JRC Response to the Consultation on. More Radio Spectrum for the Internet of Things

Similar documents
Further Consultation on the Release of the / MHz Sub-band

Glossary of Terms Black Sky Event: Blue Sky Operations: Federal Communications Commission (FCC): Grey Sky Operations:

Programme Making and Special Events High power PMSE applications in the lower two megahertz of Channel 38 ( MHz)

Licensing of Telemetry Systems in the VHF and UHF Spectrum Bands Guidelines for Applicants

Policy for Allocation and Assignment of Spectrum 2.5GHz Band (2500MHz MHz)

OfW48 UK Frequency Allocations for Fixed (Point-to-Point) Wireless Services and Scanning Telemetry

Statement on variation of 900 MHz and 1800 MHz Wireless Telegraphy Act licences

Spectrum opportunity cost calculations in parts of VHF Band I

Analogue and Digital PMR446 Information Sheet. Business Radio

COMMISSION IMPLEMENTING DECISION

Consultation on the licensing of spectrum in the 800 MHz and 900 MHz bands

This Licence document replaces the version of the Licence issued by the Office of Communications (Ofcom) on 23 March 2015 to EE Limited.

OfW48 UK Frequency Allocations for Fixed (Point-to-Point) Wireless Services and Scanning Telemetry

EE Limited - Public Wireless Network Licence Company Registration no First Issued: 26/03/93 - Licence Number: Rev: 20-10/01/17

Urban WiMAX response to Ofcom s Spectrum Commons Classes for licence exemption consultation

1. The Office of Communications (Ofcom) grants this wireless telegraphy licence ( the Licence ) to

Response of Boeing UK Limited. UK Ofcom Call for Input 3.8 GHz to 4.2 GHz Band: Opportunities for Innovation 9 June 2016

Consultation on the Technical and Policy Framework for White Space Devices

Statement on the Authorisation of Short Range Devices in 870 to 876 MHz and 915 to 921 MHz

Variation Form for a Business Radio Area Defined Licence

Spectrum and licensing in the mobile telecommunications market

Electronic Communications Committee (ECC) within the European Conference of Postal and Telecommunications Administrations (CEPT)

Release of the GHz Band

Approved 8 November Amended 3 July 2015

1. The Office of Communications (Ofcom) grants this wireless telegraphy licence ( the Licence ) to

May 24, Sent via

More Radio Spectrum for the Internet of Things

Q1. What future uses might this spectrum support?

Huawei response to the. Ofcom call for input: 3.8 GHz to 4.2 GHz band: Opportunities for Innovation

Notice of coordination procedure required under spectrum access licences for the 2.6 GHz band

Authorisation of terrestrial mobile networks complementary to 2 GHz mobile satellite systems (MSS) A Statement on the licensing of 2 GHz MSS

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C

Submission to the Ministry of Economic Development. on MHz Band Replanning Options

Proposals for Liberalisation and Simplification for Business Radio Licensing and pricing

OfW48 UK Frequency Allocations for Fixed (Point-to-Point) Wireless Services and Scanning Telemetry

Improving access to 5.8 GHz spectrum for broadband fixed wireless access

Statement on the Requests for Variation of 900 MHz, 1800 MHz and 2100 MHz Mobile Licences

The Response of Motorola Ltd. to the. Consultation on Spectrum Commons Classes for Licence Exemption

ERC/DEC/(01)07 EUROPEAN RADIOCOMMUNICATIONS COMMITTEE

This Licence replaces the licence issued by Ofcom on 25 April 2006 to Manx Telecom Limited.

This Licence replaces the licence issued by Ofcom on 22 April 2013 to British Telecommunications PLC.

Private Mobile Radio Spectrum License

Arqiva submission to Ofcom s consultation, 5G spectrum access at 26 GHz and update on bands above 30 GHz

UK Broadband Ltd Spectrum Access Licence Licence Number: Rev: 4: 11 January 2018

DAB MULTIPLEX CHANGE REQUEST: CARDIFF & NEWPORT Request to extend coverage area and change frequency of Cardiff & Newport local radio multiplex

UK Broadband Ltd Spectrum Access Licence Licence Number: Rev: 5: 14 December 2018

Consultation Paper on Using a Portion of the Band GHz for Tactical Common Data Link (TCDL) Systems

CEPT/ERC/RECOMMENDATION E (Bonn 1994, revised June 2007)

Spectrum Management Approach in the GHz and GHz bands Ofcom s decision on the future management approach for the 70/80 GHz bands

Official Journal of the European Union L 163/37

UK Broadband Limited Company Reg No: Spectrum Access 3.5 GHz Licence First Issued: 28/02/17 Licence Number: Rev 1: 11/01/18

Technical Requirements for Wireless Broadband Services (WBS) in the Band MHz

Notice of aeronautical radar coordination. Coordination procedure for air traffic control radar - notice issued to 3.

Mr. Marc Dupuis Director General, Engineering, Planning and Standards Branch Industry Canada 19 th Floor, 300 Slater Street Ottawa ON K1A 0C8

ECC Decision (17)06. Approved 17 November 2017

Technical Requirements for Cellular Radiotelephone Systems Operating in the Bands MHz and MHz

(Text with EEA relevance)

WHITE PAPER ON UPPER 700 MHz A BLOCK SPECTRUM

Technical Requirements for Fixed Radio Systems Operating in the Bands GHz and GHz

UK Radio Interface Requirement 2020 for Radar 9 GHz (non-solas) in the maritime radionavigation service

Variation of UK Broadband s spectrum access licence for 3.6 GHz spectrum

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. ) ) ) ) )

Official Journal of the European Union DECISIONS

(Text with EEA relevance)

Technical Requirements for Fixed Wireless Access Systems Operating in the Band MHz

Deregulating Futures: The role of spectrum

Licensing Procedure for Automatic Meter Reading Equipment in the 1.4 GHz Band

Business radio light licence application form OfW432

Guidelines for the Submission of Applications to Provide Mobile-Satellite Service in Canada

COMMISSION IMPLEMENTING DECISION. of XXX

Response to Ofcom consultation: Consultation and information on technical licence conditions for 800MHz and 2 6GHz spectrum and related matters

Submission by Free TV Australia Limited

GOVERNMENT GAZETTE REPUBLIC OF NAMIBIA

Dynamic Spectrum Alliance response to consultation on the ACMA Five-year spectrum outlook

COMPATIBILITY BETWEEN NARROWBAND DIGITAL PMR/PAMR AND TACTICAL RADIO RELAY IN THE 900 MHz BAND. Cavtat, May 2003

Spectrum for audio PMSE. Use of the 694 to 703 MHz band

FIXED WIRELESS ACCESS (FWA) SPECTRUM ENGINEERING & FREQUENCY MANAGEMENT GUIDELINES (QUALITATIVE)

Mobile Data Strategy Statement Publication date: 28 May 2014

UK Interface Requirements to IR

Vodafone Response to Ofcom Consultation: Mobile Coverage Enhancers and their use in licensed spectrum

UK Interface Requirement 2044

NOT GOVERNMENT POLICY. 174 to 184 MHz: Land Mobile Radio technical consultation

Strategic Review of UHF Spectrum at MHz UHF Bands 1 and 2

Re: Gazette Notice SLPB : Consultation on Releasing Millimetre Wave Spectrum to Support 5G

Appendix A: Our current practice in setting AIP fees An appendix to SRSP: The revised Framework for Spectrum Pricing

Policy guidance regarding authorisation for Earth Stations on Vessels (ESVs)

Guidelines for communication system of smart meters PLC, RF, cellular network (3G/4G) CENTRAL ELECTRICITY AUTHORITY

WIA Repeater and Beacon Licence Recommendation Policy August Background

Determination, Control & Improvement of an SKA Radio Environment in South Africa

ELECTRONIC COMMUNICATIONS COMMITTEE

DSA Submission to the Telecom Regulatory Authority of India Consultation on Public Wi-Fi

Recognised Spectrum Access (RSA) for Receive Only Earth Stations Statement on the making of regulations to introduce RSA in the frequency bands 7850

RADIO SPECTRUM COMMITTEE

Official Journal of the European Union

Application Form for a Business Radio Area Defined Licence

BANZINET RESPONSE TO: DRAFT FREQUENCY MIGRATION REGULATION AND FREQUENCY MIGRATION PLAN AUGUST 2012

Response to Ofcom s Consultation on Administrative Incentive Pricing

Licensing Procedures Manual for Satellite (Non-Fixed Satellite Earth Station) Applications

The release of spectrum within the frequency ranges 143 MHz to 169 MHz

UHF Radiomicrophones:

Transcription:

JRC Response to the Consultation on More Radio Spectrum for the Internet of Things JRC Ltd Dean Bradley House 52 Horseferry Road London SW1P 2AF United Kingdom +44 (0)20 7706 5199 +44 (0)20 7222 0100 info@jrc.co.uk www.jrc.co.uk/about KEY POINTS JRC welcomes the opportunity to respond to this consultation regarding this unused VHF Low Band and Band I spectrum. JRC suggests that the term Machine-to-Machine (M2M) should be interpreted widely and not assumed to be technology specific JRC highlights that the utilities have been operating Resilient Machine to Machine (RM2M) systems for over 50 years. JRC highlights that the electricity utilities typically use the 400 MHz UHF band for their RM2M systems because of the lower noise floor in this spectrum when compared with VHF spectrum. The problem being that the occasional electrical discharges from sub-stations, power lines, etc, are a source of very low-level radio interference to nearby VHF band radio receivers so self-interference may result if VHF channels are used. JRC understands that the lower VHF spectrum suffers higher levels of noise floor interference than the VHF Mid Band and High Band spectrum. JRC highlights that tropospheric propagation may result in harmful interference to UK systems from its European neighbours. This may result in VHF Band I not being suitable as part of a resilient system. JRC highlights that, whilst access to more spectrum in bands below 1 GHz is needed by the power utilities if they are to fulfil their regulatory obligations to maintain secure and sustainable supplies of electricity and gas, and to restore supplies in a timely manner when those supplies are interrupted for any reason, the proposed Band I and VHF Low Band spectrum may not be suitable. JRC agrees that the current Business Radio licence products, e.g. Area Defined licences, may be suitable for M2M systems within this Band I and VHF spectrum. JRC notes that the lengths and inefficiencies of antennas typically used within this spectrum may be an issue for handheld equipment. JRC notes that, like other bands, there may be interference issues if wide-band systems are assigned adjacent to 12.5 / 25 khz systems.

Consultation questions and JRC's responses Q1a. Do you agree that the spectrum we have identified (in figures 4.2 and 4.3 above) is suitable for M2M applications for remote and rural locations? JRC agrees that this spectrum could be used for narrow band machine to machine (M2M) systems but is mindful of the problems of a relatively high noise floor and the potential interference issues caused by intermittent tropospheric propagation. So, whilst the communications distances may be greater than, say, low power short-range UHF / GHz M2M systems, these two issues could limit the anticipated working range of systems operating within these two bands. Q1b. Please provide as much information as possible on likely applications. JRC highlights that, with the potential noise floor and interference issues, it has not traditionally been expected that this spectrum is suitable for resilient machine to machine (RM2M) systems. JRC highlights, however, that this expectation may change if trials within the utility industry of new digital equipment prove successful. Q2. Do you agree with our analysis that encouraging new IoT uses in the bands 55.75625-60 MHz, 62.75625-64.8 MHz and 64.8875-66.2 MHz, 70.5-71.5 MHz and 80.0-81.5 MHz should still leave sufficient spectrum to meet demands for Business Radio in the VHF range? JRC agrees that limiting the proposed M2M / IoT systems to VHF Low Band and Band I will not impact existing and future systems assigned within VHF Mid Band or VHF High Band. JRC understands that VHF Low Band (and Band I?) is occasionally used for wide-area PMR systems. The channels in which they operate will need to be protected from co-channel and adjacent channel interference from M2M / IoT systems, especially around the remote boundaries of the PMR systems. Q3a. Do you think the conditions associated with the current range of BR licences available now should change to facilitate new IoT services uses? JRC considers that no changes are necessary because the current range of Business Radio licence products should be sufficient for most narrow band radio systems, including M2M / IoT systems, using these bands. JRC recommends that, to minimise potential hoarding / warehousing scenarios, the channels should be assigned on a first-come first-served basis. JRC recommends that the existing Administrative Incentive Pricing (AIP) should apply to fees in these bands.

JRC suggests that potential major system owners would primarily seek Area Defined licences in VHF Low band because of the following three advantages: Wide Area Defined licences should ensure that their systems can be sufficiently well planned so as to maximise frequency re-use and minimise the risk of co-channel interference from adjacent UK systems; Area Defined licences are preferred because the processing of individual Technically Assigned licences is likely to be time consuming, and involve significant administrative costs to Ofcom, e.g. to process international co-ordinations, and perhaps unnecessarily delay the deployment of systems; and Low Band would be preferred because there is not a formal VHF Low Band MoU agreement between the UK and its neighbours. This means that licensees may independently predict and confirm their own coverage areas instead of using the Post Issue Support Process (see OfW64) that is necessary for Band I, Band III, and UHF 1 systems. (The Post Issue Support Process requires Area Defined licence holders to notify Ofcom if they are not able to independently predict and confirm that any proposed system will not cause harmful interference to other UK services or those of neighbouring administrations.). JRC understands that, in addition to national co-ordination requirements, any proposed UK VHF Low Band system should not breach the interference threshold requirements of the Harmonised Calculation Agreement (HCM) MoU. Proposed systems that breach the relevant level may need to undergo a lengthy international co-ordination process. JRC uses industry standard radio planning software so it is well placed to independently predict and confirm the coverage of the systems that it manages. Q3b If you do, what should these changes be? JRC suggests that there is a potential for innovative higher modulation level equipment to be used in some of these narrow band channels. JRC suggests that this spectrum could also be used for innovative wider bandwidth systems. These systems could be licensed using multiples of 12.5 khz channels with a licence fee proportionate to the number of 12.5 khz channels. (Wide-band users will also need to licence any guard-band spectrum that is required to stop the system from interfering with adjacent 12.5 khz systems.) JRC suggests that, for Technically Assigned licences and Post Issue Support of Area Defined licences, it may be necessary for Ofcom to update its licensing software to take into consideration the increased wanted to unwanted ratios and other planning criteria that the above innovative wide-band equipment may require.

Q4. Do you think we should create a new licence product specifically for IoT services? JRC suggests that existing Business Radio Technically Assigned and Area Defined licences will be suitable for narrow band M2M / IoT systems. JRC suggests that Exclusive Use channels will be needed for systems that need instant and / or constant access (e.g. data links) whereas Shared Use channels may be used when only occasional access is required. JRC suggests that only Area Defined licences should be made available for systems intending to operate innovative wide-band systems because of the potential cost to Ofcom to update its licensing software, etc. NB: the licenced spectrum should include any guard-band requirements needed to prevent the wide-band system interfering with any adjacent systems.

The Joint Radio Company Ltd (JRC): JRC Ltd is a wholly owned joint venture between the UK electricity and gas industries specifically created to manage the radio spectrum allocations for these industries used to support operational, safety and emergency communications. JRC manages blocks of VHF and UHF spectrum for Private Business Radio applications, telemetry & tele-control services and network operations. JRC created and manages a national cellular plan for co-ordinating frequency assignments for a number of large radio networks in the UK. The VHF and UHF frequency allocations managed by JRC support telecommunications networks to keep the electricity and gas industries in touch with their field engineers throughout the country. These networks provide comprehensive geographical coverage to support the installation, maintenance and repair of plant in all weather conditions on a 24 hour/365 days per year basis. JRC s Scanning Telemetry Service is used by radio based Supervisory Control and Data Acquisition (SCADA) networks which control and monitor safety critical gas and electricity industry plant and equipment throughout the country. These networks provide resilient and reliable communications at all times to unmanned sites and plant in remote locations to maintain the integrity of the UK s energy generation, transmission and distribution. JRC manages the microwave licenses for the majority of UK gas and electricity transmission and distribution businesses. JRC protects these microwave links and the above UHF telemetry links from potential interference from wind turbines, and advises wind farm developers on mitigation methods to avoid interference with all forms of radio communication services. JRC also undertakes radio consultancy work associated with critical national infrastructure radio services, and participates in European and international regulatory consultation groups. JRC works with the Energy Networks Association s Future Energy Networks Groups assessing ICT implications of Smart Networks, Smart Grids & Smart Meters. Internationally, JRC supports or participates with global utility telecoms organisations under the umbrella of the Global Utility Telecom Council: US Utility Telecom Council (UTC) European Utility Telecom Council (EUTC) Latin American Utility Telecom Council (UTCAL) Canadian Utility Telecom Council (UTCC) African Utility Telecom Council (AUTC) ENDS

Cover sheet for response to an Ofcom consultation BASIC DETAILS Consultation title: To (Ofcom contact): Name of respondent: More Radio Spectrum for the Internet of Things Stephen.Jones@ofcom.org.uk Adrian Grilli Representing (self or organisation/s): The Joint Radio Company Ltd (JRC) Address (if not received by email): as received by email CONFIDENTIALITY Please tick below what part of your response you consider is confidential, giving your reasons why: Nothing: Name/contact details/job title: Nick Woollard, Nicholas.Woollard@jrc.co.uk Project Manager Whole response: Organisation: JRC Part of the response: If there is no separate annex, which parts? If you want part of your response, your name or your organisation not to be published, can Ofcom still publish a reference to the contents of your response (including, for any confidential parts, a general summary that does not disclose the specific information or enable you to be identified)? JRC would prefer the contents of the annex to remain confidential until otherwise agreed. DECLARATION I confirm that the correspondence supplied with this cover sheet is a formal consultation response that Ofcom can publish. However, in supplying this response, I understand that Ofcom may need to publish all responses, including those which are marked as confidential, in order to meet legal obligations. If I have sent my response by email, Ofcom can disregard any standard e-mail text about not disclosing email contents and attachments. Ofcom seeks to publish responses on receipt. If your response is non-confidential (in whole or in part), and you would prefer us to publish your response only once the consultation has ended, please tick here. Name Adrian Grilli Signed (if hard copy)