Responses to the consultation document - Consideration of Possible Frequency Plans for the 3G Expansion Spectrum, 2500 to 2690 MHz

Question 1

Should the 2500 to 2520 MHz and 2670 to 2690 MHz sub-bands be designated for the satellite or terrestrial component of IMT-2000 within Europe?

The consultation produced polarised responses to this question. The satellite community arguing for satellite use of the sub-bands and the terrestrial community for terrestrial use.

Ofcom recognises that co-existence of terrestrial and satellite use in Europe is technically not feasible and that the weight of opinion within Europe for terrestrial use makes satellite use in the UK untenable. We have therefore agreed to support the designation of the sub-bands for terrestrial use.

Question 2

How much emphasis should Europe place on frequency arrangements that could be partially implemented on a global basis?

Responses indicated that harmonisation within Europe should be the top priority, taking into account European interests. Frequency arrangements that could be partially implemented on a global basis are desirable but not essential.

Ofcom’s view is that priority should be given to spectrum arrangements that support UK needs.

Question 3

Is it practical for the deployment in a particular country to differ from that of its neighbours?

The majority of respondents indicated that differing deployments within different administrations in Europe is, while possible, neither optimal, nor efficient, nor desirable. Respondents would generally prefer harmonised allocation across Europe in order to achieve a number of key benefits:

• Seamless international roaming
• Increased equipment choice (both terminals and infrastructure)
• Manufacturing economies of scale (both terminals and infrastructure)
• Reduced cost of equipment (both terminals and infrastructure)
• Early equipment and terminal availability
• Reduced terminal complexity
• Reduced border co-ordination complexity
• Seamless cross border handover

Ofcom is facilitating the development of a common approach to the use of the 2.6 GHz band within Europe and will aim to ensure that pan-European services are not impeded. However within this context we will seek maximum flexibility in the spectrum arrangements for the UK.

Question 4

What could the spectrum potentially be used for in terms of applications, target markets etc?

Respondents indicated that the spectrum will be used for additional capacity by incumbent operators, mainly for use in the areas of highest traffic demand. New entrants will use the spectrum for the provision of mobile voice and data rate services.

Ofcom is of the view that the market should be able to decide the optimal use of the spectrum.

Question 5

What are the anticipated traffic characteristics/assumptions that should be made on aspects such as asymmetry characteristics and whether more spectrum is required in the ‘downlink’ direction than in the ‘uplink’ direction?

Further experience of UMTS services and data applications is required to predict future traffic characteristics. However it should be noted that the UMTS Forum is currently estimating traffic asymmetry to be between 2:1 and 3:1 between downlink and uplink. It should be noted that technical developments such as High Speed Downlink Packet Access (HSDPA) will allow average asymmetric traffic of the order of 2:1 between downlink and uplink to be carried over symmetrical frequency allocations.

Ofcom believes that asymmetry within offered traffic is best dealt with by maintaining flexibility in the spectrum arrangements and allowing the market to respond to any asymmetric spectrum requirements.

Question 6

Should the core 3G spectrum – both the licensed and the unlicensed (self-provided) bands – be considered for potential pairings with the 2500 to 2690 MHz band, or should they be treated separately?

The general view was that the 2500 to 2690 MHz band should be considered separately from the 2 GHz core bands. There should be no mandated pairing between 2 GHz core bands and the 2.6 GHz bands. However this should not exclude the allocation of FDD downlink external spectrum within the 2.6 GHz band, and it should be permitted for an operator to optionally use any allocation of FDD downlink external with any available uplink band.

Ofcom shares the general view indicated above.

Question 7

Do the boundaries between the different ‘elements’ within the expansion spectrum need to be fixed, apart from the position of the minimum duplex separation band and the duplex direction? For example, does the boundary between FDD and TDD/downlink-only need to be fixed?

The general view was that it is necessary to fix the lower and upper endpoint of both the FDD uplink and FDD downlink allocations within this band in order to specify the terminal filter design. Within the FDD downlink, flexibility can be retained in terms of how much of this is for internal pairing and how much is for external pairing. Fixing the endpoints of the FDD uplink and downlink will naturally also fix the allocation for TDD.

Ofcom recognises that certain elements of these arrangements, such as internally paired FDD spectrum, may need to be fixed to ensure that standardisation and equipment development can be ready in time for deployment around 2008 but in general we wish to maintain as much flexibility in the arrangements as possible.

Question 8

Will all terminals need to support all scenarios for roaming (i.e. FDD, TDD and downlink only) including support for the core 3G spectrum?

The general view was that it should be a market based decision on which frequency bands and modes the equipment supports – between the manufacturers and operators. This is the situation that exists today and there is no reason for it to change.

Ofcom shares the view indicated above.

Question 9

What are your views on the timing of the mandate deliverables, particularly for the final CEPT Report and the ECC Decision?

There were mixed views on the timing of the mandate deliverables with some respondents arguing for a delay of two years and others for no delay.

Ofcom supports the overall deliverable timetable of Mandate 5 but we believe that some elements of the spectrum arrangements, particularly for the unpaired spectrum, should be delayed beyond the end of Mandate 5. Indeed, it is desirable for as many decisions as possible on use of the band be left to the market during the initial award process and/or subsequent trading regime.

What frequency arrangements would you like to see in the 2500 to 2690 MHz band? Alternatively, what options should be retained for consideration and on what basis?

Most respondents had some preference for the arrangements shown below, while noting that blocks B or C might be reduced to zero width should assumptions on traffic asymmetry change, or there prove to be no viable deployment of TDD technologies.

A reasonable minimum value for the separation gap between FDD uplink internal and FDD downlink internal in the 2.5GHz band is 30MHz

It remains too soon to determine how much, if any, spectrum within the band should be allocated to each of internally paired FDD, externally paired FDD downlink and TDD use.

Respondents would strongly support any Ofcom intervention in the discussion of the band plan that sought to maintain flexibility and to counsel against decisions ahead of real market experience.

However, some respondents indicated that there are a number of points on which it is both desirable and possible to take a position now. These are:

• the total amount of spectrum to be made available to mobile satellite services in the band;
• the size of any required duplex separation gap; and
• the preferred "scenario" to support flexibility in the future use of the band.

Ofcom seeks maximum flexibility in the frequency arrangements developed under Mandate 5. We recognise that certain elements of these arrangements, such as internally paired FDD spectrum, may need to be fixed to ensure that standardisation and equipment development can be ready in time for deployment around 2008 but in general we wish to maintain as much flexibility in the arrangements as possible.