ࡱ> ` [bjbj 7YSO   EEE8ExF t@GPGPGPGPGJJJsssssss$vhdyt 6N JJ6N6Nt PGPG2t<QQQ6N PG PGsQ6NsQQR?n J pPG4G mrEO3ossntxtQob,zP,z<pp,z pJKQL1MJJJtt0QjJJJt6N6N6N6N dD$h,D Dh,   BASIC DETAILS Consultation title: Digital Dividend Review To (Ofcom contact): paula.guest@ofcom.org.uk  DOCPROPERTY ResTo \* MERGEFORMAT  Name of respondent: Anne-Tuulia Leino Representing (self or organisation/s): UMTS Forum Address (if not received by email): - CONFIDENTIALITY What do you want Ofcom to keep confidential? Nothing Name/contact details/job title Whole response Organisation Part of the response If there is no separate annex, which parts? If you want part of your response, your name or your organisation to be confidential, can Ofcom still publish a reference to the contents of your response (including, for any confidential parts, a general summary that does not disclose the specific information or enable you to be identified)? DECLARATION I confirm that the correspondence supplied with this cover sheet is a formal consultation response. It can be published in full on Ofcoms website, unless otherwise specified on this cover sheet, and I authorise Ofcom to make use of the information in this response to meet its legal requirements. If I have sent my response by email, Ofcom can disregard any standard e-mail text about not disclosing email contents and attachments. Ofcom seeks to publish responses on receipt. If your response is non-confidential (in whole or in part), and you would prefer us to publish your response only once the consultation has ended, please tick here. Name: Anne-Tuulia Leino Signed (if hard copy)  The UMTS Forum represents a significant group of spectrum users, which are directly interested in the development of public mobile communication networks including UMTS/IMT-2000 and, especially, the related spectrum topics. UMTS Forum gathers many different players involved in third generation (3G) mobile communication systems, including equipment manufacturers, operators, administrations, service providers and software developers. Introduction UMTS Forum appreciates having the opportunity to express its views and concerns on the early setting out of the effective use of the radio frequency spectrum to mobile usage in the range 470 862 MHz released by the switch-out of the analogue television broadcasting and possible other incumbent use of the band between years 2008 2012. IMT-2000/UMTS subscriber numbers, traffic and coverage are increasing strongly; however, many growth markets still have in coverage limited to main cities. In the medium and longer term, there is a need for very cost effective IMT-2000/UMTS coverage solutions, business models and affordable IMT-2000/UMTS devices. The transition from analogue to digital broadcasting will free some spectrum in the band 470 862 MHz due to the higher spectrum efficiency of the digital TV technology, in combination with satellite and cable based systems for TV distribution. This freed-up spectrum, the so called digital dividend, would present a significant amount of spectrum and very suitable for mobile communications. UMTS Forum invites Ofcom to take into account the harmonization ongoing within CEPT/ECC;within the band 470 862 MHz a European-wide common sub-band should be identified for IMT-2000/UMTS. Question 1: This executive summary sets out Ofcoms proposals for the release of the digital dividend. Do you agree with these proposals? The view of the UMTS Forum is that the analogue to digital broadcasting switchover offers a unique opportunity to harmonize a new frequency band for mobile use in the range 470 862 MHz. One example would be the identification of the lower end of the band as described in the UMTS Forum Report 38. Furthermore, this UHF-band is best suited to support full mobile communication. Also, many other services could be provided over public mobile communication networks using standardized IMT-2000/UMTS and IMT-Advanced systems in harmonized parts of the spectrum in the range 470 862 MHz. UMTS Forums is of the view that rich voice, messaging, e-mail, mobile video, multimedia and mobile television services for public mobile communication mobile phones using standardized IMT-2000/UMTS or IMT-Advanced technologies would represent the most efficient usage in harmonized sub-bands in the range 470 862 MHz. The Forums views and response to the possible other uses in the radio frequency spectrum in this range are as follows: needs for local television program channels could also be satisfied through delivery using other media, e.g. over xDSL, fiber, satellite, cable systems and/or be time shared and integrated in existing television networks, but could alternatively and if agreeable be satisfied over public mobile communication networks using standardized IMT-2000/UMTS or IMT-Advanced technologies; needs for additional national digital terrestrial television program channels, in either standard definition or high definition could, in addition, be satisfied through delivery over xDSL, fiber, satellite and/or cable systems; needs for private mobile communications, such as voice calls and data could also be satisfied over public mobile communication networks using standardized IMT-2000/UMTS or IMT-Advanced technologies; needs for broadband wireless access and fixed broadband access services could equally be satisfied over public mobile communication networks using standardized IMT-2000/UMTS or IMT-Advanced technologies (it is expected that the border between BWA and public mobile communications will disappear in any case in the future); . needs for low-power wireless applications, such as Wi-Fi in the home should not be considered in a sub-band suitable for the high density traffic public mobile communication service, and UMTS Forum is of the view that it would be beneficial if Ofcom could provide the necessary regulatory clarity for the stakeholders to be confident enough investing in access networks in response to the digital dividend of spectrum: Allocations to public mobile communication usages are always subject to subscriber demands creating the highest level of incentive to use the spectrum resources efficiently; The regulatory clarity would allow for the service best suited in this range of which represents some of the best spectrum bands for public mobile communications services; Harmonization of the mobile usage with other countries for similar usage cross Europe would improve the spectrum efficiency, particularly in border and costal areas. In further exploiting the possibilities for the distribution of media content, the UMTS Forum assessment is that the digital dividend in the UK could be extended beyond the 112 MHz, which Ofcom is suggesting and made available to other usage. UMTS Forum believes that the most effective way to raise the value to society in regard to the spectrum usage is to provide the necessary international harmonization to the spectrum users. It is worth mentioning that it is by now probably clear to everybody that the particular value of the GSM as well as the IMT-2000/UMTS Core bands is the fact that they internationally harmonized. Therefore Ofcom should put all its efforts to make this spectrum available in a harmonized way at least within Europe. The Forum is of the view that licences in this range of the spectrum could be liberalised by making the licences tradable, allowing this freedom to the users to adopt their individual business cases over time, but keeping the same basic usage for these valuable mobile bands. UMTS Forum is of the view that a minimum of 2 x 30 MHz spectrum could be awarded in spectrum packages that are suitable for mobile public mobile communication usages. . The UMTS Forum is of the view that the broadcasting television digital dividend in the UK should be made available: for the IMT-2000/UMTS and IMT-Advanced public mobile communication systems; extended beyond the suggested 112 MHz; to provide extended mobile coverage, still at high enough capacity, over very large geographical areas with relatively fewer base stations, providing for affordable service offering when compared to services delivered at higher frequencies; by establishing a minimum of 2 x 30 MHz harmonized sub-band that should be reserved for IMT-2000/UMTS and IMT-Advanced, and in a way that it would allow for pan-European harmonized spectrum for IMT-2000/UMTS and IMT-Advanced to raise the value of this spectrum to the benefit of the society. Question 2: Do you have any comments on our analysis of the essential constraints that will apply to the available UHF spectrum? The Forum has the view that the frequency range 200 MHz to 1 GHz is particularly valuable as these frequencies combine characteristics of coverage and deep indoor penetration (propagation), and wide enough to provide capacity (bandwidth). The exceptional value of this range of spectrum is the radio wave propagation properties in related to mobile usage, which should be kept in mind, when considering the review of the band 470 862 MHz both CEPT and ITU-R; in relation to the Digital Divide in CEPT, and the WRC-07 candidate band as well as the Digital Divide in ITU-R. The expectation for the future is that the public mobile communications will increase in regard to multimedia based services, including mobile TV. The clearly expressed unbalanced situation between terrestrial television broadcasting (46 %) and mobile communications (9 %) in this range of the spectrum needs to be adjusted for in the review. Several members of the UMTS Forum are significantly involved in technical analyses which indicate that the use of public mobile communication devices transmitting both uplink and down signals within the cleared and harmonized spectrum will under harmonized, planned and coordinated conditions allow for coexistence with DTT stations. Question 3: Do you agree with the more detailed analysis and proposals regarding these technical constraints as set out in Annex 10? The Forum wants to reiterate its view that the interference situations, which are detailed and addressed in Annex 10, could to a large extent be handled and cleared while introducing a regulatory practice where international harmonization of the usage should be considered under the scheme of the Digital Dividend. The Forum believes that a minimum of 2x30 MHz Mobile sub-band from the band 470 862 MHz should be implemented in the UK and internationally harmonized European-wide basis. Such an arrangement with uplink and downlink bands should be allocated within a bandwidth of less than 200 MHz due to terminal device antenna issues. Question 4: Do you have any comments on Ofcoms assessment of the potential uses of this spectrum? Are there any potential uses which should be considered that are not mentioned in this document? The UMTS Forum supports the view that there is significant demand for the available UHF spectrum from the public mobile communication sector. The Forum is convinced that there is a high degree of certainty, how the mobile sector will develop over time and how the exceptionally high value of this development would generate to the benefit of the society. In the longer-term, Ofcom could therefore consider the usage of IMT-Advanced broadband systems in further released spectrum. Particularly, this would be useful for household in remote areas of the UK where the access to wired broadband services of mobile broadband services in higher bands may remain limited. According, the Forum regard the band 470 862 MHz to offer the optimum technical and economical way of providing country wide high bit-rate mobile and broadband access for the household in the UK. There are studies within the Forum that are based on the market estimates by the European Commission, CEPT and ITU-R. These studies are in unanimity concluding that the mobile information based and data services are increasing significantly in the future and more immediately over the next few years to come. Some studies suggest that on global basis the information based and data services will overtake the voice services in a couple of years. At least in one IMT-2000/UMTS/WCDMA network the traffic volume of the information based and data services have already overtaken the traffic volume generated by the voice services. Another piece of fact is the demand for interactive access to higher bit-rate services in the fixed wired networks is increasing and the same trend are following in the mobile broadband networks of IMT-2000/UMTS. Question 5: Do you have any comments on our analysis of the choice between a market-led and an interventionist approach to the release of this spectrum? Do you agree with the analysis of different mechanisms for intervening to remedy potential market failures? The UMTS Forum would like to offer the following overarching opinions and comments: All services in the same frequency band should be treated in an equal manner that any national license practice, with regard to timing and other conditions, should be harmonised with other CEPT member states, and a harmonized sub-band in the range 470 862 MHz should be designated in CEPT to IMT-2000/UMTS. The Forum would like to stress that there are many reasons to consider the licensing of a sub-band in the range 470 862 MHz for IMT-2000/UMTS: the fast market growth (more than 100 million subscribers worldwide in the beginning of year 2007); the migration towards the new innovative developments of high speed packet access technologies (HSDPA and HSUPA); development of mobile television services within IMT-2000/UMTS networks. The Forum has great concerns with Ofcom plans to divert from the current regulatory practice of working towards harmonised European band plans and usage. This would lead to confusion in the industry and would eventually have a negative impact on the consumers situation in the UK. The Forum is convinced that such an approach, of diverting form a regulatory practice that is thriving for harmonization, cannot be successful. Therefore, the Forum urges Ofcom to keep the usage in the UK in line with international harmonisation by retaining global or regional CEPT band plan arrangements for IMT-2000/UMTS technologies also in a possible sub-band in the range 470 862 MHz. With regard to technology and service neutrality, as a radio technology is the platform for services, service neutrality does not imply technology neutrality. It is consequently proposed to treat service neutrality and (radio) technology neutrality as two separate issues. For the sake of end-to-end interoperability of services, it is proposed to prefer those services based on standardised protocols. Question 6: Do you agree with our proposals to continue making available channel 69 for use by low power PMSE devices? Do you agree with our proposal to make some or all of the spectrum available for use on a licence-exempt basis? The UMTS Forum has no specific comment on this issue. Question 7: Do you agree that there should be transitional protection for professional PMSE users to ensure that they can continue to access interleaved capacity until at least the end of 2012? Do you have any views on the mechanism for providing future access to this spectrum? Ofcom could consider PMSE in other bands after the possible introduction of the sub-band for IMT. Question 8: Do you consider that additional spectrum from the digital dividend should be reserved for low power applications? If so, please provide as much evidence as possible about the nature of the application and its potential value to society. The UMTS Forum is of the view that a specific frequency band for low power applications should not be considered in this spectrum bands that are exceptionally valuable to the public mobile communication sector providing wide-area coverage. Question 9: Do you consider that it would be desirable to hold back some spectrum from award with a view to its potential use for future innovation? If so, please provide comments on how much spectrum should be held back, and for how long The UMTS Forum has no specific comment on this issue. Question.10: Do you agree with our proposal that we should package the interleaved spectrum in a way that would be suitable for use by local television services, but not reserve spectrum solely for this use? The UMTS Forum has no specific comment on this issue. Question 11: Do you agree with our proposal to package the spectrum in a way which does not preclude mobile broadband use, but to take no further action in relation to this use? The UMTS Forum certainly agrees with this view based and justified through our earlier answers. Question.12: Do you agree with our proposal that we should not intervene in the award of this spectrum to reserve spectrum for DTT? Do you agree that we should package the spectrum in a way which is suitable for DTT use? The UMTS Forum is of the view that it is necessary to harmonize, coordinate and plan the band 470 862 MHz for the allocation of a sub-band of at least 2 x 30 MHz for the introduction of the IMT-2000/UMTS. Question 13: Do you consider that we have included in our analysis the most material risks in relation to market failure? The UMTS Forum is of the view that in regard to public mobile communications the best guaranty of reducing risks and avoiding market failures is to address the appropriate harmonization, coordination and planning on a European-wide basis. The experiences from the outstanding market successes; firstly the harmonized spectrum for GSM system, and secondly the even more successful IMT-2000/UMTS system, growing fast with more than 100 million subscribers worldwide in the beginning of year 2007, are so exceptionally convincing that Ofcom should not disregard this fact in coming award processes. Question 14: Do you agree with our proposal to auction licences for the use of the available UHF spectrum? UMTS Forum would like to share its experience that auctions might not necessarily be the most efficient spectrum assignment practice as it could lead to excessively high spectrum licensing fees leading to distortions of the market situations in comparison to competing usages in other bands or other market segments. Such experience of excessive fees was painfully made in the UMTS auctions in the late 90s in some countries in Europe which in our view slowed down the investment into 3G infrastructures for years consequently and led to considerable market delay in the UK and Europe compared with other parts of the world. The UMTS Forum believes that the transparent beauty contest or an auctioning approach are considered as the most appropriate methods of allocating frequencies and are the most efficient methods for fair use of frequencies. Question 15: Do you agree with Ofcoms proposals as to the timing of any auction? If not, what alternative proposal would you make and why, and what evidence and analysis can you provide in support of your alternative proposal? UMTS Forum urges Ofcom to carry out licensing process in a planned, coordinated and harmonized sub-band in the range 470 862 MHz for IMT-2000/UMTS services. A pan-European harmonised approach is beneficial to the industry and the consumers. Therefore, the Forum finds it particularly important for Ofcom to keep its positions aligned with harmonised European positions. Question 16: Do you have any views on which of the packaging options identified for the cleared spectrum would be most suitable? The UMTS Forum is of the view that it is necessary to harmonize, coordinate and plan the band 470 862 MHz for the allocation of a sub-band of at least 2 x 30 MHz for the introduction of the IMT-2000/UMTS. Question 17: Do you have any views on which of the packaging options identified for the interleaved spectrum would be most suitable? The UMTS Forum has no specific comment on this issue. Question 18: Do you have any views on which of the auction design options would be most suitable? The UMTS Forum has no specific comment on this issue. Question 19: Do you agree with Ofcoms proposals for the non-technical terms of the licences to be awarded for use of the UHF spectrum? The UMTS Forum is of the view that the licences to be awarded for usage of a harmonized, coordinated and planned sub-band of at least 2 x 30 MHz on a Europe-wide basis should be restricted to IMT-2000 technologies to provide public mobile communication including the specified and standardized technical restrictions necessary to control harmful interference. Question 20: Do you agree with the analysis of the options as set out in this Impact Assessment? The impact analysis seems to be quite comprehensive but seems to miss at least two points: 1) It does not consider or discuss the impact of potential UK deviation from harmonised European positions and the resulting disadvantages in terms of infrastructure and terminal costs that would result from the UK loss of economies of scale. 2) There appears to be little consideration of the impact of the costs to consumers in potentially having to change out terminal equipment and/or aerials either at the time of the initial award or as a result of subsequent spectrum trading.  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L0Lv3 k :J^rntt.k!V%zM&(q(Z})uJ+I,?3.4/~[0|3u4K8U[8ac:0=f>g2?(C9CQD9@F&IfJKL'LMrM]O%PWPFQv3Us W32Y [a'[;\D\r^`*`Yb&c3de)egMjijxl6m/Jn\lo p_uCvj wlhwmy`~)SnJ$fH eASN" X`l`Y|zPmxeri__+!j(0a+'bD )wE6ol5x(3{@IX0l^ |_OPw8v:rY~ \FJP3WV}E,_:Z>c;7+mEG 2;3c7yz?@BSSSSSSSS""111111@,TJSP@Unknown Leino AnneUnknownUnknown20070330T085412236 Gz Times New Roman5Symbol3& z Arial;& z Helvetica7 ArialMT9 Webdings5& zaTahoma?5 z Courier New;Wingdings"1󳦷p F*p F*)#4d/S/S 2qHP ?'L2<Why are certain frequencies more attractive than some othersIngela Anne Galloway<         Oh+'0( @L l x @Why are certain frequencies more attractive than some othersIngela Normal.dotAnne Galloway2Microsoft Office Word@G@Rr@Rrp F՜.+,0, hp   Private*/S =Why are certain frequencies more attractive than some others Title  !"#$%&'()*+,-./0123456789:;<=>?@ABCDEFGHIJKLMNOPQRSTUVWXZ[\]^_`bcdefghijklmnopqrstuvwxyz{|}~Root Entry Fp^rData Y1TableahzWordDocument7SummaryInformation(DocumentSummaryInformation8CompObjq  FMicrosoft Office Word Document MSWordDocWord.Document.89qRoot Entry F0r@Data Y1TableahzWordDocument7$, SummaryInformation(DocumentSummaryInformation8CompObjq  FMicrosoft Office Word Document MSWordDocWord.Document.89q՜.+,D՜.+,p, hp   Private*/S =Why are certain frequencies more attractive than some others Title4