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BG
Transco plc
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Licensing Policy Unit
Radiocommunications Agency
Wyndham House
189 Marsh Wall
London E14 9SX
23rd December 1999
"Spectrum Pricing: Implementing the third stage"
Dear Sir
Transco have considered the above mentioned document and wish to comment on it's content.
Transco welcomes the fair extension of spectrum pricing by the RA to cover all relevant radio services and also welcomes their continued commitment to consult with industry sectors before implementation.
Transco welcomes the inclusion of all spectrum users, including Government Services, to ensure that spectrum is fully utilised and notes that this may lead to greater sharing of spectrum or even to the release of spectrum by some users.
Transco suggest that further analysis of the decision to extend spectrum pricing to telemetry scanning is needed, if this is based on the premise that spectrum pricing is a means to reduce congestion of bandwidth.
Transco believe that scanning telemetry is more accurately defined as fixed point to multipoint services, i.e. fixed link rather than mobile radio because each link is individually planned and co-ordinated.
Innovative investigations, using technology and management to increase capacity by 100% using the same spectrum are underway. This will lead to even more efficient use of spectrum but will also require Industry investment to achieve. Transco comment that this is likely to mean that the band is not congested and is open to further expansion, without the need for more spectrum.
The requirements for radio communications differs widely between the utility industries and the base station infrastructure is normally based on the information rate required from the outstation. Some outstations respond every minute and have few outstations per base site, whereas others with a much lower response requirement could have considerably more outstations per site, yet both methods make best use of spectrum. Transco comments that the approach by SMITH/NERA may not be the most appropriate way of allocating pricing for all.
Transco thanks the Radiocommunications Agency for the opportunity to respond to the consultation document.
Yours faithfully
Brian Thompson
Senior Telecomms Engineer
BG Transco plc
Brick Kiln Street
Hinckley
Leicestershire
LE10 0NA
www.transco.uk.com
Tel: 01455 251111
24 hour gas escape
number 0800 111 999*
*Calls will be recorded
and maybe monitored
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