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National
Air Traffic Services Ltd
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Introduction
National Air Traffic Services Ltd (NATS), as a leading provider of Air Traffic Control Services within the UK, has provided comments on previous consultations and welcomes the opportunity to comment on the latest consultation document "Spectrum Pricing: Implementing the Third Stage and Beyond".
Our response has been limited to the Aeronautical reference in the document and in particular those that affect NATS.
Response To Specific Items
Appendix 4 - Aeronautical and Maritime Sectors
International use of aviation frequency bands
NATS is pleased that the international aspect of civil aviation frequencies has been acknowledged and that the UK could not unilaterally change the use of the frequency bands used by aviation.
Incentive Spectrum Pricing
If incentive spectrum pricing is not to be considered suitable for more efficient use of aeronautical spectrum then other means need to be used to increase the efficiency of spectrum usage. NATS has first hand experience of frequency congestion particularly in the band 117.975 - 137 MHz where requests for frequencies have been outstanding for a number of years. The introduction of new technologies does not necessarily overcome this problem and there is still a reluctance by some aviation users to use more spectrally efficient (i.e. narrower bandwidth) equipment. NATS is still of the opinion that incentive spectrum pricing may still have a role to play in aeronautical spectrum efficiency.
Aeronautical licences
NATS believes that there are ways that licensing can be streamlined. We would however have difficulty in providing some information to the CAA for licensing purposes particularly that related to site information. NATS therefore could not agree with the CAA dealing with the issuing of the NATS Aeronautical licence.
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