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IN CONFIDENCE
BT RESPONSE TO THE RA's CONSULTATION
DOCUMENT:
SHORT RANGE, HIGH DATA RATE,
NOMADIC EQUIPMENT OPERATING
IN THE FREQUENCY RANGE
5.150 TO 5.875 GHz.
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1. INTRODUCTION
This is BT’s response to the RA Consultation Document "Short range, high data rate, nomadic
equipment operating in the frequency range 5.150 TO 5.875 GHz". An initial general positioning
statement is followed by more detailed account of BT’s view of the private and public use split,
specific responses to the five questions posed by the RA and finally a table, which takes the RA
proposals outlined in paragraph 10.4 of the consultation and adds BT’s comments on each. We
believe that there is a clear case for further studies into the possibilities for allocation of this
spectrum band as detailed below. For this reason, this response should be treated as a top level
“qualitative” response rather than an in depth “quantitative” one. Following various discussions
with the RA we understand that it is of the view that responses to this consultation may be expected
to provide a good steer for further action (both in terms of work that may need to be done, but also
in terms of possible levels of interest in the variety of potential outcomes.) We fully expect that
there may be a need for a further round of consultation prior to possible allocation of spectrum and
we look forward to participating fully in any further work which precedes such allocation.
2. OVERVIEW OF BT POSITION
BT believes that there is a need for the use of HIPERLAN in both public and private access systems
and that ultimately it is essential that both be accommodated. Some examples of possible market
opportunities are outlined below. Therefore BT supports the licensing of spectrum for public use.
Although the current regulatory framework need not be changed to permit this, it will be necessary
to understand how best the spectrum can be used support both types of use, in particular to ensure
that QoS issues are fully considered.
In future BT believes that it would be reasonable to restrict spectrum availability for HIPERLAN 1
in favour of HIPERLAN 2 which is more feature rich.
On the whole BT does not support the concept of developing a “HIPERLAN 0”, but more
particularly would be very much against the development of a “UK only” position on this, which
has, in our view, the potential to be damaging.
3. USE OF SPECTRUM IN BOTH PUBLIC ACCESS AND PRIVATE SPACE
The following briefly outlines our perception of the requirement in, firstly, the public space and
secondly, private in-home applications. It also seeks to indicate some of the concerns we have with
such “dual” use, and poses some questions However, it is not clear to us how best this may be
achieved, hence the call for further studies to consider the spectrum sharing and or partitioning
possibilities.
3.1 Public Access systems
BT believes that there is a requirement for public access systems in these bands, and would
encourage the RA to consider issuing licences for such a service. We believe that there will
be a demand for local area public access to the internet in urban areas, and that the current
absence of such a network (as noted in paragraph 9.6 of the Consultation Document) could
be addressed by allowing public access to a data network using the HIPERLAN interface in
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this band. We understand that a number of manufacturers share our interest in the use of
HIPERLAN for providing public access.
The kind of system envisaged would be a pico-cellular network in major urban centres, and
other locations where there are high public densities, such as shopping malls, railway
stations and airports.
However, before public access systems could be offered, it would be necessary to undertake
technical studies to determine whether or not spectrum partitioning would be required
between the public and private systems, or whether they could share the same frequency
band. We believe that further information would be required about the likely deployment of
the public and private systems before a conclusion could be reached.
We propose that the following questions be considered before a decision is made on
spectrum partitioning between public and private systems:
- What would be the relative demands for the two systems?
- How close (geographically) would public and private systems typically be located?
- Would it be possible for public and private access systems to share a given frequency band
(e.g. 5470 - 5650 MHz) if the private systems operate at a lower EIRP (e.g. 200 mW) in that
band?
- Would it be possible to offer a satisfactory quality of service for a public service in a shared
band?
- Might it be possible to obtain European wide agreement for part of the band1 to be used on a
public access only basis?
BT would be happy to assist the RA in the further studies necessary, since we believe that
further work should be undertaken before a conclusion can be reached in this regard.
3.2 Private In-Home Systems
BT believes there will be consumer demand for two types of private wireless home network
to extend the wired networks that will exist or to replace them. Both will be required to carry
video services. Wireless will avoid the inconvenience involved in adding (unsightly) new
wiring and make it possible to include portable devices.
The first, termed a Home Local Network (HLN), will build on the IEEE1394 system which
is being standardised and implemented for interconnection of digital broadcast TV set top
boxes with other reception and storage devices elsewhere in the home. HIPERLAN 2 is the
only system that is being developed for IEEE1394. Even now it is clear that video based
applications will, in many cases, occupy the complete payload but this will be more true in
the future with HDTV.
There will also be simultaneous demand for a Home Access Network (HAN) to interconnect
with broadband interactive services delivered using ADSL, cable, MVDS etc. The main
1
It is noted that, whilst the ERC Decision (99) 23 on frequency bands for HIPERLANs has now been approved, during
the drafting there were problems raised by both NATO and France regarding the use of the band 5470 - 5650 MHz by
HIPERLAN. Since the Decision will be reviewed within 2 years, it is possible that the use of that band could again be
questioned. In such an event, the identification of (part of?) that band for licensed (and if necessary, co-ordinated) only
use could resolve any sharing problems.
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requirement is for delivery of IP based services to PC’s, Internet enabled STB’s and other
terminals. The HAN would, however, also be used for intra-home connections to other PC’s
and peripherals in the home. It will almost certainly use Ethernet as for the current wired
networks.
The HAN requirements are not currently as demanding as for the HLN because ADSL is
likely to be restricted to around 5Mbit/s. The data rate is, however, likely to increase to
25Mbit/s with VDSL and it is important to allow for this. Cable and MVDS could provide
even higher data rates. This means that although it might be possible to share capacity on
HAN carriers by time division multiplexing, the requirements for multiple simultaneous
services including HDTV in the future will make this less practical.
HIPERLAN 1 and 2 and IEEE802.11(a) are all suitable for Ethernet but it is not practical to
use HIPERLAN 2 to link to both Ethernet and IEEE1394 at the same time. Separation
between the HAN and HLN is also necessary to prevent the HLN applications seizing all of
the capacity, preventing delivery of the broadband access services that customers are paying
for. HIPERLAN 2 and IEEE802.11(a) (and the Japanese MMAC system) will use the same
chips for the physical layer which will ensure a global market.
This would indicate that there is a requirement for further studies to determine how best to
accommodate not only the requirements of public and private access, but, even within that,
the optimum allocation to ensure that private use systems can co-exist without the
requirement for an extra layer of spectrum planning at that level. Realistically, it is likely
that some degree of sharing will be possible for both the HLN and HAN even during the
busy period. However it is important that the possibilities and ramifications are properly
studied before allocations are determined.
4. RESPONSE TO SPECIFIC QUESTIONS POSED BY RA
Q1 HIPERLAN Type 1 and HIPERLAN Type 2 are each open interoperability standards
produced by representatives of manufacturing industry, application designers and potential users.
It is currently Agency policy that RLANs in the bands 5.150-5.350 GHz and 5.470-5.725 GHz
should be restricted to HIPERLAN equipment complying with the relevant ETSI specification. Is
there a case for the development of a parallel co-existence standard (HIPERLAN Type 0?) based
only on simple radio parameters to allow proprietary equipment to share the bands on a licence
exempt basis?
BT does not support the proposal for a general co-existence standard in the 5 GHz band
(“HIPERLAN 0”) as we believe this may result in the proliferation of proprietary equipment. This
could significantly undermine the considerable effort which has been undertaken by all elements of
the industry over a number of years to develop harmonised standards. However, we do believe that
other, existing RLAN standards should be recognised, and in particular, that provision should be
made to enable IEEE 802.11a equipment to be used in Europe.
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Q2 If HIPERLAN Type 0 is not adopted by ETSI for European wide introduction is there a case
for the UK to develop and introduce such a standard on a UK only basis?
As discussed abovewe do not support the development of a HIPERLAN “0” in any case. As a
separate issue we could definitely not support the development of “UK only” systems, particularly
when they are mobile/portable and will be readily carried within Europe. This will be even more
important for equipment which can form an ad-hoc connection, and is not therefore dependent upon
receiving a valid control signal from an existing network before it starts transmitting (i.e. unlike a
mobile ‘phone). The introduction of such equipment would set a very dangerous precedent and
could seriously prejudice the generally co-operative approach to standard setting which has served
us reasonably well in Europe.
Q3: Given the diversity of potential uses, what are the likely applications for these bands, what
development issues remain unresolved, and when and how will services be introduced?
The following details a list of potential applications enabled by Short Range (local area network)
radio that HIPERLAN 2 could support.
1. In-building working / domestic environment (e.g. offices, shops, home etc).
Accessed via PC, Laptop computer, Mobile phone, Palm, Personal Digital Assistant (PDA), Set-
top box (STB)
WEB Shopping / Software arcade Webpads, Games pads
Information and Entertainment (e.g. Video / Music)
Downloading Information (e.g. Music to device)
Home-networking (e.g.interconnection of PC with peripherals/Set-Top Boxes and
DVDs/DVCRs with STBs etc
Business Mobility Office applications
Unified messaging (integrated fixed / mobile voice, fax, e-mail mailboxes)
Data synchronisation (e-mail, diary, file / info sharing)
Mobile Secretary / Conferencing (voice & video)
2. Outdoor Wireless (tetherless) Access
Accessed via short range radio (HIPERLAN, Bluetooth, DECT) using devices such as
Cellphones, laptop computers, PDAs from locations such as Phoneboxes / Kiosks / Railway
stations / Service Areas:
Messaging, web-browsing
Information (download high bandwidth files – music / video)
Secure Transactions (electronic /mobile commerce)
Ticketing & Tolls
Location based services (information – Maps, Location specific Marketing Material, Tourism)
3. Many of these applications will in time be available:
Directly through the fixed network (devices linked to the network e.g. ADSL)
Indirectly through the fixed network via tetherless access (e.g. HIPERLAN / Bluetooth)
Directly through the Wide Area Network via GSM/GPRS or UMTS.
Ultimately, with seamless roaming across different environments using terminating equipment
able to access both fixed and mobile networks with no break of service.
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Q4: It is currently envisaged that HIPERLAN compliant services will be private system use only.
Is there a requirement for public access systems in these bands, what kind of systems would be
envisaged, and how should they be regulated?
As indicated in our general comments above, BT believes that there is a requirement for public
access systems in these bands, and would encourage the RA to consider issuing licences for such a
service. We believe that there will be a demand for local area public access to the internet in urban
areas, and that the current absence of such a network (as noted in paragraph 9.6 of the Consultation
Document) could be addressed by allowing public access to a data network using the HIPERLAN
interface in this band.
The kind of system envisaged would be a pico-cellular network in major urban centres, and other
locations where there are high public densities, such as shopping malls, railway stations and
airports.
Given that we advocate further studies into the sharing potential and partitioning possibilities in this
band, it is probably premature to discuss detailed regulatory frameworks. However, the use of
HIPERLAN as a solution will in almost all possible applications outlined at Q3 above be only one
of the possible technical solutions. It will be necessary to ensure that any regulation imposed does
not inadvertently distort the market for those various types of solution.
In general, BT supports the framework for regulation that already exists under the WT Act for
dealing with the licensing of public and private use of spectrum, although it can be envisaged that
with partitioning it may be necessary to devise ways of ensuring that the two “uses” can be
accommodated without unnecessary degradation to either and with the appropriate amount of
protection for both. It is difficult to conceive of any specific regulatory requirements which would
be generated by licensing of this particular spectrum under the Telecommunications Act which is
not already paralleled elsewhere. The important consideration, however, would be to ensure
equality as far as possible, and transparency and perhaps parallelism across the licensing of
technologies which all sought to address the same markets.
Q5: Within the HIPERLAN family of standards, HIPERLAN Type 1 and HIPERLAN Type 2
systems are technically incompatible, therefore how best should these bands be assigned, given the
aim of frequency assignment is to ensure that the maximum numbers of users get appropriate and
fair access to spectrum for their applications? In considering this it should be borne in mind that
these devices are likely to be incorporated into Recommendation 70-03 which will permit their
movement across national borders and their licence exempt use across CEPT.
Since HIPERLAN Types 1 & 2 have different channel spacings (and hence different rasters), it
would be better to restrict the bands in which sharing is possible. This would limit the potential
problem of a HIPERLAN Type 1 terminal (with a channel bandwidth of 23.5 MHz), interfering into
two or even three HIPERLAN Type 2 channels terminals (and vice versa).
At this stage, since there are no HIPERLAN terminals in public hands, control of the usage of the
channels for the two types of HIPERLAN should be introduced and maintained. HIPERLAN Type
1 terminals are starting to be produced, however, we believe that they will have been designed only
for the lower frequency bands, because of the relatively recent revision of the ERC Decision on
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frequencies for HIPERLAN. Furthermore, with the rapid development of the HIPERLAN Type 2
standard, and immense industry support, it is anticipated that the HIPERLAN Type 2 equipment
should be available during 2001, offering greater functionality than HIPERLAN Type 1. We
therefore believe that there will be much more demand for HIPERLAN Type 2 equipment, and this
should be reflected in the amount of spectrum available for the two systems. Consequently, we
propose that HIPERLAN Type 1 should be restricted in operation to those frequency bands which
were initially identified for HIPERLAN, in the (now withdrawn) ERC Decision (96)03, whilst
allowing HIPERLAN Type 2 to operate in all of the bands.
The Consultation Document proposes a number of options for partitioning; these are re-produced
below, with BT’s comments.
Proposal Explanation BT comment
1 No partitioning All services co-exist on a licence This is the current situation, however we
of the bands. exempt basis. No public access believe that:
services are permitted a) it could lead to inefficiency due to
interference problems between
HIPERLAN Types 1 and 2, and
b) the absence of public access services
would deny an opportunity which
many in the industry are seeking
Therefore, we do not believe that this is
the best way to proceed.
2 No partitioning All services co-exist on a licence This could be a good way to proceed,
of the bands. exempt basis. Public and private however further study is required to
systems are permitted to co-exist. determine whether a public service could
However co-ordination and be offered with an acceptable quality of
interference resolution is the service.
responsibility of the operator and
third party customers are not
guaranteed access to spectrum at
all times.
3 Bands are Public access systems require This could also be a good way to proceed.
partitioned on licences and are co-ordinated. However further study is required to
the basis of Private systems are licence determine whether a band could be set
public exempt and uncoordinated. aside on a European basis for public
access/private access systems, and if not, whether the risk
system of unauthorised private operation could
requirements. interfere with the public access system.
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4 Bands are All systems are licence exempt BT believes that the bands shared by
partitioned on and uncoordinated. HIPERLAN Types 1 & 2 should be
the basis of restricted, to minimise the interference
HIPERLAN between the systems and hence optimise
Type 1 and 2 their usage of the channels. This could be
but not on done in conjunction with any of the
public/private options 1 to 3 above, rather than as a 4th
basis option.
In summary, BT believe that the best solution would be either option 2 or 3 above, depending on the
outcome of future studies into the potential for sharing between public and private systems, in
conjunction with a restriction on the bands shared by HIPERLAN Types 1 & 2.
PROPOSAL
BT proposes that the following spectrum plan be considered for HIPERLAN, for potential adoption
throughout Europe (through a revision of the ERC Decision):
Freq Proposal Notes
Band
5150 – To be used by HIPERLAN Types 1 & 2, Restrictions apply in ERC Decision
5250 and IEEE 802.11a for private applications. (99)23, namely indoor use only and with a
MHz maximum mean EIRP of 200 mW.
5250 – Until the recent ERC Decision (99) 23, This band (5150 - 5350 MHz) is assigned
5300 this band was only available to in the USA as a U-NII band, and therefore
MHz HIPERLAN Type 1 on a national basis. IEEE 802.11a RLANs are being
developed to operate in this band.
Therefore we propose that this band be
However, the U-NII equipment in the band
used only by HIPERLAN Type 2 and
5250 -5350 MHz is permitted to operate in
IEEE 802.11a for private applications.
the USA with an EIRP of 1 W, and
5300 – To be used only by HIPERLAN Type 2 therefore it will be necessary for IEEE
5350 and IEEE 802.11a for private applications. 802.11a terminals to reduce their
MHz maximum EIRP before they are permitted
to operate in that band in Europe.
5350 – None (Not licensed for HIPERLANs)
5470
MHz
5470 – To be used by HIPERLAN Type 2 Although this band has been assigned to
5650 systems only. HIPERLAN by ERC DEC(99)23, it was
MHz not unanimously accepted due to the
Part of the band should be used for public
presence of Maritime Radio-navigation
access systems, either on an exclusive
systems, and possible future EESS in this
allocation basis or shared with private
band. Using part of this band on a
applications (depending on the results of
licensed basis could eliminate any sharing
studies which need to be undertaken).
problems that might arise.
Those public access systems would be
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licensed by the National Regulatory
Authority.
5650 – To be used by HIPERLAN Type 2 for
5725 private applications only.
MHz
5725 – To be used by HIPERLAN Type 2 and HIPERLAN Type 2 could gain access to
5825 IEEE 802.11a for private applications. this band through the ERC
MHz Recommendation 70-03.
In the USA this is a U-NII band, and
therefore IEEE 802.11a products are being
developed to operate in this band.
5825 – (no proposal)
5875
MHz
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