bt by wuzhengqin


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       5.150 TO 5.875 GHz.

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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.


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.


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

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
    -    Would it be possible to offer a satisfactory quality of service for a public service in a shared
    -    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

  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

       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.


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

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.


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
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 –     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
5650 –   To be used by HIPERLAN Type 2 for
5725     private applications only.
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)

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