Support to Ofcom's review of fees for fixed links and permanent earth stations

JRC agrees that any band that becomes harmonised for IMT use will become highly valuable to mobile operators.

JRC advises that Utility Operations anticipate increasing its use of spectrum in order to meet its requirement to roll-out smart grid systems in pursuance of government energy policy objectives. It is expected that, whilst the current 1.4 GHz requirement may be relatively stable, a significant number of additional 1.4 GHz links may be required for power line protection as public operators reduce their commitment to provision of low latency, guaranteed routing and power resilience in their product portfolio.

JRC notes that the recent decision by Ofcom to remove access to the lower 6 MHz of the fixed links 1.4 GHz band, in favour of adjacent Supplementary Down Link (SDL) systems reduces the longer term capacity of the band by 25% as no new assignments can be made in the guard band, and where existing assignments are changed for any reasons, they will be re-allocated within the remaining 18 MHz only.

JRC suggests that, whilst the end-to-end latency may prove too long for some systems, the roll-out of Smart Grids may require access to satellite spectrum.

Yes, capping the LCA values is likely to provide a more conservative estimate than the uncapped values.

JRC is concerned with Plum's opinion that 'We have applied this cap to the LCA values on the grounds that the value of spectrum to mobile services in any band is likely to be significantly more than that for fixed services'. Spectrum is only of greater value to mobile services when its use can be harmonised internationally and released in relatively large blocks. Conversely, where use of spectrum is not harmonised internationally, its value is greatly diminished. VHF Band III is a prime example of spectrum made available for mobile use in the UK but remained largely unused as it is not harmonised internationally. In the case of the spectrum in 1452-1492 MHz which has remained unused for a long period of time in the UK, it has only recently become of significant economic value once harmonised for SDL on a European basis.

JRC recommends that, inter alia, the socio-economic aspect should also be taken into consideration when predicting the value of spectrum.

JRC has no comments.

JRC advises that Plum is incorrect in its assumption that 'The option of more efficient technology (i.e. higher modulation) was also considered but because equipment costs do not vary by modulation i.e. the user will choose the most efficient modulation scheme available'. This is because Utility Operations systems are typically designed to deliver guaranteed availability, redundancy and resilience: higher data rates beyond a guaranteed minimum are not always required. This can result in a lower modulation scheme being used to enhance availability and reduce latency rather than a higher modulation scheme to increase data rate.

JRC has no comments.

JRC notes that the proposed fees with the Path Length Factors removed, and the proposed Band Factors added, may be (i.e. proposed value / current value):

• 1.35 to 3.60 GHz = 4.0 x current fee (4.0 / 1.0);
• 3.6 to 4.2 GHz = 3.0 x current fee (3.0 / 1.0);
• 5.0 to 10.0 GHz ~ 2.4 x current fee (1.8 / 0.74);
• 10.0 to 16.0 GHz ~ 1.4 x current fee (1.0 / 0.74);
• 16.0 to 20.0 GHz ~ 2.3 x current fee (0.7 / 0.3);
• 20.0 to 24.0 GHz ~ 1.3 x current fee (0.4 / 0.3);
• 24.0 to 40.0 GHz ~ 1.2 x current fee (0.3 / 0.26); and
• 40.0 to 57.0 GHz ~ 1.2 x current fee (0.2 / 0.17).

JRC would like Ofcom tol consider a location factor of 0.25 for 1.4 GHz links that are located in rural areas, e.g. where many Utility Operations links are likely to be operating.

JRC agrees with up to 90% reduced fees in areas with low population, and / or in remote areas, because this is where many critical national infrastructure (CNI) links often need to operate.

JRC notes that the current fixed links bandwidth factor¹ 'Minimum = 1 MHz but any actual value above this with an observed maximum of 135 MHz'.

JRC suggests that, to encourage the use of low bandwidth systems, e.g. 2048 kbit/s in 500 kHz (and perhaps 64 kbit/s in 25 kHz for some Smart Grid links) as used by Utility Operations systems, the bandwidth modifier should be amended.

¹ http://licensing.ofcom.org.uk/binaries/spectrum/fixed-terrestrial-links/guidance-for-licensees/FeeCalcDoc.pdf (Section 3)

JRC suggests that, if introduced, any incentive should be sufficient to cover the additional cost of using high performance antennas over their operational period, including site rental costs.

It should also be observed that the use of larger antennas is not simply the cost of the antenna, or the additional space required on a tower to accommodate the larger antenna, but may have an impact on the wind loading on a structure. In addition, higher performance antennas will usually have a narrower beamwidth requiring more precise alignment and possibly a stiffer structure to support it, which may not be achievable on existing towers.

JRC has no comments.

JRC agrees with the proposal for a Location factor. Its inclusion could result in up to 90% reduced fees in areas with low population and / or in remote areas, i.e. where many critical national infrastructure (CNI) links often need to operate.

JRC agrees with the proposal for a Location factor. Its inclusion could result in up to 90% reduced fees in areas with low population and / or in remote areas, i.e. where many critical national infrastructure (CNI) links often need to operate.

JRC highlights that Business Radio licences 50 km x 50 km squares to enable the licensee to install multiple radio stations within the square, typically, without the need to co-ordinate these with radio stations within the adjacent 50 km x 50 km squares. This is not the same use as what is being proposed for fixed links.

JRC therefore suggests that the fixed links squares should be 25 km x 25 km. This will enable a higher granularity when identifying which squares are considered higher value areas and which are in low population / remote areas, e.g. where mobile is not an alternative use.

For regulated industries such as the utilities where price review periods may be up to seven years, it is important that any price increases in spectrum fees are introduced on a time scale commensurate with the regulatory review cycles in these industries.