JRC Response To The Third Stage Of Spectrum Pricing Consultation Document

Dear David

SPECTRUM PRICING: IMPLEMENTING THE THIRD STAGE & BEYOND

Please find attached our comments on the above document. We are content for them to be published on the Agency’s web site. We also look forward to the next stage of the consultation process, which in our case will be detailed negotiations on the application of spectrum pricing to scanning telemetry.

If you have any queries, please give me a call.

I will Email these comments to you also.

Yours sincerely
Adrian Grilli

General comments

1. Gas and electricity industries welcome the continued work to extend the scope of spectrum pricing to encompass all relevant radio services.

2. JRC member companies welcome the continuing commitment of the Agency to consult with the relevant industry sectors before implementing further measures.

3. JRC member companies welcome the full inclusion of Government Services as this will put pressure on them to release spectrum where it is under-utilised, or negotiate arrangements to share spectrum to a greater extent.

4. JRC welcomes the retention of the option for reviewing the use of fee modifiers where appropriate.Specific comments for scanning telemetry

5. The extension of spectrum pricing to include scanning telemetry needs considerable further analysis. Although superficially akin to mobile services, it differs in a number of key respects from a spectrum pricing perspective:

• Scanning Telemetry is a fixed service. Each link is individually planned and co-ordinated, resulting in greater spectrum efficiency than is possible with a mobile service.
• Mobile services are in greatest demand in urban areas, whereas scanning telemetry is of limited use in cities and most extensively deployed in rural areas.
• Scanning telemetry spectrum is planned and managed by two industry bodies which co-operate closely with each other and RA. Although the spectrum is used intensively, JRC is not aware of any applications to either itself or its counterpart CSS Spectrum Management Services which could not be accommodated because of congestion since all the spectrum was brought under industry control.
• The two spectrum management organisations have developed spectrum planning techniques which double the capacity of the band and undermine the SMITH/NERA conclusions which are based on the band being congested and RA needing to allocate more spectrum to scanning telemetry.

6. There is some merit in adopting the SMITH/NERA approach for scanning telemetry to simplify the licensing process by charging a fixed rate per scanner, although it follows from the above arguments that that the pricing level should be somewhere below the £433 per scanner quoted in the report.

Adrian Grilli
Joint Radio Company Ltd
21 December 1999

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