Turhan MULUK Intel Corporation 14 th February Ref : LIC/1209/883

Transcription

1 Turhan MULUK 14 th February 2010 comments on the Telecommunications Radio Frequency Spectrum in the Kingdom of Bahrain: Management Current and Future Requirements Release Plan Ref : LIC/1209/883 To: The General Director spectrum-consultation@tra.org.bh Telecommunications Regulatory Authority P.O. Box 10353, Manama, Kingdom of Bahrain From: Turhan Muluk EMEA Communications Policy Team Corporate Affairs Group Address: Bilkent Plaza A3 Blok 5. Kat, No: , ANKARA-TURKEY Tel: Fax: turhan.muluk@intel.com Introduction (Intel) welcomes the opportunity to respond to this Consultation to ascertain potential future demand for Radio Spectrum Frequencies in the Kingdom of Bahrain. If our comments are unclear in any area or if additional information is required, we would be pleased to provide the necessary clarification or additional information in whatever appropriate format the Telecommunications Regulatory Authority (TRA) desires. is the world s largest semiconductor manufacturer and a leader in technical innovation. Intel is also a leading manufacturer of communications and networking chips and equipment. Intel s comments are contained in the subsequent pages. Best Regards Turhan Muluk Wireless Standards and Regulations Manager EMEA Communications Policy Team Corporate Affairs Group Page 1 of 9

2 Intel s General Comments: Intel commends the TRA for efforts to accelerate the ICT development in Bahrain. Intel supports the development of broadband and Internet access in all countries. We believe consultancy will help to increase broadband and internet usage in Bahrain. We would strongly encourage any administration to establish technology and service neutral policies and permit compliance to global standards. Broadband is key for competitiveness and economic growth and delay of broadband spectrum licensing results in economical loss. It is important to provide consumers with access to the benefits of innovation, competition and capable new wireless broadband technologies which are commercially available today. The cost of delaying the release of spectrum can be significant. Economists Thomas Hazlett and Roberto Munoz estimate that the net present value to consumers from making additional wireless spectrum available is 10 to 20 times the revenues generated by auctioning that spectrum.1 It is useful to note: - There are more WiMAX base station manufacturers at 2.5/2.3 GHz bands than GSM/UMTS base station manufacturers. - GSM/UMTS base station manufacturers have WiMAX products at 2.5/2.3 GHz band Bahrain citizens can start to benefit from Mobile WiMAX technology and its economic returns by assigning 2.5 and 2.3 GHz spectrum bands. Intel s Responses to Questions Question 1 TRA is of the view that the current framework for spectrum management will be found inadequate with respect to proactively identifying the future demand for radio frequency spectrum. In defining a new framework and spectrum release plan TRA intends to take into account: the future shape of radiocommunications; international developments; the encouragement of investment; strategic considerations; fair compensation for the community; and the avoidance of hoarding spectrum. TRA invites comment with respect to the factors to be considered in designing a Spectrum Release Plan for the Kingdom of Bahrain. Answer 1 TRA has correctly identified some of the key factors to be considered. Sound spectrum management and access are keys to wireless broadband connectivity. Indeed, effective use of the spectrum will bring lower cost and promote better usage of the available resources. Intel supports TRA for a new framework and spectrum release plan. 1 Thomas W. Hazlett and Roberto E. Munoz, A Welfare Analysis of Spectrum Allocation Policies, Manhattan Institute for Policy Research, June 10, 2004, p. 17. Page 2 of 9

3 Intel concurs with TRA s view that traditional command and control approaches are no longer sustainable. Importantly, some governments, recognizing that regimented spectrum management system impedes innovation, are modernizing their spectrum policies by giving manufacturers and licensees more flexibility to innovate and meet market demands. Technology Neutral spectrum management allocates spectrum flexibly without designating the technology or technologies which can be used. It supports allowing the licensee of the spectrum to choose the technology solution that is most appropriate for its business model or market, as long as it adheres to the regulatory and technical requirements. Intel believes this Technology Neutral approach to spectrum management is one of the best methods of bridging the broadband digital divide. Next Generation Mobile Broadband Systems (such as WiMAX and LTE) require more spectrum and this need for spectrum will continue to increase with the introduction of IMT-Advanced systems. Therefore, efficient usage of spectrum and radio spectrum management becomes much more important. We note that Time Division Duplexing (TDD) is ideally suited to support internet based services and it provides better spectral efficiency with asymmetric traffic. We believe it is important to ensure that the most appropriate spectrum is made available for the services and applications being considered. The MHz and MHz bands are key global bands for next generation mobile broadband services. The assignment of these bands for broadband applications will encourage broadband investment in Bahrain. Question 2 TRA is minded to revise and modify the Generic Frequency Licence, as well as removing and relocating licences terms and conditions to TRA s web-site, rather than maintaining them in a hard-copy format, attached to each and every licence. The licence s terms and conditions would be incorporated by Regulation into the Generic Frequency Licence. Both the draft future Generic Frequency Licence and the draft terms and conditions text are attached in Annex 2. TRA therefore invites comments on the proposed text modifications in Annex 2 and the intention of locating the licensing conditions on the TRA web site. Answer 2 Intel supports transparency and TRA s proposal in general. We do have a few specific concerns. In particular, we note that no spectrum trading is permitted. Intel recommends permitting spectrum trading as a method of ensuring that the band is able to be utilized for the highest valued use. Additionally, we note that there is no automatic right to renewal. We are concerned that the current one year licensing period with no automatic right to renewal will severely undercut incentives to deploy expensive, long-lived infrastructure spending Question 3 TRA plans to introduce a minimum notice period if frequency assignments are subject to modification or withdrawal. What are your suggestions with respect to an appropriate minimum notice period? Answer 3 Intel supports the application of minimum notice period. This notice period would need to be sufficient to allow incumbents to vacate the band. Question 4 Page 3 of 9

4 In addition to the current migration policy in Regulation No. 3 of 2008 and in cooperation with the SSCC should a policy on spectrum refarming and spectrum migration be evolved, which will establish policy and compensation procedures for all spectrum users in the Kingdom? Answer 4 Intel offers these comments on spectrum refarming and spectrum migration. In our experience, involuntary spectrum refarming can lead to lengthy legal delays. Therefore, Intel recommends that where spectrum refarming is necessary, TRA first attempt to negotiate with the incumbents to determine a fair solution. As noted above, we believe that it is desirable to permit spectrum trading to enable operators to utilize the spectrum for the highest valued use. In general, the cost of moving existing licensees should be funded through general tax or auction revenues. We do not favour the use of spectrum taxes or fees. Question 5 Whilst TRA is of the opinion that TDF is the most expedient form of refarming compensation mechanism it recognizes the deficiencies of the approach with respect to users not subject to the Telecommunications Law, since such users would also be not subject to Regulation No. 3 of TRA invites comments on how best to incorporate such users into a refarming compensation scheme and the appropriate minimum notice period(s) to be applied to refarming. Answer 5 Intel recommends the use of best practice re-farming methods applied in other countries. For example, countries have successfully used New Entrant Pays whereby the cost of migration becomes the reserve price of the auction. If market demand is sufficient that the winning bid exceeds the cost of migration, then the reserve price can be used to move the existing licensees and any additional monies are paid to the government. If market price does not exceed the cost of migration, the existing user retains the access to the spectrum. Question 6 TRA is of the opinion that there should be no legitimate expectation of licence renewal on expiry of a spectrum assignment provided that sufficient notice of the intentions of TRA is provided. TRA invites comments on the concept of no automatic or legitimate expectation for spectrum assignment renewal as well as views concerning an appropriate period of notice prior to the expiry of a service licence with associated spectrum assignments. Answer 6 Intel believes that the development of efficient broadband wireless networks requires long license terms. National networks can take several years to build out to substantial capacity. Operators business models are complex and initial infrastructure build out costs are high, requiring longer operating times to become profitable. Additionally, without longer certainty relative to the license duration and right of renewal, it will be difficult for network operators to attract investment. We therefore recommend that TRA set a license duration of 15 to 20 years, with a right of renewal, which will provide more time for optimum build out and more certainty to enable investment. Question 7 TRA invites comment on the potential licensing and use of the bands MHz Page 4 of 9

5 and MHz for public (commercial) mobile services in the bands MHz or MHz? Answer 7 Intel supports technology and service neutrality policies. Sufficient flexible assignment of spectrum with as wide as possible channels basing on 5 MHz channel raster is important to reduce network costs and keep broadband services affordable. Question 8 TRA invites comments on the potential designation of all or parts of the band MHz for ITU designated IMT services? Answer 8 Intel supports the assignment of all MHz band for mobile services. Question 9 TRA is of the opinion that proposals for a licence in the bands MHz and MHz should be abandoned in view of digital dividend studies, SRD developments and a possible GSM-R requirement. TRA invites comments on the future uses of these bands. Answer 9 In addition to service flexible and technology neutral assignments, Intel supports flexibility in duplexing methods. Assignment of sufficient spectrum (at least 30 MHz for each operator, excluding guard band) and flexibility to use as wide as possible channels basing on 5 MHz channel raster with widths up to 20 MHz is important to reduce network costs and keep broadband services affordable. Question 10 TRA invites comments on the potential future uses of spectrum bands currently used for FWA systems in the Kingdom, in particular should spectrum at 10 GHz, 26 GHz, 28 GHz and 40 GHz be maintained for FWA licences or should it be considered for alternative applications, which are in accordance with the NFP? Answer 10 Intel supports the usage of these spectrum bands in a harmonised and technology neutral manner. Question 11 TRA invites comments relating to any other of the data provided in Table 1 and Table 2? Answer 11 First, Intel notes that the primary bands for Mobile WiMAX, the 2.3 and 2.5 GHz bands, are currently not available for mobile broadband. Intel strongly urges the TRA to consider the expeditious release of spectrum in the 2.3 and/or 2.5 GHz band. The 3.5 GHz band identified by ITU for IMT services. EC (2008/411/EC) and ECC/DEC/(07)02 decisions gives flexibility to administrations for the mobile service application at 3.5 GHz band. Intel recommends the allowance of mobile services at 3.5 GHz band and changing the service name from NFWS to NBWS (National Broadband Wireless Service). Page 5 of 9

6 Referencing 5GHz allocation section in Table 1, the MHz band has been excluded for use by RLANs (Wi-Fi) and footnote 16 that the frequency band 5470 to 5725MHz is allocated solely for government use within the Kingdom of Bahrain. Intel recommends that the MHz band be included in this section for use by Wi-Fi and other licensed exempt devices, consistent with WRC 03 Resolution 229 for Wireless Access Systems, ITU-R M.1450, and ITU-R M The recommendations have been adopted by most countries. Adoption of these recommendations would further allow for the nomadic use of devices with built-in Wi-Fi benefiting the consumer. The current version of the technology is defined by the standard IEEE n which operates in both 2.4GHz and 5GHz spectrum, and incorporates larger channel widths (40MHz) as well as other technical innovations in order to provide significant performance improvements over the previous standard, IEEE bg. While the new standard opens up many new applications, such as video streaming, for the consumer, it also requires more bandwidth to accommodate wider channels. Further, the added spectrum (255MHz) would allow for added flexibility for future innovations in technology. Question 12 TRA consider it appropriate to publish a non-binding Telecommunications Spectrum Release Plan (TSRP) covering spectrum suitable for all sectors managed by the TRA. TRA invite comments on the proposed TSRP contents and review period. Answer 12: Intel supports the publication of a Telecommunications Spectrum Release Plan (TSRP) to address the supply of spectrum for telecommunications through transparent, open and non-discriminatory processes. Intel believes annual review of plan would be ideal. Question 13 TRA invites comments on its proposal, subject to SSCC approval, to: Offer amateur licensees in the Kingdom additional spectrum at 500 khz, 5.3 MHz and 70 MHz in order to participate in propagation experiments. Introduce a band at MHz paired with MHz for private maritime applications. Seek to introduce a lightly licensed short range communications system based on internationally available hand-held equipment, ideally at 446 MHz. Reserve the GSM-R frequency bands at 900 MHz for possible use in relation to the GCC railway project and review the situation in Determine whether spectrum gained as a result of the transition from analogue to digital terrestrial television should be used for broadcasting, fixed, mobile (IMT), converged services or other applications. Answer 13 Intel supports technology and service neutral assignment of spectrum in a manner harmonized with ITU decisions. Intel also recommends the usage of spectrum gained as a result of the Page 6 of 9

7 transition from analogue to digital terrestrial television for broadband wireless access application. It is noted in table that the digital dividend spectrum ( MHz) is proposed for LTE services only. WiMAX Products will be also available at this band. Therefore, Intel recommends changing the name of proposed services to BWA (Broadband Wireless Access) rather than limiting it to a specific technology. Question 14 There remain concerns about PMR446 (or similar equipment) being used for antisocial or illegal activities, TRA invites comments on how these may be overcome. Answer 14 Intel has no any comment. Question 15 TRA invites comments on the consideration that services currently operating at 2.3 GHz and 2.6 GHz might be refarmed to provide additional spectrum for IMT systems. Answer 15 As also explained in Answer GHz and 2.3 GHz bands are key global bands for next generation mobile broadband services. However, in Table-3, the 2.3 GHz band has been proposed for FWA and the 2.5 GHz band proposed for FWA/LTE services. Intel recommends that TRA change the name of proposed services to Broadband Wireless Access rather than refer to specific technologies. Also, the distinction between fixed and mobile networks and services is becoming increasingly blurred due to market and technology developments. Therefore, operators should be able to offer mobile, nomadic, and fixed services within these bands. The assignment of the 2.5 GHz and 2.3 GHz spectrum for wireless broadband will be an important step for Bahrain to foster cost effective broadband for Bahrain citizens. This assignment will further the government s goals of creating a knowledge-based,, technology-driven economy and the other important goals set out in the national broadband plan. Recently, the number of WiMAX deployments reached 519 networks in 146 countries, 112 of which were added in 2009.Globally, many operators offering mobile WiMAX services at 2.3/2.5 GHz bands. In Russia, Yota reached subscribers in October 2009 just months after its commercial service was launched in July Another example is Packet One Networks in Malaysia, which reached 130,000 subscribers in its first year of service. Clear, Sprint, Comcast and Time Warner Cable all have also made strides in expanding their networks this year, with multiple U.S. city launches set to come by the end of 2009 and nearly 200,000 subscribers to-date. UQ Communications announced plans to cover more than half of the Japanese population by the end of December 2009, and Korea Telecom s Mobile WiMAX network already covers more than half of the Korean population. For more information on global WiMAX deployments, please visit Furthermore, Intel has already created an embedded solution with a combination of Wi-Fi and WiMAX technologies. More than 100 different models of notebooks and netbooks containing an embedded Wi-Fi/WiMAX solution are already available. Many other companies also have base stations and subscriber stations for the MHz and MHz bands commercially available. Page 7 of 9

8 These factors are establishing global economies of scale, creating the environment for operators to provide cost effective, state of the art broadband access solutions for Bahrain as well as global citizens. We believe that the expeditious assignment of the MHz and MHz bands will greatly benefit citizens and businesses in Bahrain. Therefore, we recommend the assignment of MHz and MHz bands as soon as possible to introduce next generation mobile broadband services in Bahrain and to accelerate affordable broadband services. Question 16 TRA invites comments on its proposal to provide the band GHz for short range and fixed wireless systems within the current light licensing regime. Answer 16 Intel supports high throughput Personal Area Network (PAN) technologies utilizing the 60GHz spectrum. This wireless technology utilizes 57-66GHz spectrum. The short range technology is capable of producing multiple gigabit data rates for PAN applications such as wireless compute display, wireless HDMI (audio/video) cable, Sync file transfers (Kiosk, peer-to-peer, computer I/O and peripherals), and mobile displays. Several administrations, including U.S.A., EU, Korea, Japan, and others have allocated spectrum in this band for use by unlicensed devices. Intel recommends adoption of above spectrum on a licence-exempt basis, and encourages harmonization of related rules with other major geographies. Question 17 TRA invites comments on its proposal to make available the band GHz for fixed wireless systems using a modified light licensing regime, as described above. Answer 17 Intel has no any comment. Question 18 Do you have any proposals for additional frequency bands or telecommunications applications? Please note. All proposals should include the following information: The proposed frequency band(s); The bandwidth required; Details of the service(s) which could be provided in the proposed frequency bands; The proposed number of licences; The proposed licensing mechanism; and Any other comments or suggestions. Answer 18 Access to the 2.5 GHz and 2.3 GHz bands should be made available as early as possible for the introduction of affordable next generation mobile broadband services. Recognizing that 30 MHz of contiguous spectrum (excluding any guardband requirements if needed) is the minimum for a successful high-speed broadband wireless access deployment, it is Page 8 of 9

9 important to allow operators the opportunity to obtain additional spectrum to support their current as well as future needs. We also recommend that TRA allow operators to obtain more than 30 MHz in order to suit their proposed and future business models. Operators should be able to offer all kind of telecommunication services (fixed, nomadic, mobile, VoIP etc.) without any limitation. We do believe that enabling competition is important but not at the expense of success. We therefore believe that number of licenses needs to be assessed from a National level with the objective being that all deployments are successful deployments, i.e. one or many need to be successful. Intel generally prefers licenses to be assigned by auction because this method quickly establishes those licensees that value the spectrum the most. It also relieves pressure on Regulators to pick technology winners. In practice, this market based approach ensures that spectrum is available to those with viable business cases and valuable broadband deployments. In the case where incumbent services are in the band, it may be appropriate to consider spectrum trading or voluntary refarming with the migration costs funded by the auction revenues. Page 9 of 9