Response to the RA's Consultative Document entitled
"The
Future of the Radio Spectrum"
Section 1
Summary
Section 1
- General
- JRC's experience
- Spectrum re-working
- Coping with varying pressure for channels across the spectrum
- The JRC's basis for the prediction of traffic growth
- In conclusion
Section 2: Specific response to each of the Government's proposals with an appropriate explanation {34kB}
1. General
As is pointed out in the Frequency Management of the Radio Spectrum consultative document, the JRC has worked co-operatively with the RA and its predecessors for many years carrying out detailed frequency assignment for its fuel and power industry members. This is an arrangement which both RA and JRC consider has worked well, but it is relevant to the present consultative process to critically review the difficulties which have had to be overcome and what the important issues for the future are considered to be.
2. JRC's experience
It is the general perception of JRC members that they are subject to a near continuous process of change, and uppermost in their minds is the issue of security of tenure. In the 35 years of the JRC's existence there have been two major changes of band to accommodate growth in the PMR traffic, together with changes in fixed link assignments and the introduction of a scanning telemetry service. The first fuel and power PMR services used 100kHz channels, and while the previous and current PMR schemes have used 12.5kHz, the JRC has been one of the organisations, along with the RA, to sponsor research work in Linear Modulation 5kHz systems.
Whereas expansion of service can be possible within a spectrum allocation, this has never occurred in the JRC's PMR bands due to either a lack of available spectrum or external competition for the frequencies in use. Ideally users need the ability to expand capacity and have security of tenure. To achieve this, or at least get close to it, there needs to be longer term planning at all levels, from the system user, the JRC, RA, and international co- ordination. In the most recent PMR change it was the needs of a different service, broadcasting, which resulted in a change from what had been thought to be stable allocations capable of expanding the number of channels available, when justified by traffic, within the band without any complexity. It was a change which reduced the available spectrum at a time when traffic was increasing resulting in a higher cost system. It does raise the question of whether the disturbing party should contribute to the costs of change for the disturbed party in such circumstances.
Overall it is considered that there should be greater recognition of the balance which has to be struck between wanting security of tenure of the spectrum and the effect of ongoing traffic growth in leading to a need to change at some stage.
The experience of managing continuous expansion of radio systems has shown the JRC that a principal issue, in the higher levels of spectrum management, is achieving a balance between the two conflicting needs of obtaining a sensible and economic lifetime from installed systems as against being able to expand system capacity.
3. Spectrum re-working
While in the early stages of radio systems it is possible to open up new spectrum, and generate new channels, subsequent expansion has to be through re-working of the spectrum. This of course presents an additional level of complexity for the overall spectrum manager. In the JRC's submission to the 3rd Spectrum Review Committee it was argued that despite the intensive adoption of measures to improve spectrum efficiency with the current PMR band it could be anticipated that there would be sound justification for requesting fresh spectrum to replace the current system at the turn of the century or in the early years of the next decade, to accommodate greater traffic through the adoption of even more efficient modulation and re-use techniques.
The JRC does not believe that it will be unique in experiencing the need to satisfy traffic expansion, so that the issue of long term planning of spectrum reworking in a phased way need to become a part of the overall spectrum managers strategy. The techniques for coping with re-working of the spectrum need to worked out in the immediate future since there will need to be some percentage of the overall spectrum kept fallow to accommodate a process of change. To date there has been a tendency towards total allocation of the spectrum as if once fixed, applications, technology and demand will stay frozen.
A strategy for re-working of spectrum needs to be developed which will provide a long term planning mechanism which will allow re- working of spectrum to be applied according to the demand which actually materialises. This strategy needs to be sufficiently flexible to allow effective usage of the spectrum whether spectrum demand continues to grow at its present rate or is completely static. The key to this is thought to be ensuring that there is spectrum kept available for migrating systems from early, low spectrum efficiency system to higher efficiency systems.
It will be necessary to consider how such a policy of increasing spectrum efficiency would affect various classes of users, particularly the extremes of high growth and declining use. The user with high traffic growth will be looking for ways to increase the capacity of their system at minimum cost, which will usually imply the need to gain full economic life from already installed equipment. The first preference would be to be able to expand the installed system, generally easiest with more channels adjacent to the existing allocation. The next best is probably to increase infrastructure investment and greater re-use of the available channels. If new technology is to be used to achieve the necessary increase in capacity then it will be generally preferable to allow a substantial overlap in time of old and new systems. In the case of the static or declining user, they would no doubt see no need for change and would be content with their relatively low spectrum usage efficiency, yet they should be subject to the same timescale for change as the user with growth.
In order to achieve long term planning, in the ten to fifteen year period, it will be necessary for growth in demand for capacity to be projected into those timescales. Clearly such estimates would be speculative, but subject to on-going review. Steps to implement change would be dependant on evidence that growth was in line with earlier predictions and detail of the traffic anticipated. (or channel quality in the case of broadcast). The long term forecast would be used only to establish that the mechanisms for re-working of spectrum could cope with that possible demand. The provisional assignment of spectrum to particular purposes would be a decision in the intermediate range, perhaps five to seven years, where the capacity predictions are more realistic and the potential of the technology to provide the type of channel in a suitably spectrum efficient way can be set as a target. Research and development of new systems takes several years, so that firm decisions on new allocations probably need a minimum of three years prior to introduction.
4. Coping with varying pressure for channels across the spectrum
It is suggested that RA develop a policy for introducing more spectrum efficient technology in the band(s) subject to greatest pressure. This is an approach which could give operators and users a choice between a high spectrum efficiency solution in prime spectrum or a lower cost solution in less popular bands. This is described in more detail in the answer to Question 11. It is argued that a policy, arrived at by consensus, which identified the band(s) in greatest demand would also attract the necessary investment to ensure that equipment embodying the necessary technology became available.
As an organisation which has been concerned with ways of expanding the capacity of the spectrum available to it, the JRC is also aware of the costs which can be incurred by working towards higher spectral efficiency rather than just using more channels to expand the capacity of a simple configuration. While the previous paragraph was concerned with development primarily within a class of usage, i.e. mobile, it is more difficult to ensure balance between widely different usages such as broadcasting, defence and public services. It is thus considered that the RA, and ultimately Parliament, should be the arbiter to ensure an equitable policy of moving towards higher spectrum efficiency by the all users of the radio spectrum.
The JRC believes that there will continue to be expansion of existing services and demand for new services, both within its own domain and in society at large, and that the complex issue of opening up the remaining new spectrum and the re-working of old spectrum, the balancing of widely differing requirements, the transitions between systems, the need for the development and implementation of standards, and the need for close co-ordination within Europe, all lead to a greater role for RA. Because this high level spectrum management role would be to the eventual benefit of all users, it would be appropriate for this extra work to be financed out of licence revenue or spectrum fees.
5. The JRC's basis for the prediction of traffic growth
The JRC's views of the likely growth in traffic demand is based on the understanding within its member organisations of the changes in organisational needs, the potential of information systems in the field and the technical potential of radio to provide a wider range of services than simple voice communications. As enablers of radio communications to the Gas, Coal and Electricity industries we are vitally concerned in continuing to provide a service which is of central importance to the economy and on which, in critical situations, life can depend. We would look forward to the JRC taking on the role of an SMO to manage the PMR, Scanning Telemetry and remote meter reading services of its member industries. We need to be able to support the industries in their quest for more effective work practices through improved communications in the future, and hence to be able to expand capacity. We don't expect to be alone in wishing for expanded capacity, and want to see mechanisms developed which will ensure economic and efficient use of spectrum for all with a justifiable need. It is in this context that RA can play a vital role in looking across the whole range of radio users, present and future, to map out the strategies which would be needed if these traffic estimates become firmer and the potential users come forward with sound basis for their requests for capacity expansion.
6. In conclusion
The JRC considers that there will be continued pressure on the spectrum and that in order to ensure that there is equitable access for all with a reasonable claim to the use of radio, that there needs to be greater effort put into the long term planning and co- ordination of the spectrum. This includes encouraging the development of spectrum efficient technologies and the methods of handling a more dynamic spectrum allocation strategy, albeit on a long time scale. While these are roles for RA, the more detailed and day to day aspects of spectrum management appear appropriate for delegation to spectrum management organisations.
The JRC would seek to administer its existing allocations and to ensure that the JRC members considerable concern with the issue of security of tenure are addressed. These concerns are based on requiring their radio services to maintain essential services in emergency situations.
Administrative pricing, based on bandwidth usage, to reflect spectrum efficiency, and at a level to finance the planning needed to achieve ongoing availability of spectrum, is the preferred way forward. This would achieve the greatest availability of spectrum and hence create the capacity needed for existing services to expand and new services to be created.
There are many issues of detail which the JRC would like to believe that its experience could contribute to and would like to offer its participation in any further discussions with RA/DTI.
