DocumentNumber: RL 6/307
Organisation: London Buses
Address: Manor House Offices 279 Seven Sisters Road
Town: London
County: London
PostCode: N4 1QG
Source: Consultative Document
Date: 22 July 1994
LONDON BUSES LIMITED COMMUNICATIONS SYSTEMS
22 July 1994
Mr Green
The Future Management of the Radio Spectrum
Please find here with our response to the Consultative Document.
Technical Manager
SPECTRUM MANAGEMENT FOR THE FUTURE
A response to the consultative document "The future of the radio spectrum" issued by the
Radiocommunications Agency in March 1994.
Prepared by:
Technical Manager
LONDON BUSES
CONTENTS
1. Background of London Buses use of radio systems
2. Evaluation of recent publications and presentations
3. London Buses Limited commentary on Spectrum Management
1.
BACKGROUND SUMMARY OF LONDON BUSES LIMITED
London Buses has operated various PMR radio networks since the 1960's, and is currently on its second
generation system using a Band Ill MPT1327 trunk. This provides emergency call facilities for bus operators,
speech and data, route control, Automatic Vehicle Location (AVL), and it also supports some Passenger
Information at Bus Stops (PIBS) systems for the vehicle location link.
Currently the system is operating with 39 channels, 5800 mobiles and 650 handportables. Of the mobiles,
approximately 900 are equipped for control channel (short data message) AVL and 125 using traffic channel
AVL.
Current plans and work for expanding the network include the addition of a further 15 channels, which have
been agreed by the RA and the Confederation of Public Transport (UK) (CPT). Also, London Transport is
continuing its development of Passenger Information at Bus Stops with the support of the Department of
Transport. This requires the addition of some 460 or so of the existing vehicles to be modified to support
traffic channel
AVL.
The Communications Systems group is investigating and developing techniques for increasing the capability of
its systems to provide improved efficiency of its radio network to support vehicle location systems.
Bus operating companies have expressed interest in the use of GPS and various terrestrial location systems as
an alternative to the microwave beacon and odometer location system currently favoured by LBL.
As professional PMR users we have for a long time recognised that spectrum is difficult to manage, and are
fully aware of our responsibility to make efficient use of channels. London Buses has invested a large sum to
provide the capitals' bus operators with good radiocommunications, and tries to ensure equitable system costs
for them. It is not welcomed by us when radio channels are allocated to independents for small PMR schemes
in major conurbations where trunking is the acceptable standard to improve efficiency, when larger companies
supporting the trunk network are (surprisingly enough) disadvantaged in their operating costs against channel
inefficient small PMR schemes.
2.
EVALUATION OF
SUBMISSIONS
RECENT
PUBLICATIONS.
PRESENTATIONS
AND
DRAFT
The Fielding Report
We have followed the debates and studied the report of the Radio Spectrum Review Committee Stage 3, 28470MHz, chaired by Sir Colin Fielding, CB.
We believe that the committee has most adequately stated the view which LBL would support in chapter 11,
paragraphs 26-41, and we later provide in our chapter 3 some additional comments.
The Consultative Document
The consultative document - "The Future Management of the Radio Spectrum" is a most welcome presentation
by the RA. However, at the Chief Executive's briefing on the 11 May 1994 we were told that the "heart of the
matter" is spectrum pricing. Having, over the years, contributed perhaps £1m in licence fees we are not at all
convinced by this argument, but we will not dwell on specific issues since the Fielding Report covers them in
general and are common knowledge.
It is, however, noted and appreciated that the Government has no intentions of using the radio spectrum as a
source of taxation, rather a source of revenue for spectrum management. We are broadly satisfied with the
existing licensing system in principle, but consider that criteria including "polluter pays" factors need greater
investigation.
As far as a regulating authority is concerned, we would concur with Gerald David's remarks at the Forum that
we would wish licensing revenue to support and develop the RA as a centre of excellence for the overall
benefit of our citizens and UK industry.
Draft Response to the Consultative Document by the MRUA
Our sighting of the Draft paper by the MRUA enables us to believe their submission would be supported by
London Buses Limited.
Draft Response by the NRULG
The association by members of groups such as The National Radio Users Liaison Group, the Joint Radio
Committee and so, may serve the purposes of their members well. However, it cannot be concluded that
SMO's are in any way a substitute to an open and efficient organisation such as we would wish the RA to
become. Whatever success SMO's have achieved in the PMR sector may be due to rationing factors. The
mechanisms for existing and new SMO's to develop for the future will need to be conceived by the RS with
consultation in industry and representative bodies and regulated by the RA.
Our commentary which follows may therefore add some emphasis to our perspective.
3.
LBL Commentary on the Spectrum Management
Rights to the Spectrum
Since the spectrum is not owned by anybody it cannot be sold, or even given away, without international
consent and agreement. It is necessary to maintain adequate laws for its protection, but we see the major
difficulty here as the manner of its evolution, and the present need for an elegant solution to deal with the
prospect of continual change and improvement. We believe that the RA has been obstructed by the entrenched
interests which can only be released by a long term rationalisation objective of even 50 years or more to
complete international harmonisation.
We believe that the technical issues and cost effective migration schemes cannot be achieved in the short, or
even medium, term. However, it cannot be doubted that the spectrum could better be divided by the
propagation and noise characteristics of our environment in a more ideal fashion, using a scientific approach
rather than the existing technique of "infilling".
Spectrum Administration
We wish to see the RA or an equivalent organisation operating under the Parliamentary and EC legal
framework as the regulatory authority. Advisory committees have a place but they attract the focused attention
of powerful organisations. We would wish the example to be followed of using the Consultative Document to
be the future mechanism for periodic reviews and the confirmation of longer term strategy.
Control of the Spectrum
We believe that the spectrum will continue to be universally mismanaged without adequate technical, quality
and operational standards. We have seen or heard little but simplistic and contentious arguments and views on
this matter, and feel that a great deal of work is needed to begin the process of spectrum management. Without
a satisfactory code of practice and firm legal footing, pricing techniques and SMO's cannot be expected to
achieve the desired results.
Whilst there is an argument which says that the spectrum is a finite resource, there is a counter argument which
says that it is infinite. It is available everywhere for ever, and it cannot run out - unless it becomes unusable. It
is the waste of unused spectrum and its pollution which should be regulated, and penalised if necessary, just as
much as charging processes should be applied for usage in support of the administrative costs.
We have little doubt that individuals, professional organisations and the industry would make financial
contribution to establishing a decent set of rules for spectrum management given a good lead by the RA in the
same manner as the consultative document.
Open Planning Structure
We believe that people concerned with system planning have every right to expect the best available
information to support commercial and development plans. Consequently, they should not hinder others
attempts to use the spectrum efficiently by concealment of information, except of course in the interests of
national security although this is overstated on occasions.
It is clear that those bodies who are concerned with confidentiality over the medium must stay ahead by the use
of encryption devices at their own cost.
Pricing Techniques
LBL is completely against auctioning as it is not a suitable means of regulating radio channel availability and
improving efficiency, and fully supports the Fielding Report recommendations. Also, due to the low cost
operations of most bus companies it is difficult to see how they would be able to compete for channels in this
auction process.
The current administrative pricing policy in operation with the RA is the best approach, but changes are needed
to ensure better effectiveness and control.
A recent conference at the IEE on Traffic Control and Automation reminds us that road traffic tolls are
somewhat analogous to spectrum pricing. There has possibly been far more research and practical analysis in
the traffic management field than in spectrum management. Yet, pricing techniques and traffic control are still
not fully understood. Nevertheless, some cross fertilisation on research may yield mutual benefits to both of
these fields of study and help to establish a mathematical technique to lead us forward to the future.