WirelessNet.co Limited Response To The 3.4 GHz Consultation Document

Response to the Radiocommunications Agency Consultation on 3.4 GHz Fixed Wireless Access Spectrum

1. Introduction
2. Background
3. Frequency Bands
4. Releasing more bandwidth
5. Equipment and Antenna Standards
6. Proposals
7. Number of operators
8. Other related issues
        27.5-29.5 GHz and 40.5-43.5 GHz
        Test and Development Trials

9. Confidential annex - not for publication

This is the response of WirelessNet.co Limited ("WirelessNet") to the Radiocommunications Agency consultation document relating to the disposal of the 3.4 GHz spectrum previously allocated to lonica.

We would like section 9 of this response to remain confidential.

Where relevant, sections from the Radiocommunications Agency consultation document are quoted in italics, and WirelessNet's comments follow.

"2.1 The Government is committed to ensuring that modern telecommunications
networks are as widely available as possible across the UK. Efficient telecommunications
services play a vital role in the modern economy and both the residential and business
markets require high quality modem communications."

WirelessNet believes that the need for efficient telecommunications in both the residential and business markets is best served by the provision of low cost, always-on Intemet access.

This can be accomplished by a number of means: ADSL, cable modems or broadband wireless access. Cable modem technologies are being deployed by the cable companies, and ADSL is the subject of regulatory action by Oftel.

However, most of the market in broadband telecommunications is dominated by a very few large companies and most of the UK is not yet served by broadband access.

In the light of these facts, there is not yet adequate supply or effective competition in the UK broadband market. Wireless fixed access provides the only practical alternative for increasing competition in the delivery of broadband Intemet services in the UK.

"The spectrum under consideration in this consultation is as follows:

3.1 3.4 GHz

The spectrum will be available within the paired band 3425-3442 MHz and 3475.6883492.688 MHz. The allocation is 2 x 17 MHz with 50 MHz duplex spacing.

This is MoD spectrum to which the Radiocommunications Agency has negotiated access for FWA. It may therefore be necessary to re-negotiate the use of this spectrum for different service use. This access was on the understanding that protection would be provided for Government sites at Harrogate, Cheltenham, Bilde and Digby. This requirement remains and licensees will be expected to discuss with the Radiocommunications Agency arrangements for protecting these sites from their FWA systems. The band 3400-3600 MHz remains a MoD radiolocation band. There is occasional and transitory use of an airborne pulsed system but no other regular assignments to radiolocation in this band. The lower part of the band is also subject to some out of band radar emissions that could affect FWA systems. The locations of these radars and other data can be made available if required. It should be noted that anomalous propagation can extend the range of these out of band emissions.

Adjacent to the above paired bands there are allocations used for programme making and special events and an allocation used by the Home Office for helicopter-borne video links. Additionally, there is a Fixed-Satellite (space-to-earth) primary allocation in this band. Potential licensees must therefore demonstrate that their equipment will not interfere with, and be resilient to interference from, other users of the band.

Potential licensees should also note that there is an allocation, on a secondary basis, to the Amateur service in the sub-band 3400-3475 MHz "

WirelessNet acknowledges the restrictions on the band to be allocated, and the need to protect the interests of present users of the band.

WirelessNet contends that, whilst the 3.4 GHz band is suitable for broadband access, the current packaging of this band is not ideally suited to current technologies.

Upstream and downstream bandwidth is not necessarily identical in Intemet applications, and may vary from customer to customer and hour to hour. Depending on the technology deployed, an operator may wish to use Frequency-Division, Time-Division or Code Division Multiple Access or Duplexing technologies. These decisions should be left to the operators, subject to a restriction on emitted power density and coding efficiency within a particular area. This can most efficiently be done by allocating a single wide band for the purpose of wireless fixed access.

For these reasons, the possibility of Wireless Fixed Access operators sharing the band 3442 - 3475 MHz with Outside Broadcast and Hele-Tele operations, or relocating them to other bands, should be considered. This would result in a single wider band being available, which could be apportioned by the licensed operators in whatever way led to the most efficient service. This could be done by any of the following methods:

• by demonstrating non-interference with the existing applications
• by relocating these applications to different frequencies, with replacement of relevant equipment if necessary
• by converting existing equipment to be more compatible (for example, by use of spread-spectrum or digital techniques) within the existing allocation, again with replacement of relevant equipment if necessary

A full analysis should be carried out of the costs and benefits of service sharing or relocation, and the expense of doing so, with the objective of preserving the interests of existing users of the nearby bands, possibly with the costs of conversion or re-location being borne by the licensees.

If this is not possible in the short term, consideration should be given to releasing this bandwidth at a later date, without delaying the reallocation of the existing ex-lonica bandwidth.

5. Equipment and Antenna Standards

"Noting that the 3.4 GHz FWA band is generally available throughout Europe, a series of ETSI standards for Point to Multipoint equipment and antenna have been developed for systems operating betvveen 3 GHz and 10 GHz."

WirelessNet response:

WirelessNet notes that some of the ETSI standard interfaces are inherently more spectrum efficient than others, given a constant RF noise environment.

WirelessNet would contend that, as this band is to be allocated by beauty contest, there are good engineering and competition reasons for requiring efficient use of the spectrum by the successful operator.

6. Proposals

(i) voice and narrowband data systems ...

(ii) ISDN type services ...

(iii) Broadband Interactive Services ...

4.2 Nonwithstanding the bandwidth constraints, the Government does not propose to restrict the type of service provided. Data compression techniques continue to yield higher data rate services, and, therefore, the type of service and data rates provided should be for operators to decide based on their business plan and the availability of proven technology. Similarly, the Government does not propose to mandate voice telephony in the services provided.

The Government would welcome comments on the proposal to change the original basis on which this spectrum was licensed previously - the provision of voice services."

WirelessNet response:

We welcome the Govemment's lack of restriction on the uses of the band. We believe that the efficient use of this band is most effectively determined by the operation of the market.

7. Number of operators

"The Government has not reached a final decision as to whether this 3.4 GHz spectrum should be licensed to one operator on a national basis, or licensed on a regional (or sub-regional) basis. If spectrum is licensed on a regional (or sub-regional basis) it could be divided between more than one operator. If it is licensed on a national basis, insufficient spectrum is available to licence more than one operator. However, our starting point is that a single national licence is likely to provide the maximum benefit to competition given that the successful applicant will be competing with several well established operators using different techniques.

The Government would welcome comments on the relative desirability of licensing operators to provide services on a national, regional or sub-regional basis."

WirelessNet response:

We believe that several nationwide allocations of bandwidth suitable for wireless fixed access already exist. No existing operator with a nationwide allocation has yet rolled out a national service. WirelessNet believes that competition should be allowed on all levels, local and national.

WirelessNet believes that subject to suitable coordination, more than one operator should be able to operate within a single locality. This may be made possible by deploying suitable technology, or by reciprocal carriage arrangements.

WirelessNet believes that the successful operator(s) in a given area should not win an exclusive licence on the basis of the technical limitations of their proposed solution.

Rather, the licence(s) should be granted on the basis of operators demonstrating that they will make efficient use of the spectrum allocated. This will have the effect of encouraging competition for efficiency by the operators, in the absence of competitive price pressure from auctions.

In particular, this band should not be allocated to operators who have existing allocations that are not effectively used.

"On 5 July the Government issued a consultation document on providing spectrum for Broadband Fixed Wireless Access titled Wireless in the Information Age ^ Delivering Interactive Multimedia to Workplace and Home,. This document considers tvvo spectrum bands (2 7.5-29.5 GHz and 40.5-43.5 GHz) for the purpose of delivering Broadband Fixed Wireless Access by terrestrial means."

WirelessNet response:

WirelessNet considers that the release of additional bandwidth at lower frequencies for wireless fixed access complements, rather than detracts from, the business case for LMDS services at high frequencies.

Broadband wireless fixed access covers a range of data needs from low to high bandwidth, and low to high duty cycles. The 3.4 GHz band is suitable for supplying the lower end of the market, competing with Digital Subscriber Loop technology, with the higher frequencies able to compete at the top end of the market with fibre-provided services.

"The Government is prepared to consider applications for test and development trials of systems proposed for the 3.4 GHz band. These trials would be on the basis that they would be entirely without prejudice to the outcome of subsequent competitions"

WirelessNet response: Noted.

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