SUVAN Marine
Solutions Ltd.
Data
2 Caterham Avenue
Bolton
BL3 3RF
01204 656022
suvan@btinternet.com
www.suvan.btinternet.co.uk
13 February, 2016
Daniel Storey
Secretary Spectrum Review
C/o Radiocommunications Agency
Wyndham House
189 Marsh Wall London
E14 9SX
Dear Mr Storey
SPECTRUM REVIEW – AERONAUTICAL AND MARITIME SERVICES
Trusting an interested observer is permitted to contribute to this discussion, a few comments
on the consultation paper primarily related to maritime services.
Issue xxiv
I believe the review misses some important points with respect to the factors affecting the use
of radio spectrum by maritime services.
The maritime industry is far from homogenous. Nor, therefore, are the factors affecting the
maritime service’s use of radio spectrum. In the table and narrative attached I have broken
the industry into four business sectors to characterise the important influences. This is not to
suggest ships within these sectors are not provided with, or otherwise do not use other forms
of communication, i.e., spectrum. For example, HF (3-30 MHz) is an integral part of the
Global Maritime Distress and Safety Service (GMDSS), thus HF equipment will be found on
most ships. However, this equipment is provided purely to comply with regulatory diktat thus
seldom, if ever, is now used; the last, effective, commercial HF maritime service recently
ceased operation and all marine HF services in the UK were closed down some time ago
now. In other words, the table reflects the principal spectrum used within the sector.
To summarise, in terms of spectrum use by the maritime service:
i. Virtually all communications, including distress and safety if beyond the range of
cellular/VHF, are facilitated through commercial service providers;
ii. There is increasing convergence with terrestrial industries;
iii. In most cases, ships’ business and distress/safety communication use is distinct and
separate;
iv. Other than for distress and safety, it is difficult, if not impossible to identify a specific
maritime service in terms of spectrum use;
v. It is the business needs of the owner – not regulatory/licensing controls - which
determine spectrum use, i.e., the radio equipment fitted is the most efficient to fulfil the
user’s requirements;
vi. Other than for distress and safety, compliance with standards is determined by the
service provider;
vii. Notwithstanding they are the smallest numerically, spectrum use by ships in sector 4
(probably) exceeds that of all other sectors combined;
viii. All ships gain economic benefit from radio spectrum;
ix. Ships in sector 4 gain large indirect and direct benefits from radio spectrum;
x. Growth of e-commerce, and the reduced cost of VSAT (C Band) technology, in the
short term, is likely to lead to wider application of high-bandwidth technologies, notably
in sector 3;
xi. In the long term, related to point x, third generation mobile services – if (big IF) they
develop as a global service as projected – should prove to be very attractive to the
maritime industry as it seeks to expand its use of e-commerce;
xii. Globally there are approximately 50,000 ships using spectrum in sectors 2 through 4 of
which about 166 are licensed by the United Kingdom;
xiii. Through licensing, UK authorities can exert little or no influence on maritime service
spectrum use, at least as it relates to mobile.
Issue xxv
As discussed, harmonisation constraints may not be as important as implied in the paper –
no more than they are constraint on the wider development of cell phone and mobile satellite
technology. With the exception of INMARSAT, now a commercial entity, the historic synergy
between marine business and distress and safety communications, which formed the basis
of the original international regulatory regime apropos spectrum use (1906 Convention) is just
that: history.
Any attempt to use negative economic incentives, i.e., in the form higher licence costs or a
stricter regulatory/enforcement regime to control (or preclude in certain cases) spectrum use
(e.g.), will simply be obviated by the ships changing their country of registration.
As and when the technology is established, incentives should be given to encouraging the
adoption of third generation mobile by the maritime service. This would serve to reduce
reliance on present – and possibly unsuitable – spectrum, notably for high-speed satellite
communications, and promote the wider adoption of 3G technology.
On the issue of radar, there are many spectrum efficient technologies, mostly in the defence
field, which could be used to fulfil similar, indeed improved performance over an above the
(magnetron) based systems almost universally applied in land-based marine surveillance.
DTI, as a body, should encourage research and development of these technologies.
-2-
Nevertheless, the established technology (magnetron) is simple, (relatively) cheap to buy and
operate, has unobtrusive antennae and the frequency characteristics are ideally suited to
coastal surveillance given the targets to be identified and the environmental conditions
experienced over the sea.
It should also be remembered that the prime users of radio surveillance technology – ports,
not MCA – operate in an international, competitive market and that there are significant nonradio influences on their choice of radar surveillance systems, e.g., visual amenity (local
planners take exception to radio aerials and the larger the aerial, the more exception they
take).
Which means the installation of spectrum efficient surveillance technology, which tends to
require larger antennae arrays for operation, is unlikely to be developed without direct grant
aid to the users – a carrot, forget the stick - and may be stymied by wider social factors.
General Comment
A point rather overlooked in the consultation paper is the importance of integration in
spectrum use. In other words, how two or more systems, of moderate value in their own right,
can be combined to greatly multiply the economic benefit from the spectrum used.
Notable is the development of satellite navigation technology. Having an accurate measure of
position means nothing other than to specialist users. However, integrate that position with
other technologies, e.g., radiocommunications, databases and GIS, and a vast range of
services become available from in-car navigation through to farm management.
The European market for satellite navigation user equipment between 2005 and 2025 has
been projected to be €88 billion, the market for services €112 billion in the same period
(Source: EU Papers on the Galileo system.). Which means, in the context of this review, the
50 MHz or so of spectrum around 1575 MHz used by the satellite navigation services is,
probably, the most expensive piece of spectrum real estate there is.
Yours Sincerely
Steve Harding BSc (Hons) MSc MRIN
Director
-3-
Data Requirement
Real Time Data Connection To
Terrestrial Network (INTERNET)
Uninterrupted Ship-Shore
Connection
Cost Conscious?
Med
Med
Nil
No
No
Yes
£100s
Yes
Cell Phone
2 Deep Sea, Low Value
Cargo
3 Deep Sea, High Value
Cargo
4 Specialist (Survey etc.)
Passenger
Low
Low
Nil
Med
Low
No
No
Yes
£1000s
No
INMARSAT C/M 110
Low
High
Nil
High
High
Yes
No
No
£10,000s
Yes
INMARSAT B
37
Med
High
V High
High
V High
Yes
Yes
No
£100,000s (Survey)
[£100,000s
(Passenger)]
Yes
C or Ku Band
Mobile (3)
10 Survey 9
Passenger
1 DLTR Statistics
2 Probably far greater but of no direct relevance to this review
3 As reported http://www.installationeurope.com/jan01/f1.html and elsewhere
No. UK Flag Ships(1)
Sector
Notes:
Probable Communication
Technology Applied
Ship-Shore Connection Reliability
Requirement
Low
Marketed Services Separated
From Distress and Safety?
Third Party (Passenger) Use
High
Annual Communications Budget
[Revenue]
Business Use
1 Coastal Including Ferry
and Recreation Craft
Ship Type/Voyage Pattern
Private (Crew) Use
FACTORS INFLUENCING SPECTRUM USE BY THE MARITIME SERVICE
65 Ferry
10,000
Recreation(2)
SECTOR CHARACTERISTICS
1 Coaster or recreation craft. Seldom beyond the range of terrestrial cellular phone networks. Passenger call box facilities provided on
ferries on a cost-recovery basis. Extensive use made of cell-phone for private and business communications. Network choice determined by
price given use pattern. Otherwise only VHF used for distress and safety, and ship-ship applications.
2. Bulk carrier or oil tanker. Small crew, long voyages, homogenous cargo. Little motivation to communicate for business or pleasure. What
communication there is based on basic E-Mail and fax. Required to carry basic INMARSAT equipment to comply with GMDSS, which is
more than adequate to fulfil their communications needs. Equipment, service provider and payment choice determined by price and
potential relationship to equipment supplier. Other GMDSS equipment fitted (HF), with exception of VHF, never used.
3. Container ship. Small crew but short voyages and highly complex loading patterns. Extensive and instantaneous communication required
with specialists ashore to plan cargo, amongst other things. E-commerce the norm. Equipment cost concerns outweighed by commercial
imperative. Full use made of 64 kbps capability of INMARSAT on a ‘dial-up’ basis. All GMDSS equipment gathers dust on the bridge and,
with exception of VHF, never used.
4 Mobile oil drilling platform or large cruise liner. Former cannot operate without continuous, broad-band access to shore-based servers.
Ditto the latter to provide value-added services to passengers, e.g., personal cell phone access, INTERNET, e-mail, television in cabins etc.
Most likely using mega stream, permanently on-line satellite communications equipment operating in C or Ku Band, perhaps several
terminals in service connected to different network providers. GMDSS equipment never used.