Joint Radio Company Limited

JRC Response to the ERO's Detailed Spectrum Investigation Phase II Report

Introduction

The Joint Radio Committee of the Fuel and Power Industries (JRC) had existed for some 30 years, principally serving the interests of the coal, gas and electricity industries. It protected the member companies' operational and emergency radio communications interests via committee structures and ensured the best allocation of radio spectrum. Whilst the JRC had performed its role well, modern business and the changing regulatory scene require an organisation that is legally constituted. JRCL was formed in November 1994 by British Gas plc and the Electricity Association (On behalf of its members, the UK electricity companies). JRCL members operate a variety of communications infrastructure on a regional and national basis; these include trunk microwave, radio based telemetry and telecontrol, as well as professional mobile radio services. The latter two services both VHF and UHF spectrum. All the services are essential to the safe operation and control of the regional and national energy supply networks) particularly in times of stress, such as abnormal weather conditions or other emergencies, as well as providing for the member's business needs.

The Response

This JRCL response to the DSI Phase II document is being made in two parts. The first makes direct comment on some of the Recommendations and their effect on the Utilities represented by JRCL, and the second provided a JRCL view on the strategy for growth and change in mobile radio systems.

1: Comment on DSI Phase II Recommendations

General

REC2

The criteria in paragraph 2a should not be solely based on economic factors and should also consider the existing use of candidate spectrum and its suitability for the future needs of the current user particularly where technological developments can increase spectrum efficiency and meet the medium term needs of the Users.

It is difficult to imagine an agreement being reached on the composition of a standard formula to compensate users of radio systems when they are being asked to relocate to new spectrum. Such an arrangement may ultimately provide the only solution> although a resolution to the issues surrounding Security of Tenure i.e., operators and users moving to new spectrum being given fixed terms of tenure, would enable more effective medium and long term planning.

REC4

It is accepted that the radio spectrum will continue to be managed by the National Agencies, however, the JRCL support the delegation of responsibility for planning and frequency management to specialised groups or organisations. The JRCL has placed great emphasis on efficient use of spectrum and is able to demonstrate the benefits of good frequency planning. However, further developments and new techniques will only be pursued by organisations like JRCL as a result of increased demand from users and, in funding such development member Companies must be assured that they will be allowed to realise the full benefits.

Mobile Service

REC 18

The principle of spectrum harmonisation is to be encouraged particularly within Professional Mobile Radio. However, harmonisation at a European level will mean it is necessary for Professional Users to co-ordinate lobbying at a European level and it may lead to the requirement for a European co-ordinating body for Professional Mobile Radio users, similar to JRCL.

REC 20

There may well be a clear demand for civil commercial TETRA spectrum in the sub-bands 410-430 and 450-470 MHz. However, the JRCL would reinforce the need to provide adequate protection for the Scanning Telemetry Services operated by each of the major Utilities the Gas, Electricity, and Water Industries. These systems are essential for the safe, reliable operation of major items of plant in these Industries.

Fixed Service

REC 36

The JRCL wish to restate that there is a prime need to protect Scanning Telemetry and there is no case for this service becoming a secondary user. The scanning telemetry systems are based on mobile technology, the outstation unit is effectively a UHF mobile and the scanning station a UHF duplex base station, and the engineering of the radio propagation paths may well be subject to obstructions in a similar manner to mobile services. We are very concerned that rationalisation of spectrum at European level may threaten these services.

These systems are used for the control of substations, valves and flow monitoring points and the imposition of a move to higher frequencies would create severe problems and in controlling these assets to provide safely essential services within the UK.

Mobile Satellite Services

REC 38

The pressure being exerted at a European and World level for the allocations of spectrum at 148-150.5 MHz for 'little LEOs' is of major concern to the JRCL. In preparation for WARC 95, the Radiocommunications Agency and the JRCL have spent much time and effort concluding a satisfactory arrangement for coexistence between 'little LEOs' and existing JRCL Band services operating in this spectrum. This recommendation could cut across these arrangements. It is essential that in determining the "policies and priorities" for 'little LEOs' and existing services, there is the widest possible consultation to include the users of existing spectrum.

2: Accommodation of Growth and Change in Radio Systems

It is likely that the present rules of innovation and demand for radio based service will continue to grow, with increasing demands on the spectrum on a global scale. It has been possible in the past to look to 'new frontiers' in the form of ever increasing frequency to accommodate new services. While the higher frequencies have properties which have matched the needs of the new services i.e., the high UHF frequencies for micro-cellular, there tends to be parts of the spectrum which best suit certain applications, and there can be expected to be greater pressure on those parts of the spectrum. As a result of the increasing demand greater emphasis will be needed on the redevelopment of bands to accommodate services which use the spectrum more efficiently (in terms of E/km2/Hz and some data equivalent). To accommodate growth in this way will require a higher degree of planning than has been practiced before and will need the establishment of criteria to ensure a degree of fairness in the treatment of those who wish to make use of radio spectrum.

It is suggested that there are four main elements required in such a strategy:

i. An overall plan for rationalisation of spectrum planning towards a cycle of re-development to accommodate an on-going increase in the use of radio spectrum. The concept of permanent allocation is not compatible with the process of improving spectrum utilisation efficiency and hence accommodating growth in services and traffic. While today's arguments are for the provision of spectrum for, in the case of PMR, digital trunked systems, TETRA, there is a strong possibility that in another 10 years the range of services demanded by PMR users will have expanded and the technology available to support them in a more spectrally efficient way will have been developed, so that there will be a need for spectrum for yet another new system. Since 10 years is along time in terms of radio technology and the development of new systems, yet is short in terms of spectrum planning, the spectrum planning process needs to allow for the changing user demand and technological solutions.

1. An overall plan for rationalisation of spectrum planning towards a cycle of re-development to accommodate an on-going increase in the use of radio spectrum. The concept of permanent allocation is not compatible with the process of improving spectrum utilisation efficiency and hence accommodating growth in services and traffic. While today's arguments are for the provision of spectrum for, in the case of PMR, digital trunked systems, TETRA, there is a strong possibility that in another 10 years the range of services demanded by PMR users will have expanded and the technology available to support them in a more spectrally efficient way will have been developed, so that there will be a need for spectrum for yet another new system. Since 10 years is along time in terms of radio technology and the development of new systems, yet is short in terms of spectrum planning, the spectrum planning process needs to allow for the changing user demand and technological solutions.
   
   
2. A range of cost mechanisms within the licensing fee structure which reflect the user of the spectrum's readiness to adopt more efficient techniques. i.e., a user who is prepared to adopt more efficient technology early would pay a low or zero licence fee, whilst those who hold on to spectrum when it was needed for a more efficient service would be subject to a licence fee which increased as the inefficient use was perpetuated. This approach is put forward in the context of overall license fees reflecting the costs of spectrum and administration
   
   
3. To attempt to maintain an equal standard between widely different usage's i.e., broadcasting, defence, PAMR, PMR, Cellular. It is unreasonable to expect one sector of users to incur significant costs in changing to more efficient techniques while another user remains static and holds onto old technology
   
   
4. This process of planned change has to take account the large sums invested by companies and the individuals depending on the service, so that adequate planning times are used. Too short and return on investment is not realised, too long and progress and growth is inhibited.

It is important to recognise the need for spectrum planning as a cyclic activity, rather than as an ultimate solution. Continuous change requires that there is always a part of the spectrum where services are being phased out before a new technique is introduced, and hence that there is a percentage of each band which is following at some stage to accommodate the ongoing process of change.