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CSS
Spectrum Management Services Ltd
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Licence Policy Unit
Radiocommunications Agency
Wyndham House
189 Marsh Road
London
E14 9SX
23rd December 1999
Dear Sir,
Please find attached the response to your Consultative Document Spectrum Pricing: Implementing the Third Stage and Beyond on behalf of the UK Water Industry.
The response focuses primarily on the issues related to Scanning Telemetry as used by the Water Industry. CSS Spectrum Management has a support contract with virtually all members of the UK Industry to manage and assign spectrum to its members subject to approval and issue by the Radiocommunications Agency.
If you need any additional information please do not hesitate to contact me.
Yours sincerely,
David Tripp C.Eng. MIEE
Chairman of Spectrum Management Group
Managing Director
CSS Spectrum Management Services
Enc.
CSS Spectrum Management Services Ltd
Somerton House
Broad Street
Somerton
Somerset
TA11 7ND
Tel: 01458 273 789
Fax: 01458 273 883
Introduction
The Telecommunication Advisory Committee (TAC) is supported by the United Kingdom Water Industry and deals with a range of matters related to Mobile/Fixed Communications and Radio Scanning Telemetry.
The membership is drawn from representatives from the following Industry Groups:
10 main Water Service Companies
15 Water Supply Companies
3 Water Authorities in Scotland
Environment Agency
DOE Water Service Northern Ireland
The Water Industry (WI) is a major user of Private Business Radio operating predominately over trunked radio systems. In addition, increasing use is being made of Public Cellular, over the Analogue, GSM 900 and GSM 1800 systems.
Considerable use is also made of licensed Radio Scanning Telemetry systems designed to the MPT 1411 standard. The Industry has steadily increased the number and size of systems over the past 10 years. These systems not only collect data but also form part of unattended process control systems. In many instances the Scanning Telemetry is essential to the ongoing operation of the companies.
The Committee has provided input into the Phase 3 Spectrum Review and the resulting Consultative Documents leading to the WT Act 1998 and the various Consultations which have followed.
The Industry is keen to support the RA in its drive to release unused radio spectrum from all users by applying fair market values.
The issues related to Private Business Radio (PBR) have already been satisfactorily addressed.
Management and support for matters related to Water Industry mobile communications and scanning telemetry are provided by CSS Spectrum Management Services. This relationship provides the RF engineering and planning necessary to ensure that the most effective use is made of the radio spectrum. It also acts as a focus for the Industry and deals with financial matters related to RA Licences.
Scanning Telemetry Pricing Issues
The Industry views with interest the proposal in the Smith Group and NERA report which identifies that the licence fees could be based on a charge of £433 per base station per channel used. This approach recognises and benefits those users who time share a single channel on the same location and would discourage the use of multiple channels unless technically necessary.
As pointed out this could disadvantage users with a small number of outstations, however this could be managed within the Industry if the move to Spectrum Management Organisation (SMO) status is developed.
The "charge per base station" approach could avoid the problems associated with considering the spectrum in the same manner as PBR National Channels. A major drawback with the current allocation of spectrum is the problem of continental interference due to band reversal. At this time up to 25% of the UK can be affected by this type of interference at some time during the year. For some of those users affected by interference it has been necessary to install backup systems using PSTN or radio interference cancellation systems.
Although this problem will be removed when band re-alignment takes place it could be some time after 2004 before this is completed. The process will be protracted and complex and will affect a large number of users. The re-alignment could also be constrained by the transfer of the Police Services out of their current allocation on to the PSRCP system. Until then the shortcomings of the current allocation must be taken into account.
The cost of licences for this band have always been considered to be high when compared with their PBR equivalent. This is despite the tight control and management of the systems which has ensured very efficient and effective use of the spectrum. Prior to the second phase of spectrum pricing a PBR mobile licence was £10 while a scanning telemetry licence cost £40 per site. As a result of the second phase of spectrum pricing the imbalance is still considerable and needs to be addressed.
The use of this type of Scanning Telemetry Systems does not necessarily follow the accepted usage profile as much of this equipment is used in remote and rural areas with limited use in the large towns and cities.
It may be necessary to review the definition of congestion in this particular band as result of the way in which it is used by what is a virtually "closed user group" formed from the Water, Fuel and Power Industries. Especially as their user communities are supported by specialist organisations such as CSS Spectrum Management Services for the WI and JRC Ltd for the Fuel and Power Industries.
Conclusion
In view of the effective way in which the available spectrum has been allocated through the Adaptable Cellular Plan and the current negotiations that are taking place in relation to SMO status, the most effective way forward would be for TAC through CSS and JRC to meet with members of the Radiocommunications Agency and discuss the issues raised in this response.
David Tripp
Chairman of Water Industry Spectrum Management Group
Managing Director
CSS Spectrum Management Services
23rd December 1999
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