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APWPT at United Kingdom, (April 2015)

Response from APWPT to Ofcom Consultation on MCWSDs

APWPT expects considerable problems if MCWSD (white space devices in the UHF TV band) are taken into operation. Studies show that PMSE are not protected sufficiently:
Response from APWPT to Ofcom [187 KB]

Find the public consultation information below.

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United Kingdom, (February 2015)

Manually configurable white space devices - MCWSDs

OFCOM introduces the document for public consultation with this lines:

"
This document sets out Ofcom’s consultation proposals for authorising certain types of white space devices (WSD) on a licensed basis.

‘White spaces’ are gaps in the radio spectrum in frequency bands, which can be used to offer wireless applications. These can bring benefits to citizens and consumers. While we expect most WSDs will operate on a licence exempt basis in the future, many do not currently meet our requirements for licence exemption and require manual configuration by the user.

Ofcom is therefore considering whether these manually configured devices should be licensed on a transitional basis, while equipment is developed that meets our licence exemption regulations. We would propose to review whether authorisation is still required after around three years.

This follows a recently published statement allowing white spaces devices that are able to operate automatically and without any manual configuration to operate in the UHF TV band on a licence exempt basis.

The consultation closes on 10 April 2015.
"

Get further information here

See also:

* OFCOM: Implementing TV White Spaces
* CEPT: Geolocation databases

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United Kingdom, (January 2014)

OFCOM published study for improving mobile coverage in buildings

"
A research study outlining options for improving mobile coverage in buildings. Published 09/01/2014
Existing indoor cellular coverage is increasingly important for both voice and high speed data services.
The study identifies a number of options including ongoing development and enhancements to existing wide area macro networks, such as MIMO antenna deployment and allocation of sub 1GHZ spectrum addressing the issue of deep indoor coverage..

..The study highlights the potential benefits and challenges associated with deployment of dedicated indoor solutions including: Self and carrier provided WiFi Repeaters Femtocells Picocells Distributed Antenna Systems Distributed Basestations (CoMP, CPRI, X2)..
"

Get further information here

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United Kingdom, December 2012
OFCOm presents the London 2012 Olympic and Paralympic Games

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OFCOM (April 2013)

OFCOM published call for public consultation on future use of the 700MHz band

Future use of the 700MHz band
Call for public consultation published
Closing Date for Responses: 5 July 2013
Get a document copy here [297 KB]

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APWPT response (July 2013, short form)

Two summary statements:

Please be aware that any wrong decision will have an immense impact on the cultural and social life of every citizen of the European Union and UK in particular.

The decision on allocating new IMT services in the band 694 – 862 MHz need to be directly linked to a sustainable harmonised EU solution to prevent building up new borders within EU for cultural life.

Comments on the Consultation

1. This is the APWPT response to Ofcom’s consultation on the future use of the 700 MHz band in close collaboration with the British Entertainment Industry Radio Group (BEIRG).

2. The secondary status of PMSE is an obstacle to a long term sustainable solution for PMSE.

3. Ofcom should understand that PMSE is one of the most efficient spectrum users and proved to be a service that can share spectrum with other (sharing) services.

4. Ofcom should understand that allocating spectrum to IMT will make any co channel sharing impossible! LTE is one of the most polluting digital modulation schemes creating unpredictable Out Of Block emissions causing harmful interferences to other services.

5. IMT should be forced to be more spectrum efficient in the already allocated frequency bands (GSM and UMTS bands are still underused, providers do not share spectrum, etc.).

6. Ofcom should realise that there is a waste of spectrum to IMT because of the „free market and competition“ approach. Every market player a chunk and therefor any chunk is underused. Ofcom should arrange IMT licenses in that way that providers are forced to share in order to be more spectrum efficient.

7. Ofcom should understand that providers are not willing to pay the amounts on auctions as on previous years and will even demand money in return to build the networks (trend of the IMT industry presentations on „Forum Europe Spectrum Management Conference 2013“). As the data demand growth on IMT is based on old studies before 2008 that do not take into account consumer and business behaviour in the current economic crisis, a market failure could occur. Another trend is that the main providers invest in high capacity cable networks.

8. The IMT industry should be aware that they kill their own content production which could have a negative effect on their income on SMS services and traffic during events.

9. Professional Programme Making and Special Events (PMSE) users rely extensively on the Interleaved UHF TV band spectrum, or ‘White Space’, notably for major live events such as the recent Olympic Games, Wimbledon Tennis, etc. but also routinely for touring theatre and live music, TV, corporate events, News Gathering and many other day-to-day activities. PMSE have an increasingly international character (Olympic Games, UEFA championship, etc.).

10. After the London Olympic Games Ofcom published a report on PMSE spectrum needs during the event. APWPT welcomes this report. Ofcom however should learn from this, that sufficient alternatives are released to PMSE in order to facilitate events in the future and to compensate for any further spectrum loss. Manufacturers are not able to build equipment suitable for just one occasion.

11. The reallocation of DTT allotments currently active in the 700 MHz below 694 MHz will have a diminishing effect on the availability of white spaces for PMSE.

12. When an appropriate alternative cannot be secured the 700 MHz digital dividend should be allocated to PMSE.

13. The 600 MHz band should be opened for PMSE, radio microphones in particular, in order to create an alternative for the loss of the 800 MHz band.

14. The 1,4 GHz L-band (auctioned off to Qualcomm, but so far NOT USED) should be allocated to PMSE and radio microphones in particular, in order to provide alternatives for the 800 MHz band (recent policy of Germany is to allocate 1452-1492 MHz to radio microphones). When the 700 MHz wouldn’t be available anymore the extension of the L-band (1492-1525 MHz) should be added as it is a necessity. Other spectrum between 1,2 and 1,6 GHz should be released to fully compensate the loss.

15. TV channels that are available to professional PMSE users at various locations may in practice be rendered unusable due to LTE out-of-block emissions. DTT is not the only service that needs theoretically to be protected from LTE interference and it is vital that a strict regulatory approach is adopted in order to protect PMSE use of the remaining interleaved spectrum. Any relaxation of out-of-block EIRP limits or increases in maximum permitted base station EIRP directly threatens the PMSE industry. We strongly urge Ofcom to adopt and monitor the most stringent emissions mask and to resist any pressure to relax or remove controls on out-of-block emissions or to limit maximum LTE base station EIRP.

16. To grasp the full socio-economic value of PMSE you need to take into account at least a part of the revenues made by productions using PMSE equipment such as:

a. Direct sales of equipment

b. Direct ticket sales of concerts, sport events and other venues

c. Direct revenues of rental companies on the equipment

d. The advertisement coming from all the events

e. The spin-off of these events (like tourism, hotels, taxis, restaurant and catering industry)

f. indirect revenues from SMS services linked to events (European Song Contest, The voice of…etcetera)

g. Indirect revenues of IMT providers on the traffic during events

h. Indirect revenues (sometimes lasting even more than 10 years after the event) of recorded material of the events (DVD, Blue Ray, You Tube, Film Industry, etcetera).

17. What should be understood is that if the 1st and 2nd Digital Dividends are implemented and most events cannot be produced in their current form, then the loss of the above-mentioned socio economic benefits of PMSE would outclass all revenues on IMT auctions. It would be „pennywise-pound-foolish„. (e.g. London West End revenues due to secondary revenue streams of the musical industry = £0.5 bln annually times 20 years = auctioned off frequencies £10 bln; source BEIRG UK).

18. The growth of the number of channels used in events is estimated a 10% every year and the data demand growth is similar to that of IT/IMT. PMSE need additional spectrum in order to facilitate this growth.

19. What we demand is a policy that acknowledges the importance of the PMSE industry (users in particular) and a focus on a sustainable long term future that can accommodate the growth of the industry.

20. We fully support BEIRG in their response to this consultation with the exception of the below comments:

Question 3: Any benefit to IMT is over estimated as

a. The effects of the 1st DD are not known yet

b. The data demand growth of IMT are old studies and not amended to current needs and consumer behaviour

c. The behaviour of consumers to use Wi-Fi to off-load is a pain for providers but a benefit for consumers

d. IMT will sit on spectrum and already do. They are underusing already allocated spectrum

e. The benefits should be compared with the loss of revenues as mentioned in the above socio-economic criteria of PMSE.

Question 5: Further erosion of PMSE spectrum is unacceptable and will hurt the culture economy in its heart. The musical (London West End) industry might even vanish.

Question 7: Ofcom should do whatever it can to defend the interest of the PMSE industry internationally (EC, CEPT and ITU-R/ITU-T).

Question 8: CEPT report 32 identifies for daily productions, which might use up to 98 channels of IEM and radio microphones, that 144 MHz of white space below 1GHz is needed. This spectrum demand should be considered a necessity and guaranteed for PMSE in dense populated areas.

Question 9: The 700 MHz band should not be released in favour of IMT but in favour of PMSE!
Any further erosion of the UHF TV band is unacceptable!

Question 24 is answered already in points: 2; 3; 9 till 19. The following links are additional useful information:

1) Social and economic benefit of European Art, Culture and Creative Industry [1.643 KB]
and
2) PMSE strategy paper [1.511 KB]

Question 25: Regulators do have the opinion that PMSE, because most radio microphones are still analogue, is an old fashion industry. Currently there are numerous digital radio microphones on the market. Ofcom should realise that:
a. Digital radio microphones are as sensitive to interference as analogue

b. Digital radio microphones are not more spectrum efficient than analogue (they even occupy more bandwidth when the same audio quality is needed)

c. Digital microphones still (and will) suffer from more latency then analogue.

d. Although the C-PMSE project is in an evolutionary stage, it shows that the PMSE industry is far „more developed“ in clever cognitive radio then e.g. the WSD.

Question 26: Answers already in points: 9 till 14.

United Kingdom News History


United Kingdom (December 2012)
OFCOm presents the London 2012 Olympic and Paralympic Games

OFCOM (June 2012)
Consultation for the ‘XX Commonwealth Games’
(Start date: 23 July 2012 / End date: 23 November 2012)

BroadcastEngineering (24th May 2012)
UK fears for DTT over 4G interference

APWPT News: (23rd April 2012)
Present spectrum activity in the UK

BEIRG: (April 2012)
Response [296 KB] to the "OFCOM Second consultation on coexistence of new services in the 800MHz band with digital terrestrial television"

OFCOM: (29th March 2012)
Securing long term benefits from scarce spectrum resources
A strategy for UHF bands IV and V

OFCOM: (31st January 2012)
A review of the management of the spectrum currently used
To be closed on 30th April 2012

Broadnad TV News: (2nd June 2011)
Ofcom plans ‘platform replacement’ to avoid 4G interference

Ofcom: (16th May 2011)
4G Capacity Gains

Ofcom Update: (18th October 2010)
The Spectrum Plan for the London 2012 Games

InAVateonthenet.net (5th August 2010)
UK Government lets down events industry

Rethink Wireless (23rd July 2010)
Qualcomm confirms it will exit MediaFLO

Ofcom Update: (14th June 2010)
The TV-channel 38 will be available

Rethink Wireless: (18th May 2010)
AT&T reverses 'straight-to-LTE' strategy

Spectrum and License News updated: (16th April 2010)

Ofcom: (18th February 2010)
Digital Dividend at 600 MHz

Ofcom update: (21st December 2009)
New licensing arrangements for wireless microphone users

OFCOM Info WEB Page: (8th November 2009)
The Spectrum Plan for the London 2012 Games - Statement

OFCOM Info WEB Page: Olympic wireless plans on track (22nd October 2009)

BEIRG: Response to DDR Funding Consultation (11th September 2009)

OFCOM:Digital dividend: band manager award – second consultation on detailed award design (8th September 2009)

Ofcom - Clearing the 800MHz Band (30th June 2009)

APWPT Response to consultation ‘Clearing the 800 MHz band’ (20th April 2009)

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