Motorola Internal Use Only DRAFT 1 of 8

Table 1 Scenario Comparison

SUBJECT: MOTOROLA RESPONSE TO UK CONSULTATION ON
LICENCE EXEMPT SPECTRUM
Motorola is pleased to have the opportunity to respond to the consultation on the use of
licence-exempt spectrum for provision of public telecommunication services.
In addressing our comments we have some general points to raise as well as answering
the specific questions.
General Points
We note that three possible scenarios are listed. These are portrayed in table 1 below.
Scenario 1
This scenario seems to foresee that
new public services can be given a
licence providing there is minimal
impact on an existing one.
This seems extremely problematical in
practice. Two situations could be
forecast.
1. Disruption to existing
users
In the event that the use of this
spectrum provides benefit to a
large number of people (which is very much to be
hoped see below), the introduction of a licensed public service could easily be
disrupted by the existing services which may be ad-hoc. In this case how would
the regulations be applied and what could be done about it? What would be the
advantage of having a licence?
2. How many operators?
If the spectrum was in fact lightly used but slowly and continuously increasing. A
public service can be licenced, how would the decision be made as to when to
stop issuing licences for fear of future congestion?
Motorola is unsure how this scenario would either help the development of the use of
radio or actually provide a basis for the management of the spectrum as would be
Motorola Internal Use Only DRAFT 2 of 8
required if licences were issued. Conversely, the uncertainty whether another public
operator being allowed into the band would cause an adverse impact on the incumbents
might lead to situations in which some operators were disadvantaged over others with
little hard evidence to support the decision.
In addition to this there is the difficulty of the right of the public user (having a WT-Act
licence) to some degree of protection even though they are operating on spectrum that is
licence-exempt for other users.
Scenario 2
The public services being exempt from the need to gain a licence removes any question
of rights to protection and thus the service must operate on a non-protected basis. Basing
the spectrum regulation on an interface requirement removes the direct dependence on a
named technology which allows future upgrades. Furthermore, the applications to which
the equipment is put is similarly freed up.
However, the lack of the licence may not remove the need for base station registration.
The results of the Stewart report may apply to this new public telecom service for
example.
The effect of the difference in limits on the allowed applications between the public and
private is difficult to judge until the extent of these differences becomes known. Taking
the example in the consultation whereby public services would be limited to indoor
applications, would this exclude public places like cafes where some tables are inside and
some outside? Situations like this could be difficult to define and police later on.
Were a limitation like the public service could only be accessed from indoors, we would
expect that to have quite a significant effect on the usefulness of the public service to the
users. It can be assumed that many users will want equipment that connects to the source
of the content they want through their own private system at home or in the office
otherwise, when traveling, they will want the ability to use it anywhere. If this is not
possible, the public service may be difficult to justify to the customer. Certainly, there
may be some implications on equipment design that could introduce significant supply
chain complexity in the efforts to ensure the users get the appropriate equipment.
So public users would get equipment that has its use limited to specific bands and power
levels whereas private equipment can be used anywhere. We would be grateful for
details on how this would be policed in an environment where it might be expected that
users will move between public and private use.
Taking the 5GHz band, would such a limitation effectively mean that the public service is
limited to the 5 channels in Band A?
Scenario 3
This is the simplest scenario to envisage. It is also the regulatory scenario that provides
the greatest user access to the equipment through normal distribution channels as there
are no limitations on applications etc.
Motorola Internal Use Only DRAFT 3 of 8
In this case the service provided is limited only by the commercial model and at some
stage in the future possibly by congestion if the service is a great success. As noted in the
consultation, it could well be that this point is never really reached as the user density
will tend to self-limit.
Motorola supports the adoption of scenario 3
Response to Section 6.2
In response to the request in the consultation in section 6.2 Motorola provides the
information in table 2. The following explanations of the conclusions are offered.
Overall Economic Benefit
It is generally accepted that the greatest economic benefit to the Nation occurs with the
largest number of users. The recent RA Study (Feb 2001) confirms this.
The experience with GSM of the uptake of the use of radio technologies as tools and
convenience aids shows that user access is critical. Other technologies (even those that
are free to air) have not shown similar uptake when licensing delays and difficulties are
introduced.
Therefore the greatest benefit to the Nation is achieved when the most open regulatory
regime is provided. This is scenario 3.
Interference to Existing Users
Motorola assumes that irrespective of the scenario chosen, there will be spectrum
regulation applied. At present, the technology allowed in the band is specified in the
Statutory Instrument. The other scenarios provide that the traditional interference issues
will be resolved through Interface Regulations.
In respect to the interference with other users of the same band it is important to be
assured that the service likely to provide the greatest economic benefit is not impeded
through excessive regard to existing users who may not be able to provide service to the
same number due to choice of technology or business model. For example, concerns
over interference to satellite services in sub-band A of the 5GHz band from the RLAN
technologies are justified. However, as the satellite services cannot service as large a
number of users and also may not provide the range of services the users can benefit
from, it is not in the interests of the Nation to restrict the RLAN based services in favour
of these technologies in licence exempt spectrum.
Technologies exist that limit the interference through access control algorithms. This
provides an instantaneous and dynamic means of ensuring the interference issues are kept
under control. For example, Dynamic Frequency Selection (DFS) prevents units from
attempting access to channels that are already in use. This provides much better actual
interference limitation than any regulation-based scheme could ever hope to achieve. At
present, not all proposed bands have requirements for interference mitigation
technologies. The 2.4GHz band has no such requirement. Furthermore, there are a
Motorola Internal Use Only DRAFT 4 of 8
number of different technologies already in the band that might occasionally interfere. It
is not clear to what extent this will actually cause a problem and thus it is not proposed
that this be considered sufficient reason to exclude the 2.4GHz band from the
arrangements of Scenario 3.
Congestion in Licence Exempt Spectrum
It is to be hoped that the spectrum will be very heavily used. This is because the greatest
economic benefit is achieved through use. Heavy use is therefore to be expected and not
at all to be prevented through regulation. The design of the access control scheme
employed is therefore crucial to ensure that heavy use does not translate to destructive
congestion. The internet has shown one way of providing for very heavy use for
applications that are not time-critical.
Non-broadcast services that are time-critical are much more difficult to keep congestion
free. Real-time video may require the entire resources of channels even for ostensibly
high data rate transmission systems. Efforts are in progress to look into this further.
Licence exempt spectrum is not considered appropriate for safety critical services of any
kind. Equally, priority users on licence exempt spectrum appear to give rise to
difficulties to the remainder of the user population while at the same time not necessarily
providing the assurance these users may require.
It would appear that scenario 1 will severely limit the number of users of licence-exempt
spectrum. At present, the technologies specified do not all have to implement any form
of DFS. Thus even with the much lower uptake there is no guarantee of congestion
avoidance.
Our conclusion is that which scenario is chosen is irrelevant to congestion. What is more
important is that the correct mitigation techniques are deployed. This includes existing
users also.
Types of Third-Party Services
Motorola is of the opinion that no limits should be set.
Quality of Service
In consideration of the fact that services will be established for users with no guarantee of
the conditions some time later and that there is also no reason to prevent existing users
from upgrading their equipment to provide better service, it seems unreasonable to
predict the quality of service that will be provided.
We therefore propose that no regulated limit be placed on quality of service. Instead,
users should be free to move to better services in the normal manner under market forces.
Implications of Competition with Operators on Licenced Spectrum
As a manufacturer we make no comment.
Motorola Internal Use Only DRAFT 5 of 8
Timescales for the Introduction of Policy
The UK Broadband Britain policy will be greatly helped by the introduction of high
capability, cost-effective solutions such as are possible with these radio applications. At
the same time it is clear that the UK is effectively in a race against other Nations to have
the benefits of broadband. We therefore assume that the intention is to introduce
Scenario 3 as soon as can be achieved. We strongly support this.
Table 2 Summary of the above comments.
Scenario 1 Scenario 2 Scenario 3
Economic benefit Limited Good Best
Interference No clear advantages
and many problems
No clear advantages
to the economic
benefit
Risk limited by
users.
Congestion No change
Third-Party No clear advantages Limited by location. Any service
permitted
QoS Not applicable No Limits No Limits
Competition No comment No comment No comment
Timescales :-
446MHz In place Remove technology
limit
Remove technology
limit
2010-2025MHz TBD TBD TBD
2.4GHz This scenario is not
suitable
Location limits
could be very
difficult
Preferred solution
5GHz This scenario is not
suitable
Location limits
could be very
difficult
Preferred solution
Responses to Specific Questions
Q1: What are the potential gains and benefits to the UK of allowing
commercial services in licence-exempt bands, in terms of new innovative
services (business models), promoting competition, and making Britain the
best place to do e-business?
It is difficult to answer this question. The advantages of broadband
Britain are thought to be well known and accepted. Allowing
commercial services are thought to enhance these objectives.
Q2: Will the introduction of public telecommunication services into existing
licence-exempt frequency bands, within the conditions of use identified in
Appendix B, result in unacceptable levels of interference to existing users,
and if so, in what geographic locations might this be expected?
Motorola Internal Use Only DRAFT 6 of 8
It is to be hoped that the benefit derived from the use of the spectrum
will rise substantially with the increase of the number of users that the
spectrum will support. The number of users will dictate any possible
interference issues. Whether the users are public or private does not
seem to affect this argument.
Q3: Would the introduction of public telecommunication services, into existing
licence -exempt allocations, and within the current conditions of use
identified in Appendix B, result in congestion of the frequency bands?
If the spectrum becomes heavily used (as we hope it will be), it does
not matter whether the users are on public or private schemes.
If however, the belief were to be that not introducing public
telecommunication services into the band would cause the spectrum to
remain lightly used this would be a misuse of the spectrum, not in
accordance with maximising the greatest economic benefit to the
Nation and not helping the Broadband Britain initiative.
Q4: In bands where channel access techniques have been identified for specific
services, will these techniques be sufficient to avoid future congestion? If
not, please give information about other techniques that might be
applicable.
These techniques greatly improve the likelihood of avoiding
congestion. It is not possible to give a guarantee that congestion will
be avoided forever into the future.
Q5: What type of public telecommunication services could be offered in
licence-exempt spectrum and what is the anticipated market potential?
Any services. There should be no limit.
Q6 : Assuming that there would be a lower quality of service available from
public telecommunication services using licence-exempt spectrum,
compared to those using licensed spectrum, how could potential end users
be informed of this?
Several mechanisms exist to advise users of various limitations on
products. No difference is seen in this case.
Q7: Which, if any, frequency bands identified in Appendix B are not suitable
for the introduction of public telecommunication services and why?
It is important to examine the bands on a case-by-case basis in
conjunction with the plans of the operator before concluding on this
point. As a manufacturer we cannot comment on the plans of
individual operators.
Motorola Internal Use Only DRAFT 7 of 8
We would make the general comment that bands having a small
amount of spectrum could be difficult for public service operators to
successfully deploy advantageous services in. For example, PMR446,
having neither a lot of spectrum nor allowing infrastructure would
appear to present difficulties. Whereas, were a railway operator (say)
to request that a public telecommunications operator provide the
applications in the band listed as 2-30MHz (SRD) it is not clear why
this should not proceed.
Q8: Are there any potential problems associated with allowing commercial
services in licence-exempt spectrum?
It is Motorolas belief that the recent advances in technology will
provide services of good quality in even heavily used bands to large
numbers of people. This is expected to provide a much-needed
impetus to the Broadband Britain initiative and is clearly in line with
the maximising of the economic benefit to the Nation. However, it
also means that the huge fees in the recent 3G auction are much less
easy to justify from a business standpoint.
Q9: Assuming that public telecommunication services are permitted in licence-
exempt spectrum, what would be considered suitable time scales for
making these changes in each of the bands identified in Appendix B?
We assume it will take around one year to achieve the changes
necessary were it to be started immediately. This appears to be a
suitable timescale.
Motorola Ltd.
January 2002.
Questions on this should be directed to Tim Cull in the first instance
Motorola Internal Use Only DRAFT 8 of 8