450-470 MHz Band Alignment
A Summary of the Responses to the
Consultation Document on 450 – 470 MHz Band
Alignment
The Radiocommunications Agency is an executive agency of the Department of
Trade and Industry
This summary records the opinions of the respondents to this consultation document.
The views expressed below are those of the respondents and are not necessarily
endorsed by the Agency.
Executive Summary
The Radiocommunications Agency has published a consultation document on the
450-470 MHz band alignment project. It invited the radio industry, users and any
other interested parties to comment on the proposed band alignment process. A total
of 21 responses were received from a broad range of interests. The Agency would
like to thank all those that took the time to participate in this important consultation.
Overview of responses
There were many differences of opinion on 450-470 MHz Band Alignment Project.
Technical, commercial and financial issues were discussed and some solutions were
proposed. The potential benefits and costs of Band Alignment in UHF2 was a key
issue raised in the responses. Some companies provided a detailed approach to the
consultation document.
There were a number of responses supporting the concept of the Project highlighted
in the Consultation Document, although a number of responses also raised various
concerns.
There was a broad agreement with the RA about band alignment reducing equipment
costs by achieving economies of scale in manufacturing, which would assist the
introduction of new digital equipment. Benefits of facilitating the introduction of digital
services such as TETRA were mentioned as being quite substantial:
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Old equipment that cannot be re-tuned will have to be replaced with new
equipment that will improve RF performance and have a ‘cleaner’ RF
environment;
Positive impact on the value of the assignments and/or licence fee.
Nevertheless, a number of respondents emphasised the fact that some customers
were satisfied with the analogue system and may have no need for an expensive
digital voice system.
In terms of Spectrum Management, benefits would include:
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Rationalising existing assignments,
Maximising co-channel frequency re-use for new assignments,
Improving the quality of the assignment.
450-470 MHz Band Alignment
There was support of the development of a modelling and re-planning tool that could
be beneficial for Band Alignment.
However, the Project would only bring significant benefit to certain users of the
spectrum and the costs of the project’s implementation will be borne by those users,
like the utilities, forced to replace their equipment with no specific benefit to
themselves. This point was emphasised by the majority of the respondents.
A main concern across almost all the responses, was the impact of the re-alignment
on the radio aspects of the UHF2 Band. The Interference issue was detailed in many
responses highlighting situations on case-by-case basis. Timescale of the Project,
which is approximately 5 years from 2005, was another issue attracting close
attention.
Statistical highlights
There are about 30,000 assignments within the UHF2 Band in the UK. The RA 450470MHz Band Realignment Consultation Document was published in December,
2002. There were 6293 reminder letters sent (including users for common base
stations, maritime on-board frequencies, on-site paging, local communications and
suppliers). Less than 7% of the letters came back with changed addresses (subject
to the data quality review). More than 250 public calls were received seeking
clarification. The total number of written responses was 21, with 27 messages by email.
A substantial proportion of those who responded was in favour of Band alignment.
Furthermore, many respondents expressed a wish for the Band Re-alignment to be
carried out over the minimum possible time-scale. However, in some cases that
would not reduce the period of site engineering problems.
More than 60% of those expressing a view considered that costs should not be
incurred by users, other than for scheduled equipment replacement. The majority
suggested RA/UK Government/ Europe should cover all the expenses related to the
changes. Views on the questions related to the benefits as stated in the consultation
document were evenly divided.
Further copies of this summary may be obtained free of charge from:
Information and Library Service
Radiocommunications Agency
Wyndham House
189 Marsh Wall
London E14 9SX
Tel: 020 7211 0502/0505
Email: library@ra.gsi.gov.uk
or may be downloaded from the RA website at www.radio.gov.uk
The full responses, except those for which confidentiality was requested, may be
viewed on the Agency’s web site.
(Telephone: general enquiry point on 020 7210 312, Fax: 020 7211 0163)
450-470 MHz Band Alignment
Summary of Responses to Specific Questions
There were specific issues highlighted across all the responses:
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Potential Benefits;
Costs;
Time-scale;
Interference.
Several respondents agreed the proposed methodology of the band plan, and
migration was accepted, but should only proceed with the re-alignment once the
spectrum has been cleared. The development of the modelling and re-planning tool
mentioned in the Consultation Document was broadly supported.
A majority of those expressing a view broadly agreed that the risks stated for the
band re-alignment are acceptable.
However, It was suggested that Band re-alignment was dependent on the Republic
of Ireland’s reaction. For a successful alignment process, many respondents said
that the Irish Administration should agree to synchronise with the UK.
Another issue was that due to the densely packed environment of multi-user base
sites, major cities and at hill top sites in rural areas; there would be many cases of
blocking and intermodulation when the different services reverse their frequencies at
different times.
Airport related companies raised technical, economic and financial concerns.
Airports are small geographic sites and the implementation of such a change would
inevitably lead to interference issues. For some companies the re-alignment would
affect other PMR users such as airside vehicles at airports.
Several responses favoured the benefits of facilitating the introduction of digital
services such as TETRA. However some did not see any potential benefits. The
assumption that band alignment will attract new users was challenged.
The majority of respondents considered that there would be no substantial benefit to
existing users, but only to the Government, Police and Fire Emergency Services and
the military, who, under present plans would not contribute to the costs of the project.
One manufacturer confirmed that band alignment would allow potential customers to
use their digital equipment and it would be within the capability of their equipment. In
this case benefits as stated in the consultation document were fully supported and
would be of long term benefit to the potential users, manufacturers and the economy.
There were various costs raised as impacting on band re-alignment.
There was concern among the respondents over whether industry and its
customers should fund the project. It was claimed, the only real beneficiary would be
the Government. As a result, some users would take the opportunity to reconsider
their communications solutions rather than paying for band alignment.
Costs would include equipment costs, labour to make the changes and the planning/
engineering costs. Increased costs from having to monitor and identify levels of
interference to their systems during the band re-alignment.
450-470 MHz Band Alignment
Another cost-related issue was regarding the equipment that has been suggested for
use. Some respondents stated that there was no evidence that low cost digital
equipment would be available to replace analogue equipment.
Specific views included:
 Band alignment should be carried out over the minimum possible time-scale in
order to reduce the period of site engineering problems;
 Some said that major installations would need longer than 6 months to make the
necessary changes, as this would be insufficient to plan for changes, for example
at a major aerodrome. Users should be given sufficient time to consider the
renewal of equipment;
 Due to the 5 year implementation period for band alignment, the ability of some
manufacturers to compete in the spectrum would be delayed. This problem is
already being experienced in UHF1, where there is no spectrum available and
users have to compete on national projects such as the Firelink and the
Ambulance Radio Replacement Programme.
On the other hand, it was suggested that a lengthy time scale would lead to a great
deal of uncertainty in the industry.
It was stated that PMSE licensees rarely complain about problems of continental
interference. The possibility that future changes in Europe could affect users in the
UK was not seen as a convincing reason for users to spend money in order to
modify or replace their radio systems. This was discussed in many responses.
450-470 MHz Band Alignment
Detailed Questions
Introduction and Background
There was broad understanding of the principle and stated intentions of the band
alignment among respondents. The need to address the difference in band plans
between the UK and Europe was supported. Many respondents claimed that in any
such change it was essential that the impact of the change on existing users be
properly assessed. It was viewed as essential that where necessary, measures were
taken to ensure that individual users’ cases would be taken into account and users
would not be penalised particularly where they would gain nothing directly from it.
A number of concerns were raised by those who responded to the consultation,
which contributed to some organisations disagreement with the plan to align 450470MHz band with our European counterparts. On the other hand, a number of
respondents agreed to accept the issue of the consultation if they faced a reduced
impact from the project.
Following on from the comments listed in the Consultation Document some PMSE
users wished to be more actively involved in the consultation of users during planning
and implementation.
Key drivers
The vast majority of respondents to the consultation felt that the need to reduce
interference from the Continent to UK users, was not of sufficient validation to
warrant the disruption and cost to current users of the band that would be caused by
the realignment process.
There was also a concern that if the band was realigned to be in line with Europe,
that the UK would need to co-ordinate more closely with Europe. This could
potentially lead to power limits being imposed and a slower or more complicated
licensing process.
However, the majority welcomed the opportunity to consider Band Alignment. As long
as there were clearly defined benefits resulting from financial expenditure of any
type. It was stated that without financial support there would be very little direct
benefits to current users.
Responses included suggestions that:
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Site Owners should have been consulted first of all before wanting to proceed
with the project because the most likely failure of the project is the co-habitation.
This should have been discussed with the Site Owners;
Users of the current band who suffer from interference should be considered as a
special case and options explained to them;
There will be extensive interference because of the lack of planning;
Parallel running on alternative frequencies needs to be implemented, but the
technical issues with the high noise floor would prohibit this unless detailed
planning were undertaken;
No decision to proceed should occur until a clear plan for co-habitation with timescales is published to the satisfaction of all involved.
450-470 MHz Band Alignment
It was recommended to investigate the potential interference to the current
production of both analogue and digital television receivers, from interfering
transmissions across the new base transmit band 460 – 470MHz. Furthermore, it
should define the degree of acceptable interference and what restrictions should be
applied to the new allocations to achieve the level of protection.
It was also recommended that a central co-ordination point would be essential to
manage a project of this scale, given the complexity of the project.
It was suggested that the Industry Working Group (IWG) should be re-established by
the RA or Ofcom under an independent Chairman, to address those issues to which
there was currently no solution identified and prepare a more robust cost-benefit
analysis.
Time-scale of band alignment
Some respondents expressed concern over plans laid out in the Consultation
document to carry out the band realignment in Scotland a year later than in the rest
of the UK. It was felt that this could lead to a risk of increased interference between
Northern Ireland, Northern England, Scotland and border regions during this year.
Many felt that the proposed time scales were neither realistic, nor adequate. Some
respondents felt that the RA need to track any slips in the time-scales for the move to
Airwave by the Police, as this would be crucial to the planning of the band
realignment. This is due to the fact that some respondents feel that band realignment
should not get underway until all existing police systems are permanently closed
down.
Other respondents expressed concern over the long time scale proposed for the
project, commenting that although this gives industry and users time to plan the
changeover, it also gives uncertainty. Uncertainty could lead to users moving to other
technologies therefore depressing the industry. Another suggestion for the speeding
up of the time scales currently proposed was that the project should go ahead, it
would allow UK users to take advantage of the bulk produced innovative digital
technology available from Europe.
Some proposed that there was no single ideal way to reorganise 20 MHz of UHF
spectrum and all of the customers using it. Any proposed final plan, and any way of
staging its implementation, would entail some degree of disruption and costs to
users. However it was believed that the plan and transition process, as published in
the Consultation, are not likely to be substantially improved upon.
IT Development Tool
It was claimed that in order to reorganise the PMSE allocations and more fully meet
the current needs of users, some intended to draw up a policy document and consult
fully with the many types of users that they license. Individual assignments would be
calculated by using home-based planning tools, rather than by the RA's new tool.
Consequently PMSE users would not receive their precise frequencies during 2003.
It was important however to confirm to licensees (and their equipment suppliers) the
frequency bands they would be moved to, and the dates of the move, so that they
could plan resources accordingly.
450-470 MHz Band Alignment
Benefits and Implications of the realignment
A serious concern felt by the majority of respondents was that the benefits of
realigning the band were far smaller than the costs to users and to industry. Those
that are expected to pay for the band realignment (current users) are not those that
will receive any benefits from it. Most respondents emphasised that the cost of
realignment would far outweigh any potential benefits that could accrue as a result of
the change.
The benefits will be received from a minority of coastal users and potential future
users, as well as the emergency services and the Government. It is therefore
considered unequitable that the current users should fund the project. It was
proposed by many that the beneficiaries should be made to pay for the project.
Many respondents expressed concern over operations where for health and safety
reasons systems can not be shut down or suffer from interference, for example
airports. It was commented that due to the nature of the use of aerodrome systems,
the frequency could only be changed at a 'quiet' time, i.e. in the middle of the night
and for some airports this could be virtually impossible. It may be difficult to find quiet
time at some airports at certain times of the year. This needs to be taken into
consideration when planning the changeover.
A number of respondents also expressed the need for consideration to be taken of
the significant cost and operational implications to airports due to the large spread of
companies involved with the despatch of aircraft. In cases such as this consideration
needs to be given to whether it would in fact be possible to operate mobile radio
equipment in both band aligned and non aligned modes at the same time due to the
many different operators such as security, fire and baggage handling. This could lead
to airport interference, which could not be tolerated for safety reasons. Other
companies such as water and electrical companies, may suffer practical problems in
a changeover, for example an operations embargo could occur for safety reasons,
preventing a transition from being completed.
A number of respondents said that they recognised that there were some benefits to
digital equipment, however most users are content with the analogue systems. Many
say that they do not need the added facilities provided by digital, and that converting
to digital is an added unnecessary expense for them.
It was not accepted by some, that radio users would have a wider choice of systems
or would benefit from lower price digital equipment as stated in the consultation
document.
Others commented that the current analogue modulation scheme is in fact very
efficient and that there is no readily available digital technology as an alternative. It
was also argued that the introduction of digital technology was not likely to provide
faster data throughput (although there may be a faster call set up) and unless the
bandwidth increases, this would reduce the number of channels available.
A number of respondents have requested that the RA show evidence to support their
claims that digital equipment is cheaper.
450-470 MHz Band Alignment
RA did not consider movement of SRD’s as being licence-exempt over the timescale. Nevertheless, it was argued that this should be addressed as a discrete issue
and made the subject of a separate consultation.
Some companies submitted a full investigation indicating the proportion of the
equipment that would have to be modified, replaced and re-engineered.
Effects on industry
This point caused the most concern among respondents.
It was claimed that the availability of equipment and technicians and support staff to
implement changes is unknown.
The effects on site-shared users of the re-alignment and scheduling on the
programme that will have to work to are unknown as well.
Most respondents outlined the potential costs that they would incur, should the band
realignment go ahead. These costs would include:
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Modifying or replacing equipment;
Moving base stations and network links ( in order to co-ordinate);
Special engineering that will be needed if blocking and inter-modulation occurs
when the frequencies are reversed;
Project management that will be needed to co-ordinate the changeover;
The labour costs for manning and monitoring dangerous or public sites during the
changeover;
Downtime which could cause problems both financially and for safety reasons;
Costs to general public and business users for being unable to use systems
during downtime;
Interference during re-tuning;
Loss of revenue as customers look for alternatives to their current system;
Increased potential churn of customers as more and more review their solution
and move to competitors;
Companies reimbursing their customers with Service Level Agreements, due to
possible severe inter-modulation type interference caused by a parallel running
during the changeover;
A negative effect on future revenue for some companies;
Base station and antenna re-planning.
Some respondents suggested that these costs be added to the Regulatory Impact
Assessment.
The majority or respondents said that the costs outlined above would cost their
businesses and their customers millions of pounds and some could be put out of
business line for a long time if not forever.
What will band alignment mean for the licensee and everyone else
Some respondents believe there will be many cases of blocking and intermodulation
when the various services reverse their frequencies at different times. This will result
in a changing pattern of interference throughout the changeover period. In some
cases it may be possible to ameliorate the effects at the additional costs with suitable
filtering. This was something that would have to be explained to the users suffering
450-470 MHz Band Alignment
from the interference and facing a possible enforcement to cover the costs of any
special engineering.
The majority of respondents suggested that as the benefits of the project would be
for others, then they should incur the cost. The majority of respondents suggested
that the Government should fund the project, as they would benefit from the
availability of up to 3MHz of nationally available spectrum, which could be licensed or
auctioned to raise revenue and would be of great economic benefit to the UK. It was
also requested that the Treasury be approached to fund the project. Europe was also
suggested as a possible source of funding for the project. Another suggestion was
that the emergency services should contribute towards funding the project, as they
would benefit from it.
It was also suggested that when band alignment is implemented, RA would have to
monitor the users moving to new frequencies. During the process of migration, RA
would need to ensure that users are protected from interference and that they would
move out within the specified time frame.
The Spectrum Efficiency Fund was also suggested as a means of funding for the
project. It was also suggested that the RA should fund the realignment process, by
offering full licence rebates during the year of alignment.
It was considered essential that a new study be carried out by RA to look at the
potential interference to the current production of both analogue and digital television
receivers, from interfering transmissions across the new base transmit band 450 470 MHz. It was suggested that the study should define what degree of interference
was acceptable, and what restrictions should be applied to the new allocations in this
range to achieve this level of protection. It was mentioned that it is important to
inform potential users of the spectrum affected by realignment in very short timescales so that changes can be made to the band plan if unacceptable operating
restrictions were indicated.