JRC Response to the DCMS Review of the Electronic Communications Regulatory Framework

Response

• JRC welcomes the opportunity to respond to this Review.
• JRC supports ‘deployment of communication networks that meet the needs of users over the next decade enabling competitiveness and economic growth and delivering social benefits. The effectiveness of networks needs to be judged by the quality of experience enjoyed, or suffered, by the user, be they an individual consumer or[a] business’.
  • Almost every service or product offered to the UK’s citizens and consumers relies directly or indirectly on the stable provision of electricity and / or gas (gas is used to generate typically 50%¹ of the UK’s electricity) by the UK’s Critical Infrastructure Utility Operations. This will continue to require the increasing deployment of resilient private communication networks that will ultimately enable the suppliers to meetof the needs of citizensand consumers over the next decade.
• JRC agrees that ‘every citizen [is offered] access to an acceptable level of connectivity’.
  • Rather than simply offer more of the same, this should ensure that the currently available public mobile spectrum will be used more efficiently throughout a 24-hour period. This is preferable to simply increasing the amount of available public mobile radio spectrum, which denies its use by other users, and this resulting in it being unused efficiently except during the busiest hour(s) in a day. 
• JRC agrees with ‘the principle of subsidiarity and [to] ensure Member States’ competency’.
  • In particular, Ofcom should continue to manage all international co-ordination requirements relating to the UK’s radio systems rather than parts of this process being handed over to the EC.

¹ Source: Grid Carbon  

JRC would like to take this opportunity to highlight the following:

• The stable supply of electricity relies increasingly on the systems that control the electricity grid. This includes resilient private wireless systemssuch as the 9.6 kbit/s in 12.5 kHz true² narrow band channelsusedfor the UK-wide supervision and data control systems (SCADA).
  • Please note that whilst these systems may be included under the general heading of Machine to Machine (M2M), they are more appropriately referred to as Resilient M2M (RM2M). Thereby highlighting that typical public mobile based M2M solutions are unlikely to be suitable. (Especially by their base stations not having up to 96-hour power backup.)
  • Further, SCADA / RM2M systems operate to the remotest rural parts of the UK. This is far beyond the economic coverage areas of public mobile systems.
• The 2 x 1 MHz of 400MHz UHF Band spectrum that was allocatedby Ofcom’s predecessor in 1985 forcritical infrastructure utility operationsis just enough spectrum to control the existing SCADA grid systems.
  • It should be noted that the UK’s Critical Infrastructure Utility Operations have more than 30years’experience ofdesigning, installing, operating, and maintaining their own resilient private machine to machine (RM2M) systemsusing proven long-term technologiesrather than technologies, such as public mobile GSM, that have a limited lifetime.
• The ever increasing roll-out of distributed generation is putting an increasing strain on keeping the existing grid stable. The critical infrastructure utilities therefore need to move to Smart Grid systems.
• The move to Smart Grids will require a significant increase in data rates, e.g. from 9.6 kbit/s to 64 / 100 kbit/s, and increased spectrum access. An increase to2 x 3 MHz of 400 MHz Band private spectrum is predicted.
  • It should be noted that the average future private spectrum requirements for Critical Infrastructure Utility Operations Networks, including Smart Grids, is likely to be equivalent to ~1.5 percent of the 1,200 MHz of spectrum identified for public mobile / IMT systems.
  • It is hoped that this ~1.5% of alternative spectrum will not be seen as an excessive resource to keep the UK’s lights on.

² Narrow band:12.5 / 25 kHz channels. (Not to be confused with 200 kHz, so called, narrow band LTE public mobile systems.)  

Joint Radio Company (JRC) 

JRC Ltd is a wholly owned joint venture between the UK electricity and gas industries specifically created to manage the radio spectrum allocations for these industries used to support operational, safety and emergency communications. JRC also represents gas and electricity interests to government on radio issues.