequency band can be re-used indefinitely, and each node in the network can have the full channel capacity available for communication. Thus a single 17 MHz channel can easily support a 34 Mbit/s data rate to the user.
One of the foremost suppliers of such innovative multipoint radio systems is TimeSpace Radio AB, (TSR) of Lund in Sweden. It is the intention of URN to use TSR equipment initially for creating localised spectrum-efficient broadband networks for business and social applications.
TSR have been active in the ETSI standards process for several years, including TM4 and BRAN. Their present systems conforms to EN 301 021 and they are involved with the MWS standard development. They have also initiated new Work Items for steerable antennas within TM4.
Business Premise
URN believe that the most effective way of providing new and competitive services within the UK environment is by enabling local enterprises to provide broadband radio services to the local community and SMEs.
URN aim to provide the necessary equipment, installation and maintenance support, investment capital, marketing and implementation expertise to the local network operators. It also aims to negotiate national interconnect agreements with appropriate carriers for telephony purposes.
URN will also undertake the spectrum management aspects of network roll-outs, given that there are two 17 MHz channels available, and that there may be many operators in one district. It is considered that the 17 MHz channels should be adequate for most local enterprise needs, and facilitate local competition by using TDD multiplexing.
Appendix C gives further details of the financing of the URN enterprise.
URN
Exemplars
In Scandinavia, although driven by needs other than competition, broadband access of the type described above has been provided using multipoint network topology by TimeSpace Radio. The first customers have been the "Communes" which approximate to local authorities in the UK.
The applications are initially for remote teaching using video techniques, data communications (including Intranet) and telephony. Other installations include an ISP who is presently testing high-speed access for business customers using the TSR equipment for local (subscriber) access.
Other TSR system applications include cellular network backhaul. Such networks can be for mobile telephony or for FWA. Note that multipoint networks do not need separate backhaul - it is intrinsic to such systems, which contributes yet further to their overall spectrum efficiency.
TSR equipment is also being installed in France and Germany.
Further details, subject to commercial confidentiality considerations, may be obtained from TSR.
Conclusion
We are aware that the multipoint network architecture that we are proposing to install is novel and may lead to a re-appraisal of the way in which spectrum is seen and managed within the UK national regulatory framework. We are confident that it will provide a unique opportunity for the UK to lead in innovative, competitive telecomniunications service deployment.
The Principals of Utility Radio Networks will be happy therefore to present their ideas and supporting data to the Agency and the Department. Their Career Profiles are given in Appendix D to this document.
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