450-470 MHz band alignment 450-470 MHz Band Alignment A consultation document December 2002 The Radiocommunications Agency is an Executive Agency of the Department of Trade and Industry. 450-470 MHz band alignment Contents Executive Summary ........................................................................................................... 3 1. Introduction and Background ..................................................................................... 4 2. Proposed Approach..................................................................................................... 8 3. Benefits......................................................................................................................... 9 4. Implications ................................................................................................................ 11 5. Responses.................................................................................................................. 13 Annex A: Draft Regulatory Impact Assessment ........................................................... 15 Annex B: Constraints of the Band Plan ......................................................................... 21 Annex C: Band Plan Rationale ....................................................................................... 22 Annex D: Consultation Criteria ....................................................................................... 24 Page 2 of 24 450-470 MHz band alignment Executive Summary This consultation document describes a spectrum re-planning project by which the Radiocommunications Agency (RA) will manage the alignment of the 450-470 MHz band to the configuration quoted in the European Common Allocations (ECA) Table. The UK is at a disadvantage because its existing spectrum configuration cannot easily accommodate new and readily available low-cost technology. This is a significant constraint on users and members of the radio industry who wish to provide flexible private radiocommunications solutions within the UK. The Agency has chosen this band since the Emergency Services users, which have a 6 MHz allocation in the band, will be migrated to the Home Office-sponsored Airwave Project. Additionally, the radio propagation characteristics of the band make it highly sought after for mobile radio systems since it provides coverage ranges of up to about 30 km and some in-building penetration. It is also a band that has been identified across Europe for digital services according to a common spectrum configuration plan. Therefore, in order to maximise the benefit of this spectrum to the UK radio industry, RA is proposing to complete alignment within five years. It plans to start in earnest at the end of 2005 and to complete the process by 2010. However, on a case-by-case basis, alignment will be possible prior to this date. RA notes that there will be technical and economic implications of carrying out band alignment. On the technical side, there is an associated band plan showing how alignment will be achieved in a stepwise process. This has gained majority acceptance within the project’s Industry Working Group. On the economic side, RA has produced a draft Regulatory Impact Assessment, which assesses the costs and benefits of the proposed approach. Where possible, estimates have been made using data from the band alignment survey carried out last year. However, this is a working document and is available for consultation. Overall, RA will seek to maximise the benefits and minimise the costs of band alignment over the five-year period. RA, in keeping with its published strategy to align this spectrum, seeks views from the radio industry, users and any other interested parties on the proposed alignment process outlined within this document. Page 3 of 24 450-470 MHz band alignment 1. Introduction and Background 1.1 Introduction This consultation document describes the way in which the Radiocommunications Agency (RA) will implement 450-470 MHz band alignment. RA’s plan includes the entire UK, including Northern Ireland, the Isle of Man and the Channel Islands. The radio spectrum is a finite resource, and it is a prime purpose of the Agency to manage its use optimally. Aligning spectrum between 450 and 470 MHz will expand its social and economic benefits and increase the efficiency of its use, allowing users to gain renewed benefit from assignments in this band. In some areas the demand for spectrum is growing and outstripping supply. Therefore there is a need to make spectrum available for new and innovative services as well as to enhance existing services. The 450470 MHz band alignment project, when completed, will yield European-harmonised spectrum that can be used for new and existing radio services. This band re-planning will involve moving existing users and reassigning them in the band to achieve commonality with the 450-470 MHz band structure in Europe. The aligned state is shown in Figure 1, with mobile transmit below 460 MHz and base transmit above 460 MHz. The alignment process will transpose base-station and mobile blocks of spectrum and alter their spacing to 10 MHz. 460 MHz 450 MHz Mobile transmit 470 MHz Base transmit 10 MHz separation Figure 1. Template for alignment of 450-470 MHz 1.2 What are we consulting on? Views from customers, dealers, manufacturers, radio site owners and other interested parties are sought on the implications of the 450-470 MHz band alignment process described here. The alignment is based on the spectrum configuration defined in CEPT 1 Recommendation T/R 25-08 Annex 1, which is referenced in the European Common Allocations (ECA) Table (ERC2 Report 253). This process is presented from both technical and economic viewpoints. 1.3 Background RA intends to align the current 450-470 MHz band configuration with that of our European neighbours. The requirement for the UK to commit itself to this project arises from historical differences between the UK and Europe in their planning of this band. One of these differences has caused radio services in the UK to experience interference from Continental radio systems, particularly analogue cellular systems. A 1991 report commissioned by RA recommended reversal of the base and mobile transmit frequencies in the band, to conform to neighbouring European countries. This would allow RA to co-ordinate frequency use and hence control interference. Further independent support was provided through the 1994 Stage 3 Radio Spectrum Review, endorsed by the Government. Within the CEPT administrations, the second-phase Detailed Spectrum Investigation (DSI Phase 2) concerning use of this spectrum resulted in a European Radiocommunications Committee Report (ERC Report 25, or the ECA Table), which detailed the recommended configuration and major utilisation of each band. The first major technical step of the alignment process requires an UK band plan that complies with the spectrum configuration template quoted in the ECA Table (CEPT Recommendation T/R 25-08 Annex 1). CEPT – the European Conference of Postal and Telecommunications Administrations. ERC – the European Radiocommunications Committee. 3 ERC Report 25 – ‘The European Table of Frequency Allocations and Utilisations Covering the Frequency Range 9 kHz to 275 GHz’, commonly known as the ECA Table. 1 2 Page 4 of 24 450-470 MHz band alignment Another of the DSI Phase 2 recommendations was that the analogue cellular systems should be closed down. This has happened, but the spectrum is likely to be repopulated in time with other systems. The UK has no direct control over the kind of system that might be accommodated elsewhere in Europe in this band, and in the current band configuration it therefore remains vulnerable to renewed interference. In the UK, the 450-470 MHz band consists of blocks of spectrum allocated to a variety of uses: Private Mobile Radio (PMR); Public Mobile Data operators, supported on dedicated channels within the general PMR allocations; Scanning Telemetry (ST), used by the water, gas and electricity industries for data acquisition and control at remote sites; Emergency Services (ES), also known as Public Safety; Private Wide-Area Paging (WAP); Programme Making and Special Events (PMSE); and Maritime On-Board, for use in coastal areas and navigable waterways. The arrangement of these frequencies is normally in pairs – base and mobile transmit. However, the spacing between these pairs is not constant throughout the band. Also, the base-transmit and mobile-transmit frequencies are reversed relative to their European counterparts. In the new plan there will be base-transmit frequencies above 460 MHz and mobile-transmit frequencies below, with a common 10 MHz spacing between the pair (Figure 1). 1.4 Key drivers There are several key drivers for the 450-470 MHz band alignment project. These are: 1.4.1 Major benefits to the UK. Providing spectrum to facilitate advances in technology will ensure the continued success of the PMR market. The consequent advantages of large-scale manufacture will benefit users and industry. This should reduce the cost of new digital technology, and result in lower prices and a wider choice of systems. These systems will have increased functionality and allow direct connection to IT equipment and new opportunities in e-business. 1.4.2 Better use of spectrum. Re-planning the band will allow existing systems to develop and grow, and will make it easier to introduce new equipment in the European configuration. For instance, the existing band structure constrains the introduction of new digital technology – including TETRA4, TETRAPOL5 and DIIS6 – for private systems. In fact the band is one of four identified in the ERC/DEC/(96)04 decision for the use of TETRA, which requires spectrum in the correct configuration. 1.4.3 Yield of harmonised spectrum. Existing assignments (i.e. channel allocations) will be more efficiently reassigned through the use of a new planning tool, which will repack existing users to occupy less spectrum overall and yet retain existing quality. This will yield harmonised spectrum estimated to be between 2 and 3 MHz. 1.4.4 Spectrum for Public Safety services. As a result of the Major Review of Police and Fire Communications (1991-1993), the PSRCP7 emerged. In initiating the PSRCP, the UK Government highlighted the need to start the 450-470 MHz band alignment process. In planning for Emergency Services systems, it is becoming increasingly important that additional CEPT-compliant spectrum for Public Safety users is made available in the near future. Spectrum within the aligned 450-470 MHz band could accommodate this requirement. 1.4.5 Consolidation of military spectrum. There is an interdependency between the release of military spectrum for civil use and the increasing interest by the military in the use of commercial off-the-shelf (COTS) technology. This requires aligned spectrum. Hence, early release of this military spectrum will be facilitated by band alignment. 1.4.6 Interference from neighbouring European countries. Interference is suffered by many licensees in southern and eastern England – particularly in the summer, when UHF propagation is enhanced due to high atmospheric pressure. Under these conditions. systems (some of which are safetycritical) can be severely degraded or even rendered unusable. Alignment to the ECA Table will mean that the UK can co-ordinate its use of radio channels with Europe (e.g. via the principles and TETRA – TErrestrial Trunked RAdio; the ETSI digital trunked radio standard. TETRAPOL – a proprietary digital trunked radio standard. 6 DIIS – Digital Information Interchange System; an ETSI non-trunked radio standard (not yet finished). 7 PSRCP – Public Safety RadioCommunications Project. 4 5 Page 5 of 24 450-470 MHz band alignment procedures contained in the Berlin Agreement 20018) and mitigate the effects of any future interference caused by the introduction of new systems on the Continent. 1.4.7 Lack of commonly configured pan-European spectrum in the bands used by PMR. In evidence submitted to DSI Phase 2 by the European PMR industry body EICTA 9 (part of what was then called ECTEL), this was shown as a major obstacle in the development of this sector of the communications market. A 1998 report by the European Radiocommunications Office concluded similarly. 1.4.8 RA’s published Spectrum Strategy. There is an industry-wide expectation that this band will be aligned, and some progressive organisations will have already begun their long-term planning. In fact, RA has for a number of years indicated its specific intention to implement the band alignment process. The first band to undergo this process is 450-470 MHz, because of the window of opportunity that will open when the police vacate their current spectrum and migrate out of the band. This spectrum yield can be used as a catalyst for alignment. The alignment intention was reflected in the Government Response to the Stage 3 Radio Spectrum Review (1994), and has for the past two years been notified to all affected licensees in the band. 1.5 Why is band alignment happening now? A major opportunity is presented by the migration of Public Safety users to the Home Office-sponsored Airwave Project. Airwave is a new network specifically for Public Safety users, which employs digital technology in the 380-400 MHz band. Band alignment will be facilitated when 2 x 3 MHz of spectrum in 450470 MHz is relinquished in England and Wales, with a phased two-stage hand-back based on Airwave Ready For Service dates plus an additional transition period of 18 months. The second stage is due to complete in 2006. In Scotland, police forces are also joining the Airwave Project, but the timescales for relinquishing the spectrum in the 450-470 MHz band are currently a year behind England and Wales. In Northern Ireland, a separate digital system in the 380-400 MHz band will meet the needs of all Emergency Services. This is scheduled to be operational before the migration of mainland police forces. A similar situation exists on the Isle of Man and the Channel Islands. Completion of migration by these services provides a unique window of opportunity to initiate band alignment. It provides an opportunity to align existing services in the band and to boost the introduction of new digital technology, allowing at the same time a fresh examination of the communication needs of the band’s users. This will improve the efficiency of the spectrum’s use, and may be a preliminary to the introduction of spectrum trading, subject to consultation. The 450-470 MHz spectrum in the Republic of Ireland (over which RA has no jurisdiction) is configured similarly to the UK, with the same duplex spacing and orientation of base transmit/receive, so any change made to the UK band will have consequences for the Republic. RA is therefore in close dialogue with its Irish counterpart. As can be seen from Figure 2, all our near European neighbours already comply with the recommendation or are working towards it. 8 The Agreement ratified on 30 June 2000, known as the Vienna Agreement, was revised and ratified on 14 Sept 2001. It is now known unofficially as the Berlin Agreement and covers frequency co-ordination in the fixed and land mobile service in 29.7 MHz-39.5 GHz 9 EICTA – European Information, Communications and Consumer Electronics Industry Technology Association. Page 6 of 24 450-470 MHz band alignment Implemented (23) Figure 2. Implementation of ERC Recommendation T/R 25-08 1.6 Risks of not re-planning the band The risks of not aligning the 450-470 MHz band are: in the future, there may be an increase in demand for spectrum (to expand existing radio services or to provide new services) which could exceed supply, delaying or hindering the development of such services; some radio users in the band may continue to experience Continental interference; current spectrum may be used inefficiently; existing users or new users wanting to provide radio services to customers in both the UK and Europe will not be able to operate on the same frequencies as in Europe, as the band will not be harmonised; Release of military spectrum for civil use will be hindered, as the current spectrum configuration will not support non-operational military requirements. 1.7 Statutory consultation In accordance with the provisions of the 1949 Wireless Telegraphy Act, RA will publish notices in the London, Edinburgh and Belfast Gazettes detailing the substance of the proposed alignment project. Shorter notices will be posted in the equivalent publications in the Channel Islands and the Isle of Man. It is also intended to place copies of these notices on the RA website. In addition, this consultation document will be published on the RA website, on the UK Online register of consultations and in hard copy. 1.8 Regulatory Impact Assessment RA is required to complete and publish a Regulatory Impact Assessment (RIA) before any changes are made to the 450-470 MHz band. A draft initial RIA is attached to this document (Annex A) and will be developed in the light of responses to this consultation. Comments on the draft RIA are therefore particularly welcome. Page 7 of 24 450-470 MHz band alignment 2. Proposed Approach 2.1 Proposed approach RA proposes to start a managed alignment process in 2005, although some alignment will take place prior to this date where opportunities allow. The aim is to complete the process within five years. In managing the process, RA will continue to plan in partnership with the radio industry. To this end, RA continues to engage industry and customers in dialogue about band alignment through regional customer focus panels, the Mobile Services Committee (MSC) and the Industry Working Group of the 450-470 MHz Band Alignment Project (IWG), as well as through mail- and web-based publicity. 2.2 Proposed band plan and migration It is possible to arrive at a band plan for the alignment process that complies with the CEPT Recommendation, by considering a phased transition process. This is based on moving spectrum blocks within the band over time into vacant spectrum slots to achieve the desired configuration, stimulated by the migration of Public Safety users out of the band. However, it is subject to a number of constraints (to do with existing services in and adjacent to the band, and also the technical characteristics of current equipment), which dictate where and when spectrum blocks can be moved. The constraints are described in Annex B; the transition process, endorsed by a majority of IWG representatives, is described fully in Annex C. 2.3 IT solution RA, in collaboration with its IT strategic partner Radio Spectrum International (RSI), is in the process of developing a software tool that will allow re-planning of the band to the most efficient configuration. This tool will be capable of combining licence-related information from RA’s databases with data taken from external frequency managers. Using advanced graphical functionality, the tool can visually move channel assignments in conformance to the CEPT plan. This system will also automate and verify the process of propagation modelling and interference analysis, to ensure accurate alignment and optimum use of the band. The feasibility of the software tool has been researched, and the first release of this application took place in August 2002. The full development of the application will be completed by June 2003 and it is expected that users will be notified of new assignments from summer 2003. 2.4 Practical experience RA is able to draw upon the experience of a previous band re-planning project, which took place in the 1980s. Implementation of major frequency changes to police and fire services, resulting from changes agreed in the World Administrative Radio Conference 1979, was managed at this time by the Home Office Directorate of Telecommunications (DTels); this project was very similar to the current intention to align the 450-470 MHz band. The successful implementation of the DTels project relied upon precise project planning and accurate assignment data – RA is confident that, by following the same basic principles, the 450470 MHz project will be equally successful. Some of the key points that RA will consider are: users will be consulted and involved at each stage of planning and implementation; accurate radio site engineering data (especially for the more complex sites) will need to be gathered, such as assessments of: the spare capacity on masts/towers; the space in equipment rooms; the radio assignments at sites; the likely EMC issues, blocking, desensitisation and the generation of intermodulation products; the likely access problems if the site is remote, and the location of key holders; the amount of recabling necessary; and the standard of lightning protection. All this site information will be documented in a ‘constraints database’, which will form part of RA’s band alignment IT system; and the alignment scenario planning will go through several iterations before the most stable configuration can be agreed upon. Page 8 of 24 450-470 MHz band alignment 3. Benefits 3.1 Benefits of this approach 3.1.1 Spectrum efficiency By reassigning existing users into aligned spectrum, the overall result will be improved spectrum efficiency, reduced congestion and a yield of aligned spectrum. In the long term, there is a risk that the demand for spectrum in the band may outstrip supply unless there is an organised structure to the band (i.e. through band alignment). There is a view within the European PMR industry that the lack of available harmonised spectrum is the principal constraint to the development of this sector. The removal of this regulatory barrier will allow existing and new users of the band to have a wider choice of systems and to benefit from lower prices of new technology, as manufacturers gains from economies of scale. Band alignment will create band stability for new and existing assignments into the future. 3.1.2 New technology and services The release of harmonised spectrum can be used to introduce new equipment, improve the quality of existing services and allow existing users to expand their radio service. Any new equipment used in the band will need to comply with relevant UK Interface Requirements (IRs), e.g. IR2001 for PMR equipment. Examples of digital technologies presently or soon to be available are TETRA, TETRAPOL and DIIS. Providing spectrum to facilitate advances in technology will allow increased access to the spectrum, and so allow natural development of the radio business sectors occupying the band. Those that would like to use TETRA or other digital technologies will benefit from extra functionality – allowing expansion of existing services or provision of new radio services – in addition to efficiencies and a more flexible band plan due to advancement of technology. RA seeks to remove the ‘UK only’ market at the earliest possible time. This should reduce equipment costs by achieving economies of scale in manufacture, thus assisting the introduction of new digital equipment. The UK is actively contributing to CEPT Project Team FM38, which is tasked with developing a strategic view on the future use of PMR throughout Europe. While it is expected that some PMR users will continue to operate cost-effective analogue systems, it is recognised that there is a market requirement for more sophisticated PMR services, which can be satisfied by digital technologies. Accordingly, it is expected that analogue users will, given the choice, migrate to digital PMR/PAMR systems as analogue systems become more expensive to maintain and operate (due to equipment shortages and increasing operational expense). This migration from analogue to digital narrowband systems will be followed in an evolutionary step to the deployment of wideband systems offering modern high-speed data services. 3.1.3 Public Safety services There is an increasing digital communications requirement from the Public Safety services and commercial users, which requires aligned spectrum. Current tendering processes by the fire and ambulance services may create a need for new ‘guaranteed access’ bands for Public Safety services. Should this happen, part of the spectrum yield from the alignment process may be required to satisfy this need. There will be a release of spectrum when Public Safety users migrate out of the band, which will stimulate the alignment process. Such an opportunity to align the band is unlikely to be repeated in the foreseeable future. 3.1.4 Prevention of Continental interference Band alignment will offer protection against long-term interference within the band in the shortest possible timescale. If the band is harmonised throughout Europe, this will allow effective co-ordination of assignments (e.g. via the Berlin Agreement 2001) and reduce vulnerability to Continental interference in the south and east of England. Page 9 of 24 450-470 MHz band alignment 3.1.5 Alignment process management Implementation will be carefully controlled and co-ordinated by RA. This will enable RA and industry to plan the alignment’s implementation on an integrated rollout plan, removing uncertainty concerning the future of the band. RA has developed technical tools to aid this process. An RA-managed process will assist the early introduction of digital technology in a structured manner. Implementation will be co-ordinated so that assignments change with reference to each other; this will make the process easier, especially for those sharing sites or within interference range of other sites. RA proposes to reduce the band alignment’s operational impact and minimise disruption by working to an implementation plan. This will involve selectively closing the band to new assignments and completing the alignment process over the shortest possible timescale. RA will notify existing licensees of their new assignments as soon as possible (estimated to be from summer 2003). 3.1.6 Potential benefits of harmonised spectrum RA has for a number of years stated its strategic intention, through the consultative process, to align the band. Some organisations have already planned accordingly. Subject to consultation and whatever general arrangements apply at the time, spectrum trading could provide some scope for licensees to sell their licences to others. It is possible that online Internet assignments could be made in CEPT-aligned spectrum and sold by their licensees to others. Page 10 of 24 450-470 MHz band alignment 4. Implications 4.1 Band alignment survey To assess the effects of band alignment, RA carried out a customer survey in October 2001. All affected licensees in the band were surveyed, to obtain technical and economic information about their current radio use. Questions covered subjects including the extent to which licensees’ existing equipment could be modified to meet the CEPT Recommendation, consistent with the proposed new band plan (given in Annex C). The results indicated that approximately 65% of equipment currently in the band can be modified to operate on the new configuration. Economic information from the survey has been used to produce a draft Regulatory Impact Assessment (Annex A); respondents to this consultation are encouraged to provide evidence on costs and benefits if possible. 4.2 Who will be affected? The 450-470 MHz band alignment project affects licensees, equipment manufacturers, equipment suppliers, site owners and ultimately end consumers. Examples of the types of uses affected are taxis, broadcasting, medical, retail, transport, construction, education, banking, security, utilities, government and leisure. There are around 25,000 PMR licences in the band, and two national Public Mobile Data operators (having over 60,000 subscribers between them, with numbers currently growing rapidly. RA has a good working relationship with these customers and is actively assisting them in their preparations for alignment. Programme Making and Special Events (PMSE) and Scanning Telemetry (ST) users have management companies that make assignments on behalf of RA; there are around 470 ST customers and 410 PMSE customers in the band, with each customer having at least one assignment. Table 1 breaks down the customer survey responses by type of use of the band. Type of use On-Site Private Mobile Radio Public Paging Wide-Area Private Mobile Radio10 Private Wide-Area Paging Telemetry Programme Making Percentage of total respondents 70 0 22 3 1 4 Source: Band Alignment Survey 2001 Table 1: Breakdown of survey responses by type of use in the 450-470 MHz band There are 28 ‘large’ users (defined as those with over 250 mobiles) in the 450-470 MHz band, including the Public Mobile Data operators, which each have more than 250 mobiles on their systems. For large users, band alignment will represent a significant re-engineering effort. RA has already established close working relationships with some of them, and is actively helping them to assess the alignment’s effect on their operations and to identify an appropriate engineering solution. RA will also contact the remaining large users with a view to offering engineering assistance. Within the band there is a 1 MHz block (458.5-459.5 MHz) used for a number of applications by, among others, Short Range Devices (SRD). SRDs are licence-exempt, so it is not considered feasible to move this block over the timescale of the band alignment project; as a result, all changes will occur around this block. 4.3 Effects on industry Carrying out the project in the shortest possible time will entail a cost to industry. In particular, licensees may need to buy new, updated equipment before they had planned to, so will experience accelerated depreciation of their equipment. Site operators will have to revise site-engineering formats. Although this approach will mean short-term costs for some organisations, there is considered to be a wider benefit for the radio industry. Band alignment will ultimately enable the spectrum to realise its full potential and value. By choosing a short timescale, RA is trying to minimise business disruption to users, while promoting confidence in the commercial use of the band. However, given the notification period of five years and a further five-year implementation period, it is expected that industry and radio users will fund the cost of alignment to the CEPT Recommendation or seek alternative communications solutions. 10 Includes the responses from both Public Mobile Data operators. Page 11 of 24 450-470 MHz band alignment 4.4 What will band alignment mean for the licensee? Band alignment will mean that licensees will be given new frequency assignments, in the 450-470 MHz band, on which to operate. Some new assignments may be in the 440-450 MHz band. Equipment will need to be retuned (possibly including hardware modification) or replaced in order to operate on the new frequencies. Possible changes to equipment include modification of base/mobile radio transceivers, change of base-station site equipment (e.g. filters, antennas, combiners and duplexers) and recall of mobile fleet/hand portables for reprogramming. Where analogue equipment needs to be replaced, radio users may have the opportunity to purchase digital equipment. Such equipment may provide users with additional functionality, enabling them to expand their business or provide a new service. Scheduling any of the changes to equipment, within tolerable levels of disruption, will be an important consideration. For some radio users there may be a time frame that could make the change to a new frequency more feasible. For example, if the radio service is only in operation during the week, alignment could take place at the weekend; alternatively, alignment could be co-ordinated when the radio service is out of action for routine maintenance. It is conceivable that some users could change frequency remotely ‘over the air’. However, RA notes that this will not be possible for all users, as national networks and other essential radio services need to be in operation on a 24-hour basis. In these circumstances, RA will offer advice to individuals and companies in providing solutions to these difficulties. It is RA’s responsibility to manage the interference environment during alignment transitions; RA will therefore enforce a strict implementation plan, working in partnership with radio site engineers and users. 4.5 What will band alignment mean for everyone else? Radio suppliers and dealers will play a key part in the alignment process, as they will need to be prepared to plan appropriate solutions for their customers’ radio systems. For most users, it is unlikely that manufacturers will need to produce specific equipment as a direct result of alignment. However, alignment provides an opportunity to introduce pan-European equipment. Through a centrally managed process, site managers (who also have a key role to play in the process) will need to co-ordinate the retuning or replacement of base stations with their customers and with other users on the same site and nearby sites. All those involved will be given time to plan their changeover, in terms of when they should align or whether they wish to use an alternative band or find an alternative solution (such as short-term hire or GSM). Page 12 of 24 450-470 MHz band alignment 5. Responses 5.1 Responses to the consultation – some questions In response to the consultation document, particular attention is drawn to the following questions. 1 In considering the band plan given in Annex C (in particular, the frequency you are currently operating on and the frequency you will have to move to), what issues would you face as a result of band alignment? The following points might assist your thinking: the down time of your radio system during the alignment changeover period; the availability of technicians to carry out the required changes to your system; the availability of equipment (for short-term hire, new equipment etc); health and safety/contractual issues; and alternative solutions (GSM, DECT etc). 2 As a site owner, dealer or manufacturer, what issues do you anticipate regarding band alignment? 3 Do you have any comments on the Regulatory Impact Assessment in Annex A? 4 Further areas you might like to consider in your response are contained in the questions that were recently posed to users in this band – see www.radio.gov.uk/topics/spectrum-strat/450-470-realign/question/question.htm. 5.2 Dates and addresses for responses We welcome your responses to the issues raised in the consultation document and request that responses to this consultation should be sent, to arrive no later than 24 March 2003, to the following address: Band Alignment Project Team Radiocommunications Agency 11G/6D Wyndham House 189 Marsh Wall London E14 9SX Email: band.realignment@ra.gsi.gov.uk Any comments or complaints about the conduct of this consultation should be addressed to: Julia Fraser Information and Publicity Manager Radiocommunications Agency 9Y/14B Wyndham House 189 Marsh Wall London E14 9SX Email: julia.fraser@ra.gsi.gov.uk 5.3 Notes to respondents Respondents to this consultation should note that, in the interest of open government: unless confidentiality is expressly requested, individual responses will be placed in the public domain in printed and electronic form, together with the names and contact details of the authors. Respondents are requested to make it very clear if they wish to keep some or all of their response confidential and are advised to separate any confidential material into a clearly marked annex; unconditional permission to publish responses will be assumed unless the author expressly states otherwise; any copyright attached to the responses will be assumed to have been relinquished unless it is expressly reserved; and the provision of the Data Protection Act 1998 will apply to information in electronic form. Responses from representative groups should be accompanied by a summary of the people and organisations they represent. Page 13 of 24 450-470 MHz band alignment It would be helpful if lengthy written documents could be supplied on disk or by email (preferably in Word 97 format). Further copies of this consultation can be obtained by contacting: 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 Page 14 of 24 450-470 MHz band alignment Annex A: Draft Regulatory Impact Assessment 1. TITLE Alignment of the 450-470 MHz Band 2. PURPOSE AND INTENDED EFFECT 2(i) Issue and objective The radio spectrum is a scarce resource, and for some radio services there is a growing demand. Therefore there is a need to ensure that spectrum is used efficiently to meet current and future demand. To meet this main objective, RA intends to re-plan the 450-470 MHz band over a period of five years. Services operating in this band in the UK do not currently operate on the same channel plan as in Europe. This is because the base-transmit (mobile-receive) and the mobile-transmit (base-receive) frequencies are the opposite of those found in mainland Europe. RA proposes to re-plan the spectrum in line with Europe for the following reasons: to harmonise allocations in accordance with Europe; to reduce the cost of introducing digital equipment. Equipment providers would gain economies of scale in equipment, due to commonality on a European scale; to release spectrum by re-planning the band in an efficient manner. Such spectrum could allow existing systems to develop and grow, and could make it technically easier to introduce new equipment. Further spectrum may be released if users migrate to digital equipment; to reduce long-term interference from mainland Europe suffered by radio users in this band; because the Emergency Services may require harmonised spectrum; and to facilitate the consolidation of military spectrum. The timing of re-planning the 450-470 MHz band has become pertinent due to the migration of police services in England and Wales out of this band, which will be completed in 2006, and the subsequent migration of Scottish Police services approximately one year later. This migration gives RA an opportunity in the form of a free block of spectrum that could be used to re-plan the 450-470 MHz band. The result could be the release of extra spectrum from re-packing existing users into harmonised spectrum. 2(ii) Risk assessment Risks of not re-planning the band: In the future, there may be an increase in demand for spectrum, to expand existing radio services or to provide new services, which could exceed supply. This could delay or hinder the development of such services. Some radio users in the band may continue to experience Continental interference. Current spectrum may be used inefficiently (although more efficient technology could be introduced). Existing users or new users wanting to provide radio services to UK customers and Europe will not be able to operate on the same frequencies as in Europe, as the band will not be harmonised. Release of military spectrum for civil use may be hindered, as the current spectrum configuration does not support non-operational military requirements. Risks associated with re-planning the band: In the transition period, failure to co-ordinate between users moving to new frequencies may result in interference to each other and to other radio users. A risk is that users will not move according to the new band plan. During the transition period, some users may require parallel running. There is a risk that equipment will not be available, or available on time, to operate on old and new frequencies. The increase in costs incurred by existing radio users from moving to new frequencies (e.g. the increase in cost of shared sites) may have been underestimated. Uncertainty may cause users to move to more costly systems in order to meet their business needs. In the transition period, additional spectrum may be required either for parallel running or as guard bands, to move current radio users to new frequencies. Page 15 of 24 450-470 MHz band alignment The Home Office may be delayed in migrating to its new digital system, hence delaying implementation of the new band plan. 3. BENEFITS 3(i) Identifying the benefits The potential benefits of band alignment are: Release of spectrum by re-packing existing users into the band more efficiently. This will allow the introduction of new services, or the expansion of current radio services. In the band alignment survey, around one respondent in ten reported improved access to European customers, an increase in the UK customer base, and the ability to enter a new product or service market as potential benefits. A potential opportunity to introduce spectrum trading in harmonised spectrum. Radio users will have a wider choice of systems and may benefit from lower prices of digital equipment. Providers of radio services may be able to acquire additional UK customers. With new equipment allowed to be introduced, possibly with extra functionality, users may be able to increase the quality of existing services and gain more customers. In the band alignment survey, over half of those who reported that they would benefit anticipated an increase in the quality of service that their business would provide. Further, one in five of the PMR respondents wanted the ability to send text, 17% the ability to send data and one in ten wanted roaming to a public network 11. An opportunity to rationalise certain military systems, with subsequent release of spectrum in civil PMR bands. 4. COMPLIANCE COSTS 4(i) Business sectors affected Radio is used by businesses and public organisations of all sizes, throughout the economy. The alignment of the 450-470 MHz band will affect all licensees in the band. In particular, the following types of radio users will be affected: Programme Making and Special Events; On-Site Private Mobile Radio; Wide-Area Private Mobile Radio; Telemetry; Private Wide-Area Paging; and Public Mobile Data operators These types of users use radio for a wide variety of business and public activities such as taxis, broadcasting, medical, retail, transport, construction, education, banking, security, utilities, government and leisure. In the band alignment survey carried out last year, most respondents were in the public services, education and health sectors. Furthermore, there are 28 large users (i.e. those with over 250 mobiles) in the 450-470 MHz band. In the band alignment survey, around 40% of the respondents had up to nine mobiles. 4(ii) Identifying costs The potential costs of alignment are likely to be incurred by existing radio users. These costs are likely to be: Loss of residual value of current equipment. Where current equipment cannot be retuned, users will need to purchase new equipment so may experience accelerated depreciation. Cost of retuning existing equipment (if possible). Around 65% of the respondents to the band alignment survey said that their existing equipment was retuneable. Loss of revenue to radio users from their radio service being out of action with no substitute available. Cost of employing more staff to retune or replace all equipment. Cost of migrating to an alternative service or band. 11 Private Wide-Area Paging users generally preferred greater coverage and roaming to a public network. Wide-Area PMR users were more likely to see the ability to send data as a useful additional function. Page 16 of 24 450-470 MHz band alignment 5. COMPETITION ASSESSMENT Various types of public organisations and private individuals/companies use radio to provide a service, so competition in a range of product and service markets is likely to be affected. For example, in the upstream market this may be in the supply of equipment, possibly on a European level if equipment becomes harmonised. Examples of downstream markets that may be affected include the provision of taxi services or security services. These markets are likely to compete on a local, regional and national level. Band alignment is likely to affect some firms more than others. For example, a company that purchased equipment relatively recently is likely to incur larger equipment-related costs (i.e. early depreciation) than a company planning to update its system soon after 2005 anyway. Consequently, band alignment is likely to affect the market structure in many markets. The costs of band alignment to current radio users may make it difficult for some companies to compete, particularly if their competitors are not faced with these additional costs. As a result, some companies may have to exit the market, leading to less choice and higher prices to end consumers. On the other hand, band alignment may have a positive impact on competition. Existing users may be able to upgrade to digital systems, improving the quality of service to end customers. Such users may also benefit from being able to purchase lower-cost digital equipment. The release of spectrum also provides scope to expand or introduce new radio services. This will have the benefit of increasing choice and lowering prices to end customers. 6. CUSTOMER SURVEY RESULTS In December 2001, RA carried out a survey, obtaining economic and technical data to assess the replanning of the 450-470 MHz band. Questionnaires were sent to all 9,238 customers that will be affected by band alignment. The results from this questionnaire have been used to produce this Regulatory Impact Assessment. 7. ENFORCEMENT, SANCTIONS, MONITORING AND REVIEW When band alignment is implemented, RA will have to monitor the users moving to new frequencies. During the process of migration, RA will need to ensure that users are protected from interference and that they move out within the specified time frame. Page 17 of 24 450-470 MHz band alignment Appendix 1: Quantifying the Costs and Benefits of the 450-470 MHz Band Alignment This appendix provides an estimate of the potential costs and benefits. 1. Quantifying the Costs In calculating the costs of alignment, the following assumptions have been made: Any equipment that is not retuneable will need to be replaced. Therefore, costs will be incurred by users whose equipment will not operate on the new frequencies and will expire after 2010. Between 2005 and 2010, costs may be incurred by users whose equipment expires early because they are required to operate on new frequencies when it is technically feasible (according to the new band plan). This may mean that users cannot move when it is economically viable, namely at the end of their equipment’s lifetime. Equipment that is retuneable will incur retuning costs. Most users will incur their equipment costs in a single year. Users with a large number of terminals may incur equipment costs over several years; however, the band alignment survey found that over 40% of respondents had up to nine handheld or vehicle-mounted terminals, suggesting only a small number of large users. The potential costs of band alignment have yet to be estimated using the format outlined in Table 2 below. 2. Quantifying the Benefits The most significant benefit from band alignment will be the release of harmonised spectrum. This spectrum may benefit many companies and individuals. The benefit to the UK economy from releasing this spectrum has been calculated using RA’s Economic Impact Study 2001 12. This study calculated the net benefits of different types of radio services, including Private Mobile Radio (PMR). Large firms, small companies and public organisations use PMR to help them in their day-to-day business. The principal beneficiaries are the users, and therefore the largest benefits accrue in the form of consumer benefits. Consumer benefits (consumer surplus) accrue if the price users are willing to pay for a good or service exceeds the price they actually pay. In the Economic Impact Study, the consumer benefits of using PMR were estimated by commissioning a survey to determine the willingness to pay for PMR. The total net benefit of Private Mobile Radio was estimated to be £1,051 million in 2000. The spectrum available to PMR was estimated to be 39 MHz 13. Dividing £1,051 million by 39 MHz of spectrum provides an estimate of the annual average benefit to the UK economy from using PMR per MHz of spectrum. This figure was calculated to be £26.9 million per MHz per year at 2000 prices. This is £27.5 million per MHz at 2002 prices 14. However, this value assumes that all 39 MHz of PMR spectrum is congested and of equal value. The migration of the Emergency Services from the 450-470 MHz band will free up around 6 MHz of spectrum. If this spectrum is used for PMR, assuming that PMR is the best use of spectrum, then 6 MHz of spectrum could benefit the UK economy by £165 million per year. This benefit could be achieved regardless of band alignment. See Table 1 below. Band alignment will release additional spectrum by re-packing existing users into the band more efficiently. It is estimated that an additional 2-3 MHz of spectrum may be released. It is assumed that this additional spectrum will be released in 2011, as band alignment will have completed by the end of 2010. Therefore, the one-off benefit of releasing 2-3 MHz spectrum in 2011 is estimated to be in the range of £55 million to £82 million in today’s prices. See Table 1 below. 12 Available at www.radio.gov.uk/topics/economic/eis-report.pdf Source: Land Mobile Statistics Report 2002, published by RA. The calculation consisted of {(Total number of dual-frequency channels x 2) + Total number of single-frequency channels} x 12,500 = 39MHz 14 Inflated using GDP deflators. Source: www.hm-treasury.gov.uk/Economic_Data_and_Tools/GDP_Deflators/data_gdp_fig.cfm 13 Page 18 of 24 450-470 MHz band alignment Quantity of Spectrum (MHz) Value (£ million) Effect 6 165 Migration of Emergency Services from the 450-470 MHz band, regardless of band alignment 2-3 55-82 Benefit from re-planning the 450-470 MHz band Table 1: Benefits of releasing spectrum However, the benefits of band alignment are likely to be higher due to the following additional benefits: benefits of cheaper equipment to users in the realigned 12 MHz spectrum; incremental benefits of moving 6 MHz of spectrum (as either contiguous or fragmented spectrum, and the range of services which could be permitted); benefits of enhanced services from the use of digital equipment in the realigned 17-18 MHz of spectrum; and benefits of reduced Continental interference. Page 19 of 24 450-470 MHz band alignment Type of user On-Site Private Mobile Radio Private Paging Wide-Area Private Mobile Radio Programme Making and Special Events Telemetry £ £ £ £ £ £ £ £ £ £ Number of licences Number of users Costs Loss of residual value of equipment Cost of retuning equipment Loss of revenue from radio service out of action Increase in staff costs Other costs Total costs Benefits Increase in revenue from access to European market Increase in revenue from more UK customers Value of released spectrum Total benefits Total net benefits Table 2: Costs and benefits of band alignment over a five-year period Actual cost-benefit analysis is currently being carried out. Some users, particularly large users, are likely to incur different costs and benefits, and these will be taken into account. Respondents to the consultation are invited to comment on the Regulatory Impact Assessment, and are encouraged to provide data where possible. Page 20 of 24 450-470 MHz band alignment Annex B: Constraints of the Band Plan It is possible to construct a phased transition process to arrive at a band plan for the aligned spectrum. This is based on moving spectrum blocks to achieve the desired configuration; however, it is subject to a number of constraints which dictate where spectrum blocks can be moved to. This band plan has met with almost unanimous agreement within the Industry Working Group (IWG) as a way in which alignment could be taken forward. Constraints Emergency Service migration Migration of the Emergency Services to their new system will leave two 3 MHz holes in the spectrum at 14 MHz duplex. Effecting a single move of base and mobile frequencies within the band is considered to be the least disruptive way of achieving alignment. It is possible to move both legs into vacant spectrum, but this limits the moves that are possible to achieve an aligned plan. Base-mobile crossover The transition between the base-receive and base-transmit frequencies occurs in the middle of the band at 460 MHz. This is the most sensitive part of the band, with the possibility of base receivers just below 460 MHz being adversely affected by transmitters placed just above 460 MHz. It will be necessary to consider very carefully how the spectrum in this area is allocated. Television channel 21 Another consideration when planning the upper end of the band is the presence of television channel 21. The terrestrial television spectrum immediately above the band is divided into 8 MHz channels, the first of which (470-478 MHz) is denoted channel 21. This lowest channel only came into widespread use with the start of Channel 4. Studies conducted in the early 1970s showed that there was a compatibility problem between narrowband base stations (e.g. 12.5 kHz PMR bases) and domestic reception of television signals on this channel if the narrowband bases were close geographically to the television receiver and they operated above about 466 MHz. When the current plan for 450-470 MHz was devised, it was not known where channel 21 television transmitters would be located, so 467-470 MHz was kept clear of base transmitters. In the new plan, base transmitters are to be placed above 460 MHz, so the constraint is to avoid interference to domestic television reception on channel 21. The locations of analogue television transmitters and the first phase of digital transmitters on channel 21 are now known. It is possible, therefore, for newly planned base transmitters above 466 MHz to be co-ordinated with the television service. This will mean that users of bands above 466 MHz may have geographical limitations on use of their spectrum. Digital television receivers are known to be less sensitive to out-of-band interference, but new digital transmitters are likely to be introduced as analogue switchover approaches. The pattern of restrictions is therefore likely to be a moving target, and further research is required in this area. Flexibility of the band plan As implementation of the band alignment is scheduled to begin in 2005, the greatest difficulty is predicting the technological market share that will have arisen by then. To cope with this uncertainty, RA has attempted to design a technology-neutral plan that does not specify whether the technology will be analogue or digital, proprietary or open standard. Instead we have opted for a co-existence mask. This is a compromise between waiting to see what technology prevails in five years (an option which would not leave enough time for proper planning) and mandating current technology (which would run the risk of not being forward-thinking enough nor able to introduce the then current market-favourite technologies). The use of CDMA has been discounted by the IWG, which felt that the technology would not be suited to the use currently existing in the band. Instead, RA favours creating a channel raster from the highest common factor. A raster of 1.25 kHz would allow channel widths appropriate to narrowband and wideband technologies. A more detailed look at the proposed band plan can be found in Annex C. Page 21 of 24 450-470 MHz band alignment Annex C: Band Plan Rationale From the band plan diagram, it can be seen that we propose to realise the alignment in a phased process. We have chosen to set basic constraints on the way the alignment is achieved: paired blocks must be positioned 10 MHz apart; each block moves only once; and each move puts a block into vacant spectrum where possible. There is a limit to the moves that are possible at each stage, since in general each move is facilitated by those that have preceded it. Of the various block allocations within the band, two are of particular interest since they do match the CEPT Recommendation. One of these is the small allocation for maritime on-board15 use at 457 MHz and 467 MHz. These two blocks are the same size and are spaced 10 MHz apart. They are also international allocations so it is not feasible to move them. The other allocation in this category is the single 25 kHz paging channel at 466.075 MHz. This is an allocation used in various countries in Europe, although use in the UK has ceased. Paging is effectively base transmit, and this channel is already in the upper half of the band. For the time being, this channel will remain in reserve. There are other blocks that appear to be spaced at 10 MHz, but these blocks are not paired with each other. There is a 1 MHz block used by Short Range Devices (SRDs), which are licence-exempt. It is not feasible to move this block over the timescale of this project, so all moves will occur around this block and it will remain intact. To begin the alignment, first we are looking for blocks that can be moved to create holes with 10 MHz spacing. There is a hole at 464-467 MHz and another at 450-453 MHz, so we can either: a) move something from within 454-457 MHz and so create a hole in this range; or b) move something from within 460-463 MHz. The CEPT Recommendation, as well as defining the configuration for 450-470 MHz, also identifies the band 440-450 MHz as being for simplex (single-frequency) usage. RA has been negotiating with the Ministry of Defence to gain greater access to military spectrum in 410-450 MHz. Civil access to some single-frequency channels on a national basis within 440-450 MHz has recently been granted. There is currently a block of Wide-Area Paging, which is single-frequency base transmit, at 454 MHz. Since this is single-frequency usage, it should be positioned in channels between 440 and 450 MHz. The proposed process for the alignment is as follows: Step 1 The single-frequency European Wide-Area Paging channel lies within the Emergency Services allocation that will become vacant after migration. This channel is not used at present in the UK, but the channel will continue to be held in reserve for the time being. The first move of the plan is to migrate the 454 MHz WideArea Paging block to new dedicated national channels between 440 and 450 MHz. This creates a hole at 454-455 MHz, which can be paired with the ex-Emergency Services hole at 464-465 MHz. Which block to move next? We have to think what paired holes can be created as a result of each move. Step 2 Within the band there are two pairs of blocks for PMR (used for duplex services) and one block for singlefrequency assignments. Within the paired PMR blocks there are a number of channels that, as well as being duplex channels, also exist as independent single-frequency channels. The second phase is to move the purely duplex assignments in one of these pairs (456-457 MHz/461.5-462.5 MHz) so that the base-receive leg moves into the spectrum vacated by Wide-Area Paging at 454 MHz and the corresponding base-transmit leg to ex-Emergency Services spectrum at 464 MHz. Not all the channels in the existing block contain assignments, and additionally there will be some spectrum yield as a result of using new and better spectrum assignment techniques. This block will therefore fit into less than 1 MHz. ITU-R Radio Regulations Article 5.287 states, ‘In the maritime mobile service, the frequencies 457.525 MHz, 457.550 MHz, 457.575 MHz, 467.525 MHz, 467.550 MHz and 467.575 MHz may be used by on-board communication stations. Where needed, equipment designed for 12.5 kHz channel spacing using also the additional frequencies 457.5375 MHz, 457.5625 MHz, 467.5375 MHz and 467.5625 MHz may be introduced for on-board communications. The use of these frequencies in territorial waters may be subject to the national regulations of the administration concerned. The characteristics of the equipment used shall conform to those specified in Recommendation ITU-R M.1174 (see Resolution 341 (WRC-97)).’ 15 Page 22 of 24 450-470 MHz band alignment Step 3 As explained in Step 2, there are a number of channels within the paired PMR blocks that, as well as being duplex channels, also exist as independent single-frequency channels. The next step of the move starts to gather these single-frequency channels into channels between 440 and 450 MHz, in line with the CEPT Recommendation. These are largely on-site services, which can conveniently be considered as mobile transmit since, even though there may be base stations, these will be of similar power to handheld radios. So the single-frequency block is placed below 450 MHz in the single-frequency band. Step 4 Scanning Telemetry (principally used by the utilities for remote acquisition of data for command and control purposes) occupies two blocks, each of 1 MHz. One of these blocks is used by central stations that transmit to a number of outstations and collect data. The other is used for transmissions from the outstations. The scanner can be considered a base station and the outstations can be considered mobiles, even though they are fixed in location and can thus use directional antennas. This phase moves the scanner transmitters to 461.5-462.5 MHz, vacated by PMR mobile transmitters in a previous phase. The outstation transmitters move to 451.5-452.5 MHz, which is vacant since this is ex-Emergency Services spectrum. Step 5 This rationalises the residual Emergency Services spectrum – which is currently made up of several small blocks in various positions in the band – into two blocks with the correct spacing. Step 6 There are 26 channels used at airports for controlling the movement of vehicles in close proximity to aircraft. These are basically PMR systems, but require Civil Aviation Authority (CAA) approval for assignment. These channels are moved in this phase to holes at 467 MHz and 457 MHz, both of which were vacated by Emergency Services in the previous phase Step 7 Programme Making and Special Events has a number of blocks distributed in the band. At present these are concentrated towards the top of the band, but (as explained in Annex B) this can be problematical in areas where television channel 21 is used. Major news or sporting events generate a large requirement for separate, co-located on-site systems; this requires careful frequency planning to avoid technical problems. To meet this requirement, it is best to provide several small blocks distributed throughout the band rather than one large contiguous block. This phase creates a pair of 500 kHz blocks in the centre of the band, at approximately 455 and 465 MHz. At present, the bottom end of the lower block contains some channels used for railways’ track-to-train communications systems (allowing one-person operation of trains). In time, this system will migrate to a new digital system in a different band, so these channels will become clear. Step 8 This moves the single-frequency channels within the other paired PMR block at 453-454 MHz and 459.5460.5 MHz into channels between 440 and 450 MHz. Step 9 This moves the duplex channels in the second PMR pair to be appended to the existing aligned duplex channels. This creates a large contiguous paired PMR block. Step 10 We now complete the single-frequency block by moving the single-frequency channels from 461 MHz to channels between 440 and 450 MHz in the new single-frequency block. Step 11 This continues the redistribution of Programme Making and Special Events spectrum by creating a paired block at the bottom of the band, separated by approximately 5 MHz from the block created previously. Step 12 This completes the process by rationalising the remaining Programme Making and Special Events spectrum, through extending two existing blocks at just above 457 and 467 MHz, either side of the already correctly positioned Maritime On-Board channels. The 12 steps of the process are illustrated in the chart accompanying this document. Throughout the process it is not possible to give exact frequency ranges for the new blocks of spectrum, since the extent to which yields will be made as a result of the introduction of better spectrum planning techniques is not yet known. Page 23 of 24 450-470 MHz band alignment Annex D: Consultation Criteria 1. Timing of consultation should be built into the planning process for a policy (including legislation) or service from the start, so that it has the best prospect of improving the proposals concerned, and so that sufficient time is left for it at each stage. 2. It should be clear who is being consulted, about what questions, in what timescale and for what purpose. 3. A consultation document should be as simple and concise as possible. It should include a summary, in two pages at most, of the main questions it seeks views on. It should make it as easy as possible for readers to respond, make contact or complain. 4. Documents should be made widely available, with the fullest use of electronic means (though not to the exclusion of others), and effectively drawn to the attention of all interested groups and individuals. 5. Sufficient time should be allowed for considered responses from all groups with an interest. Twelve weeks should be the standard minimum period for a consultation. 6. Responses should be carefully and open-mindedly analysed, and the results made widely available, with an account of the views expressed, and reasons for decisions finally taken. 7. Departments should monitor and evaluate consultations, designating a consultation co-ordinator who will ensure the lessons Page 24 of 24