Ofcom Consultation – Enabling mmWave Spectrum for new uses
Executive Summary
JRC and its Members welcome the opportunity to respond to this consultation and as critical system operators JRC Members depend on access to spectrum and as such are concerned with Ofcom’s proposals to displace fixed links from the 26GHz band. The focus of JRC’s response is summarised below;
- In light of Ofcom’s approach to clear fixed links from the High-Density Areas (HDA) whilst allowing them to remain in the non-High-Density Areas and the intention to establish a technical co-existence regime to afford appropriate protection of fixed links in non-HDAs then we encourage Ofcom to revisit its decision to block changes to existing links and the deployment of new fixed links in non-HDAs;
- The Costing Model does not fully reflect the actual costs for the systems deployed by JRC’s Members and we encourage Ofcom to revisit the underlying cost components and the scenario that should be applied;
- With regard to the establishment of a co-existence regime with fixed links JRC and its Members are keen to work with Ofcom to ensure that the technical coexistence arrangements established afford appropriate protection particularly in light of the suggestion to revisit the decision to block modifications to and new fixed links in the band.
To put the impact of these proposed changes in context, we encourage Ofcom to recognise the long term spectrum access needs of other platforms / systems, e.g. Energy Network Operators, PMSE, etc.. To this end we are very supportive of the work underway in Ofcom’s ‘Spectrum for Utilities’ study and as such our perspective is aligned to the long-term imperative of additional spectrum access for the Energy Network Operators to facilitate Government policy, i.e. the ‘Net Zero’ transition.
Background
Joint Radio Company Ltd (JRC) 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 manages blocks of VHF and UHF spectrum for Private Business Radio applications, telemetry & telecontrol services and network operations. JRC created and manages a national cellular plan for co-ordinating frequency assignments for several large radio networks in the UK.
The VHF and UHF frequency allocations managed by JRC support telecommunications networks to keep the electricity and gas industries in touch with their field engineers. These networks provide comprehensive geographical coverage to support installation, maintenance and repair of plant in all weather conditions on 24 hour/365 days per year basis.
JRC’s Scanning Telemetry Service is used by radio based Supervisory Control And Data Acquisition (SCADA) networks which control and monitor safety critical gas and electricity industry plant and equipment throughout the country. These networks provide resilient and reliable communications at all times to unmanned sites and plant in remote locations to maintain the integrity of the UK’s energy generation, transmission and distribution.
JRC supports the European Utility Telecommunications Council’s Radio Spectrum Group, and participates in other global utility telecom organisations. JRC participates in European Telecommunications Standards Institute (ETSI) working groups developing new radio standards, and European telecommunications regulatory groups and workshops.
JRC also manages microwave fixed link and satellite licences on behalf of the utility sector.
JRC works with the Energy Networks Association’s Future Energy Networks Groups assessing ICT implications of Smart Networks, Smart Grids & Smart Meters and is an acknowledged knowledge source for cyber-security in respect of radio networks.
JRC’s Detailed Response to Questions
Confidential? No.
JRC’s Members depend on fixed links in the 26GHz band for the operational integrity of their networks and fundamental to the safe and secure supply of Electricity to UK consumers. Ofcom in seeking to enable access to the band for 5G services has sterilised the band for fixed links and is proposing to displace fixed links in and adjacent to High Density Areas. We encourage Ofcom to reconsider the importance of continued access to the band for fixed links, subject to establishing an appropriate co-existence regime to address the ‘mission critical’ operational needs of the Energy Network Operators, particularly in those non-HDA areas where demand for 5G service deployment is likely to be low and fixed links will be a relevant alternative use. Furthermore, the approach advised in the consultation is to enable co-existence between fixed links and 5G services in non-HDA areas if this is the intention then to maximise value Ofcom should seek to enable further fixed link access to the band in non HDA areas and modifications to links in non-HDA subject to confirmation of the co-existence regime which in the case of Energy Network Operators will need to assure the critical function that these links undertake. The above approach would support the policy objective of achieving efficient allocation of spectrum whilst also ensuring timely availability of spectrum. Independent of this change to Ofcom’s proposals there is a likelihood that Ofcom will fail to deliver on its regulatory obligation because of the sterilisation of the band for the fixed link service in areas of the UK where Ofcom acknowledge that demand for 5G service deployment is likely to be easily served and relatively low.
Confidential? No.
For the 26GHz band it would appear to be disproportionate to block further fixed links deployments and changes to existing licensed links particularly for the non-HDA areas and we encourage Ofcom to move quickly to develop the co-existence regime that has been outlined to ensure that appropriate protection is afforded to existing fixed links operated by JRC Members for both the HDA and non-HDA areas assure the operational integrity of critical national infrastructure.
Confidential? No.
Yes, in principle but as has been noted in response to Q1 and Q2 above there appears a risk of regulatory failure with the whole of the country being sterilised to new fixed links and changes to existing fixed links. Ofcom’s approach to designate HDA and non-HDA areas is predicated on their expectation that it will be practical to continue to operate fixed links in the non-HDA areas. Furthermore, with the expectation that there will be relatively limited demand for 5G services in rural locations we would encourage Ofcom to revisit its decision to block new links and modifications to existing links in low density areas and open these areas for further fixed links. Such a modification is consistent with the approach being considered in Question 11 where Ofcom are contemplating enabling future satellite earth stations access to low density areas.
Confidential? No.
No Comment.
Confidential? No.
No comment.
Confidential? No.
No Comment.
Confidential? No.
No, as it has the potential to overlook discrete locations such as hospitals and universities. There is also the potential for temporary high-profile, high-density deployments e.g. Reading & Leeds Festivals, F1 (Silverstone) and major golf competitions that fall outside the HDAs i.e. low density areas where 5G may be actively deployed on a time limited basis. In these scenarios we are keen to work with Ofcom to ensure that the incumbent fixed links which are critical to the operational integrity of the Energy Networks will be afforded appropriate protection.
Confidential? No.
No, we believe that the relevant number of HDAs should be informed by the Mobile Network Operators’ expectations for spectrum demand. However, independent of appropriate guidance from the market, i.e. the MNOs, and in recognition of the potential uncertainty of ongoing reliability with the potential risk of harm and cost of disruption to UK Energy Consumers we propose that the level be set at 80. In addition, we encourage Ofcom to advise its approach to addressing links that are close to the HDA but not designated as impacted by the HDA which are subsequently compromised.
Confidential? No.
No Comment.
Confidential? No.
JRC notes Ofcom’s approach to the costing analysis is aligned to the scale economies that are available to Mobile Network Operators (MNOs) when purchasing this type of equipment. As a result the cost base used for the analysis is set too low to reflect the actual costs incurred by other operators that do not have the benefit of such scale economies. In addition to the higher hardware and installation costs incurred by non-MNO fixed link operators it is also important to note that the configuration of the fixed link deployment is different in the case of critical infrastructure system operation, e.g. Energy Network Operation, with additional redundancy and the integration of back-up power necessary which adds additional costs to the system which is not considered in Ofcom’s analysis.
In terms of the four scenarios developed by Ofcom and in light of the aspects noted above we believe that the scenario ‘Higher ongoing costs, 15 year useful equipment lifetime’ better reflects the reality from an Energy Network Operators. Furthermore, in the act of trying to estimate the costs of the revocation process it is inevitable that there will be cost inconsistencies across users. Perhaps the approach that Ofcom could adopt is to set a budget for the process in line with ‘Higher ongoing costs, 15 years useful equipment lifetime’ scenario and then compensate individual operators based on the actual costs incurred.
Confidential? Yes.
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Confidential? Yes.
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Confidential? No.
No Comment.
Confidential? No.
No specific comments other than noting the importance of the technical licence conditions being designed to afford appropriate protection to existing and potentially new fixed links in non-HDA areas subject to Ofcom changing its approach to fixed links to avoid a scenario where Ofcom could be perceived to fail in delivering on its obligations as a spectrum regulator.
Confidential? No.
Based on the limited information provided it is difficult to respond, please refer to our response to Question 11, we look forward to the follow-on consultations in which Ofcom will set-out greater detail on the license conditions and we encourage Ofcom to ensure that they take into account the potential for the licensing of fixed links to be re-established in non-HDA areas whilst ensuring that appropriate protection is afforded to existing fixed links in both HDA and non-HDA areas.
Confidential? No.
No Comment.
Confidential? No.
No Comment.
Confidential? No.
No Comment.