3400 to 3600MHz. Crown Recognised Spectrum Access in 3400 to 3600 MHz. The response of Alcatel-Lucent to Ofcom Spectrum Policy Group

Transcription

1 Crwn Recgnised Spectrum Access in 3400 t 3600 MHz The respnse f Alcatel-Lucent t Ofcm Spectrum Plicy Grup Spectrum Access in t 3600MHz

2 Fr additinal infrmatin and clarificatin, please cntact: Jean-Pierre Bnin, Luis Lucater, Neil Baker, 2

3 1. General principles advcated by Alcatel-Lucent fr the use f the band MHz The band GHz shuld be made available as sn as pssible t BWA applicatins There is an increasing demand fr high speed data cnnectins in urban areas. The band MHz represents a unique pprtunity t cmbine the delivery f very high speed cnnectins in ht spts and dedicated areas with the advantages f perated netwrks in terms f service quality and availability. In additin the Cmmissin Decisin 2008/411/EC urges Member States t make this band, r parts f this band, available fr BWA as sn as pssible. N limitatin shuld be prvided t the pssibility fr Operatrs t develp their netwrk using the technlgy f their chice, and t adapt it in due time with the last features and technlgy innvatins in rder t satisfy market demand. The band MHz prvides a unique pprtunity t deliver very high capacity bradband services in dedicated areas Our view is that all players shuld be granted licenses cvering at least 60 MHz, either in a single blck f 60 MHz, r in paired blcks f 2 30 MHz. This wuld avid spectrum fragmentatin and wuld minimise the number f frntiers between BWA blcks, thus being cmpatible with the implementatin f large channel bandwidth. Such blck size wuld allw peratrs t effectively build systems with very high capacity. Channel widths up t 20 MHz width wuld becme pssible and netwrks culd further evlve twards IMT-Advanced implementatin. The existing peratr UK Bradband shuld be allwed, if they wish, t enter int trade with Crwn Bdies fr additinal spectrum, if hey wish, in rder t benefit frm the same pprtunities. The regulatry framewrk shuld be as flexible as pssible Such regulatry framewrk will allw Operatrs t ffer the set f services and applicatins they cnsider the mst relevant while minimising their CAPEX as much as pssible. We cnsider that the fllwing will serve these bjectives: - Crdinatin and synchrnisatin between peratrs in adjacent blcks shuld be encuraged. Such synchrnisatin / crdinatin wuld allw Out-Of-Blck levels higher than thse resulting frm the strict applicatin f the Blck Edge Mask. It wuld minimise the extra-csts resulting frm the insertin f RF filters assciated with 3

4 the cmpliance t the Blck Edge Masks. Such regulatry prvisins are allwed by Cmmissin Decisin 2008/411/EC. - The regulatry framewrk shuld nt restrict the type f services and applicatins an Operatr shuld be allwed t deliver fr the benefit f the final users. - Operatrs shuld have the right t swap, trade and rearrange their bands amng them in rder t ptimise their netwrks. Terminal Blck Edge Mask shuld nt be impsed Our view is that cmpliance with existing standard(s) fr Terminals, namely EN fr Mbile Terminals, wuld be sufficient t ensure the c-existence between adjacent blcks. The rights f the existing BWA Operatr shuld be preserved The expected changes in the use f the band / MHz, especially the intrductin f new BWA players in the spectrum immediately adjacent t the spectrum f the BWA peratr UK Bradband, and/r changes in the regulatins fr EPSS use, shuld nt affect the pssibilities fr UK Bradband t develp its netwrk with regard f what they can actually implement, as fr instance the prvisin f 2 10 MHz channels in each f the 20 MHz blcks. We are f the view that impsing the BEM prvisins t UK Bradband spectrum edge may restrict this pssibility. Shuld EPSS be shifted t anther part f the spectrum it shuld be ensured by the regulatry framewrk that the level f interference t UK Bradband netwrk shuld nt be increased with regard t the current scenari. 4

5 2 Respnse t specific Questins Questin n 1: d yu agree that we shuld intrduce RSA in the 3400 t 3600 MHz? By ffering Crwn Bdies mre flexibility and financial advantages in cmparisn with cnventinal spectrum release methds RSA prvides a way fr faster release f the band MHz t ther applicatins. Therefre we share Ofcm views that RSA shuld be intrduced in the 3400 t 3600 MHz band, especially fr the part f the band which is expected t be transferred t cmmercial applicatins. Questin n 2: d yu agree that we shuld extend the relevant regulatins t allw Crwn bdies t be granted and t trade RSA in the MHz and MHz blcks? If nt, which frequency ranges d yu think the RSA regulatins shuld cver and why? We agree that granting RSA t the MOD wuld be an efficient tl t release spectrum fr cmmercial BWA use f the band. Fr the part f the spectrum which will be used fr EPSS applicatins in the future, either existing ne r a new ne if this applicatin is shifted, we have n pinin n the need t grant RSA fr this specific piece f spectrum, and n the details f the RSA prcess in this case. Questin n 3: d yu agree that there shuld be n minimum trading unit fr the RSA grant and the WT licences arising frm trade in the band? Taking int accunt the nature f BWA applicatins and the bligatin fr UK t apply the prvisins f Cmmissin Decisin 2008/411/EC, we are f the pinin that allwing t small blcks wuld nt serve the interests f ptential BWA Operatrs. Therefre we respectfully suggest Ofcm t define a minimum trading unit f 10 MHz. Cncerning the administrative trading unit, we supprt t grant licences rather in wide areas than in small ne. Therefre we suggest that licences t BWA Operatrs be granted natinwide r at least at reginal level. Questin n 4: are there specific cnditins that yu cnsider shuld be included in RSA grants and WT licences arising frm trading in the band? N respnse. Questin n 5: d yu agree with the prpsed in blck emissins limit fr base statins in the MHz blck? In principle we agree with this in blck emissins limit. Nevertheless we pint ut that this limit shuld be applied with sme flexibility in rder nt t give 5

6 penalty t systems equipped with MIMO and/r beam frming features, i.e.these limits shuld preferably be applied t each antenna and nt glbally. Questin n 6: d yu agree with the prpsed ut f blck emissins mask at the 3500 MHz and 3580 MHz bundaries fr base statins? We als agree in principle, with the fllwing reservatins: - The right shuld be given t peratrs in adjacent blcks t crdinate r synchrnise their netwrks in rder nt t be bliged t implement the ut f blck emissin mask. The regulatr shuld encurage this synchrnisatin / crdinatin prcess and shuld impse the mask nly as last slutin when crdinatin appears nt t be pssible. - The technical cnditins impsed at the extremities f the band shuld nt result in limitatins t the actual implementatin capability f UK Bradband. Questin n 7: d yu agree that less stringent technical parameters shuld be permitted if agreed between neighburing peratrs? Yes, see respnse t Questin n 6. In additin we think that by nature the frequency band MHz prvides gd pprtunity fr the deplyment f pic r femt cells. In this case we are f the pinin f less stringent masks, pssibly based n current standards, shuld be sufficient t ensure cexistence with neighburing netwrks. Questin n 8: shuld we align UK Bradband licence cnditins fr base statins at 3500 MHz and 3580 MHz with thse in the RSA grants if and when UK Bradband requests t d s? In principle yes if it is requested by UK Bradband. Questin n 9: d yu agree with the prpsed in blck emissins limits fr terminal statins? In principle we agree. But as fr base statins these limits shuld be cnsidered with sme flexibility fr items equipped with multi-antenna features. 6

7 Questin n 10: d yu agree that the blck edge mask shuld be based n the spectrum emissins mask frm ETSI EN ? Als there we agree. But masks which may be develped in this band fr UMTS and LTE Terminals shuld als be cnsidered. Mre precisely, taking int accunt the final decisin f CEPT nt t require any change t WiMAX and LTE UE standards in view f the cnclusin f ECC Reprt 131 in the band GHz we cnsider that similarly in the band GHz there is n need t develp an Out Of Band emissins mask and that the selectivity prvided by the specificatins in the standards wuld be sufficient. Questin n 11: d yu agree with ur derivatin f regulatry ut f blck limits fr terminals and, if s, which f the prpsed fur alternative regulatry cnditins d yu think mst apprpriate? Our preference is fr Optin 4, i.e. just apply the prvisins in the relevant standards. This wuld facilitate future intrductin f 20 MHz channels in the band which may be refrained by the definitin f a Blck Edge Mask implicitly based n narrwer channel sizes. Questin n 12: shuld ut f blck limits fr fixed, nmadic and mbile termnals be different? Taking int accunt that fixed terminals are generally equipped with directive antennas their interference ptential t neighburing netwrks is in principle lesser than the ne f mbile r nmadic terminals. Therefre we cnsider that the same ut f blck limit may nt necessarily be impsed t them. As far as the rule wuld just be t be cmpliant with their respective standards this is nt cntradictry with the principle f technlgy neutrality. Questin n 13: shuld we align UK Bradband licence cnditins fr terminal statins at 3500 MHz and 3580 MHz with thse in the RSA grabts if and when UK Bradband requests us t d s? If requested yes, but we d nt think there is a ratinale fr them t d s, at least nt at the beginning f the prcess. Questins14 t 20 N respnse. 7

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