25 July 2003
tel: 020 7728 1310
fax: 020 7728 1778
paul_deedman@inmarsat.com
Martin Fenton
Public Wireless Networks Unit
Radiocommunications Agency
11R/2A
Wyndham House
189 Marsh Wall
London E14 9SX
Dear Mr Fenton,
Subject:
Inmarsat reply to the RA Consultation Document "Use of the 1781.71785.0 / 1876.7-1880.0 MHz Bands for the Provision of GSM 1800
Telecommunications Services"
Inmarsat welcomes the Agency's consultation on possible new uses of the GSM 1800 guard
bands. Inmarsat has been developing proposals for the integration of GSM technology with
satellite technology for a number of applications. These include the operation of GSM
picocells on ships and on aircraft. The consultation is therefore well timed.
Inmarsat strongly supports the second option - the use of this spectrum for short range, lowpower use on a licence-exempt basis. This is the boldest of the options entertained in the
consultation document, but the one which we anticipate to give most benefit to UK plc
through the introduction of new services for UK consumers.
In the attachment, we give our answers to the specific questions posed.
Please contact me if I can provide any clarification or further information.
Yours sincerely,
Paul Deedman
Senior Engineer
Spectrum Management
Attachment
Question 1
Given the other potential uses outlined in this document, do you consider it
most appropriate to make the spectrum available for wide-area public use?
Answer 1
No. For reasons we explain further below, Inmarsat considers that the greatest
benefit to UK plc would come from making the spectrum available for short
range, low-power GSM services.
Question 2
If your answer to question 1 is yes, do you consider it most appropriate for the
spectrum to be used to supplement the spectrum of the existing GSM operators,
or to be made available for potential new GSM operators on a regional or
national basis?
Answer 2
Not applicable.
Question 3
If your answers to questions 1 and 2 are yes, do you consider it most
appropriate for the spectrum to be awarded via an auction process?
Answer 3
Not applicable.
Question 4
Given the other potential uses outlined in this document, do you consider it
most appropriate to make the spectrum available for short-range, low-power
GSM use on a licence-exempt basis?
Answer 4
Yes. For the applications which are envisaged for this spectrum, little
regulation would be required by the government. Operations should be
maintained at a sufficiently low power that the risk of interference from one
system to another is negligible. This can be ensured without licensing through
licence exemption legislation and Interface Requirements in a similar way to
systems in the 2.4 GHz ISM band. Thus there should be no need for licensing.
It will also be necessary to ensure that applications do not unfairly compete
with the existing four GSM licensees. The definition of "low-power" will also
have to be considered in this context, but it should be sufficient to allow an
operator in the unlicensed spectrum at least to provide in-building coverage at
reasonable cost.
Question 5
If your answer to question 4 is yes, what kinds of application do you anticipate
will develop? Estimates of potential market size and anticipated penetration
would also be useful.
Answer 5
The Agency was identified a number of applications in section 5.2.4. In
addition to these example public service offerings, there may be applications
for closed users groups such as schools and offices. These public and private
applications have high potential and would most likely be applications
generating the strongest demand. For Inmarsat, interest lies in some specific
applications, two of which are described below.
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We point out that the applications considered by Inmarsat are ones which are
either not provided for by the existing GSM licensees or are provided for to a
limited extent only.
a)
Provision of public services through GSM pico-cells on ships.
There are already a number of ships which have GSM pico-cells operating on
board. These are typically installed on cruise ships and ferries, and provide
GSM service to crew and passengers. The pico-cell can be linked to land via a
satellite link, either using standard Inmarsat terminals or ESVs (Earth stations
on Vessels). Currently, operation is generally restricted to regions some
distance from shore to avoid causing interference to land based networks. This
restriction results in significant areas of the sea where the GSM services cannot
be operated and hence this service is typically limited to ocean-crossing ships
or the longer distance ferry routes. However, if this spectrum is made
available for low-power public service operation, it could be used by pico-cells
on ships close to UK shores. This would lead to an increased number of ships
for which this service could be applied, in particular ferries which operate to
UK ports.
In the UK context, we estimate that the total market for GSM pico-cells on
ferries operating from UK totals about 60 ships. The market for cruise ships
operating close to UK shores is harder to estimate, but is probably hundreds of
ships. In combination, thousands of passengers and crew could be expected to
make use of such services.
Aside from the market for passenger services, the global market for crew
calling has great potential. The total number of seafarers is approximately 1.23
million people. The International Chamber of Shipping estimates that 60% of
the total workforce is at sea at anyone time, or approximately 740,000
seafarers.
Inmarsat envisages great potential from the provision of GSM services on
ships. The ability to operate on a low-power licence exempt basis close to UK
shores would considerably enhance the attractiveness for ship operators around
the UK. If such an approach is successful in the UK, we would hope to see
other administrations follow suit, reducing or removing the geographic areas
where service has to be excluded.
The consultation document notes that there are additional regulatory
difficulties for the use of such services on ships. The only difficulty in this
case relates to the need to ensure that no interference is caused to the services
of other administrations. However, since the authorised use would be
restricted to low power, and limited to UK waters, the risk of interference to
other administrations would be negligible. In any case, the responsibility to
ensure that no interference is caused would lie with the service provider or ship
operator.
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b)
Provision of public services through GSM pico-cells on aircraft
The market for in flight wireless services is considered to be significant.
Airline passengers want to use their normal communications equipment and
personal profile. Airlines want their passengers to use cellular telephones on
board an aircraft within the safety regulations that govern in-flight safety
standards.
Given the current customer demand for this type of service and industry focus
on resolving the commercial and technical issues, we believe there is potential
for this technology to be realized on board commercial aircraft within the next
two years.
The agency notes that there are a number of regulatory issues which would
need to be overcome before such an application could be authorised. However
there is wide industry interest in the provision of wireless services on aircraft
which will give sufficient impetus to tackle the regulatory issues. A number of
fora are examining related issues, including the European Organisation for
Civil Aviation Equipment (EUROCAE). GSM pico-cells on aircraft could
only be brought into use once all the necessary regulatory issues have been
satisfactorily resolved. Hence, we consider that if the Agency does choose the
option of low-power, licence-expect applications, then the Agency would have
no reason to exclude the possible use on aircraft.
Question 6
If your answer to question 4 is yes, should the use of this spectrum for the
provision of public services be allowed?
Answer 6
As explained in Answer 5, the applications envisaged by Inmarsat are for
public services. We therefore support the authorisation of public services
under this option.
Question 7
If your answer to question 6 is yes, specifically what kinds of public-service
offerings do you anticipate will develop? Estimates of potential market size
and anticipated penetration would also be useful.
Answer 7
See Answer 5.
Question 8
Do you consider it prudent not to release the spectrum at this stage but to keep
it unassigned, thus assisting future migration to 3G and facilitating T&D work
Answer 8
Leaving the spectrum unassigned removes the possibility for the UK to gain
economic benefit from that spectrum. Regarding the concern expressed in
5.3.2 that it may be difficult to change its use at a future date and the concern
expressed in 5.3.3 regarding fragmentation of the band for UMTS, we make
the following comments:
As the Agency suggests, the curtailment of low-power unlicensed applications
from the bands in question will most realistically be accomplished
automatically by a more general trend in the transfer of mass market mobile
services from 2G to 3G. The existing licensed GSM services in the 1800
MHz band will provide a constraint to conversion of this band to UMTS until
such a time that 3G services are much more dominant. This is likely to be
many years from now. Since the use of unlicensed GSM services will mirror
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the use of licensed GSM services, the constraints resulting from legacy GSM
services apply to the licensed 2G bands to the same extent that they apply to
any unlicensed 2G bands. Hence we consider that when the RA (or OFCOM)
determines that the licensed GSM spectrum can be converted to 3G, then any
unlicensed GSM spectrum can also be converted at the same time.
Regarding the use of this spectrum for T&D work, this spectrum provides a
useful opportunity for such work. This work could continue in this band,
provided the equipment meets the necessary power limits. For higher power
T&D work, alternative solutions would be necessary, such finding alternative
bands (possibly in the GSM 1900 spectrum), or limiting testing to
geographically isolated areas. Overall, we consider that the benefits of
permitting use of this spectrum for new applications far outweigh the costs.
Question 9
Do you consider it necessary to limit future use of the spectrum for a set
period, to ensure that future migration to 3G is not hindered?
Answer 9
We concur with the suggestion in 5.4.2 that, by limiting the use of this
spectrum to GSM services, as services transfer to 3G this will automatically
limit the duration for which the band could be used. This is particularly the
case for public services which will most likely rely on members of the public
carrying GSM compatible phones. Furthermore, with the current uncertainty
over the growth of 3G services, and no sign of a decline in 2G services, such a
date would be almost impossible to set appropriately today. If however, the
Agency does consider that a date limit is necessary, this could be considered at
a later time, for example at the same time that the conversion of the licensed
spectrum to 3G services is considered.
Question 10
If your answer to question 9 is yes, what period do you consider is
appropriate?
Answer 10
Not applicable
Question 11
Is it desirable and practical to make the spectrum available in a technologyneutral way, either for wide-area public use or for short-range, low-power,
licence-exempt use?
Answer 11
For the applications considered by Inmarsat, we envisage only GSM
compatible equipment to be used. Hence we could accept limitations to this
technology. We propose that the mechanism of self-limiting the duration of
use of the band is used, but for this to function only GSM technology should
be used. For this purpose, it may be necessary to limit use to equipment
complying with GSM standards.
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