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Cable & Wireless Communications
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Cable & Wireless Communications
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Cable and Wireless Communications welcomes the opportunity to comment on "Spectrum Pricing: Implementing the Third Stage and Beyond". Our radio spectrum interests lie mainly with the fixed and fixed-satellite services, and we will confine our specific comments to those proposals in the consultative document relating to these services. We will nevertheless continue to monitor developments to ensure that an equitable approach on pricing is being taken to users of the spectrum across all radio sectors.
We continue to give our cautious support to spectrum pricing as it is being implemented in the UK. The radio spectrum is a finite and valuable resource, and we support the principle of levying WT licence fees that are commensurate with the value of the spectrum being used in support of a particular application. If the spectrum can be valued accurately, and fees levied for the right reason, pricing will be a useful mechanism for spectrum management.
Cable & Wireless Communications will of course be happy to participate in future work in this area, as and when required.
As a major user of point-to-point fixed links and already subject to spectrum pricing we welcome the proposed no immediate change in this sector. However, we realise it is too early yet to gauge the impact of the current pricing arrangements on the management of point-to-point spectrum, and that a review may be necessary at some stage. We will be happy to contribute to any review process.
We agree in principle to the application of spectrum pricing to Fixed Wireless Access (FWA). We share the view that a fee escalator arrangement would act as an incentive to rollout. We would however feel it quite inappropriate to apply both the pricing mechanism and geographical rollout obligations on FWA licensees. The imposition of such obligations runs counter to the development of a spectrum value based management and licensing regime. If the level of FWA licence fees is to be linked to the value of the spectrum assigned, the manner in which that spectrum is used for FWA purposes should be left as a matter for the individual licensee.
We note the FWA fees proposals in Appendix 1 of the consultative document. The approach of abating the reference-derived fee to take account of sharing issues and other technical difficulties in specific bands is welcomed. The RA will be aware that the quality of RFA spectrum available in the 10GHz band is further diminished by the widespread presence of illegally operated burglar alarm and other such low power Doppler-sensing devices. A further abatement for this should be made in the proposed 10GHz RFA licence fees.
The consultation proposes the introduction of spectrum pricing to fixed satellite services on a phased basis commencing with Permanent Earth Stations (PES) in July 2001.
Considering the Fixed Satellite Service in isolation, we see no evidence to suggest that the spectrum allocated to it is congested. This point is recognized in the Smith/NERA Study final report. Any shortfall in this area seems largely attributable to lack of space segment resources rather than spectrum, and the remedy would appear to lie in the hands of the space segment investor rather than those of the spectrum manager.
Spectrum pricing may have a part to play in moderating the demands of satellite earth stations where these use frequency bands that are shared with the fixed and other terrestrial services. However this would seem to represent a departure from the approach to date, which has been one of using price simply as a tool to address congestion at the assignment level. Its use as a moderator between, say, the fixed and fixed-satellite service would clearly move it into the allocation arena. In spectrum management terms we do not regard the issue of conflicting fixed and fixed-satellite spectrum needs as a particularly pressing one, and we would see little justification for the introduction of PES spectrum pricing to resolve any such conflicts at this stage.
We would also note here two technical errors appearing in Section 6.6.2 of the Smith/NERA final report. The first concerns the text relating to the antenna model in Figure 6-2; the value of the parameter j min in the ITU-R S.465-5 radiation pattern generating equations should be set to 1° and not 0.5° as indicated. The second concerns the assertion that a typical fixed link operating over a distance of about 40km will radiate a power of about 34 dBmi; it would be more usual for such a fixed link to radiate a power 30 dB higher than this, i.e. about 34 dBWi.
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